BrilliantFIT – Privacy Policy

1 Your general data protection regulation rights (GDPR) 

As a company headquartered in Australia, we are required by law to comply with the Australian Privacy Principles. However, we have also decided to make some of our services available globally which covers the European Union. 

We have done this in order to extend the additional rights and data protection offered by the General Data Protection Regulation (GDPR) that came into force on the 25th of October 2019. 

A person’s digital rights under GDPR are a great step towards a digital society of equals. We support the GDPR and what it stands for. It is only right that any individual should have control over their personal data. 

As a company that has members that are both organizations and individuals we want You to know exactly what Your personal data rights are and we want everyone who uses BrilliantFIT to benefit from the world’s leading data regulations, regardless of where they live. In our Privacy Policy, we describe these rights in simple language and together with how BrilliantFIT meets them. 

We want all people to understand how the GDPR protects You, and how we are complying with it, so we have summarised Your key rights below:

 

Article

Description

Details

What We Are Doing

5

Principles

Personal data must be:

  • Processed lawfully, fairly and transparently;

  • Collected for specified, explicit and legitimate purposes (and processed accordingly);

  • Adequate, relevant and limited to what is necessary for purpose;

  • Accurate;

  • Stored in a minimal way;

  • Processed to ensure integrity and confidentiality.

BrilliantFIT has always been committed to these principles,long before the GDPR came into effect.

Our Privacy Promise & Policy sets out in detail how we comply with these principles.

6

Lawfulness of processing

Processing of Your data is only lawful if it satisfies one or more of the requirements of this Article.

This means that processing of

Your data is only lawful if:

  • Consent has been given;

  • Processing is necessary for the performance of a contract;

  • Processing is necessary to satisfy legal obligations; or

  • If one of the other conditions in this Article is satisfied.

You determine what data You want to have processed by BrilliantFIT.

BrilliantFIT will only process data based on either Your consent or by delivering You the Recruitment or People Development Service.

BrilliantFIT services enables You to add, access, control and share data with the people and organisations You trust.

7

Conditions for consent

BrilliantFIT must be able to demonstrate that You have given us consent.

Your consent must be given in a way that is:

  • Clearly distinguishable from other matters in document;

  • In an intelligible and easily accessible form;

  • In clear and plain language.

You have the right to withdraw Your consent at any time, and You must be informed of this prior to providing consent.

You provide Your consent to use Recruitment or People Development Service by creating an account and accepting our Terms and Conditions.

Once Your account is created, You can sign in at any time and share data from Your BrilliantFIT account on Your data access terms. 

Our Privacy & Policy sets out Your rights in relation to Your data, including Your right to permanently delete it from BrilliantFIT if You choose so in writing.

8

Child consent

BrilliantFIT does not knowingly gather information from any individual under 16 years of age.

The use of the platform and Talent Analysis Tool is reserved for individuals that are 16 and older.

Our Terms and Conditions state, at clause 2.1, that users in the European Union must be over the age of 16 unless they have parental consent.  

Clause 2.2 states that if You reside outside of the European Union You can’t use the XXXXXX Services if You are under the age of thirteen (13) without parental consent or authorisation. 

Clause 2.3 sets out how consent can be provided.

12

Transparency

Information that we are required to provide to You under the GDPR must be:  

in a concise, transparent, intelligible and easily accessible form;

in clear and plain language;

and

in writing, including electronically where appropriate.

srdfhsdfh have made our Privacy & Policy and Terms and Conditions clear with simple language to make sure You are fully informed about Your rights. 

We want to You to be in control of how Your data is used, it’s the reason why BrilliantFIT exists. 

At any time, if You ever have any questions or concerns, we encourage You to contact us.

13

Information that we must provide to You

Before we collect personal data from You, we must provide You with the following details: 

  • Our identity and contact details;

  • Purpose and legal basis for processing data;

  • Recipients of data; and

  • Any transfers outside of EU;

  • Length of time of storage of data;

  • That You have the right to request access to, rectification of, erasure or transfer of data;

  • That You have the right to withdraw consent;

  • The existence of any automated decision-making. 

If You already have this information, we are not required to provide it to You again.

This information is set out in our Privacy Promise and Policy. 

From time to time, as we roll out new services, there may be additional data that we support and therefore can collect for or from You. 

We will always fully inform You and seek Your consent before we do so.

15

Your Right of Access

You have the right to obtain confirmation as to whether Your personal data is being processed, and information as to how Your data is being processed.

You have full access to all of Your data in Your BrilliantFIT account.  

If You ever have any questions about how Your data is processed, You just need to ask.

16

Right of Rectification

You have the right to have incorrect personal information rectified and we encourage you to actively update your profile.

You will be able to rectify any data You add to BrilliantFIT using the edit, delete and update functions of Recruitment or People Development Services. For other data that is shared with You from third parties, You will need to rectify this directly with the third party as this data may be in read only format.

17

Right to be Forgotten

You have the right to obtain erasure of personal data where it is no longer necessary for the purpose it was collected for, or where consent is withdrawn.

You have the right to delete Your BrilliantFIT account anytime by emailing us to do so.

18

 
Right to Restriction of Processing
 

You have the right to restrict processing of Your data where the accuracy or erasure of the data is opposed and certain other criteria are met.

You are in control of Your data. It’s the reason BrilliantFIT exists.

20

Right to Data Portability

You have the right to receive a copy of the information that You have provided to us in an accessible form.

You can export your data from your BrilliantFIT account.

21

Right to Object

You have the right to object to certain uses of Your data, such as where it is processed for internal marketing purposes (directly from BrilliantFIT).

You control how we use Your data, and we will not process it in any way that doesn’t have Your consent. However, if You ever have any issues, You just have to tell us.

22

Automated Processing

You have the right not to be subject to a decision based solely on automated processing that produces concerning legal effects or significantly affects You, subject to certain exceptions.

BrilliantFIT doesn’t read Your data or reach automated decisions about Your data. 

If we ever introduce an automated processing service it would only be with Your consent.

 

2 Privacy & policy 

Data rights and digital sovereignty are important to BrilliantFIT. This includes protecting Your privacy and ensuring You have the access and control to decide how Your data is used.  

Whilst BrilliantFIT was conceived and created in Australia we are expanding into the US, Asia, and Europe. We especially value that both Australia and the European Union have strict ways to provide greater protection and more privacy rights for any individual. 

If You live in Europe or use data services in Europe, as of 25th October 2019 You will have increased digital rights under the General Data Protection Regulation or GDPR.  

Because BrilliantFIT was designed with increasing privacy levels in mind, many of these important data rights have already been built into BrilliantFIT for how You and we manage and process Your data. 

Here is the citizens’ rights language word for word from the GDPR, including a summary of how BrilliantFIT enables these rights for You. 

Easier access to their data

Our detailed privacy policy clearly explains what information we collect and process, why and when plus how we collect, hold, use and disclose Your personal information. We aim to make this as easy to understand as possible instead of technical legal language. 

A new right to data portability

Your data is 100% portable. Export it, share it, or permanently delete it from BrilliantFIT, it will always be Your choice.

 A clearer right to erasure (right to be forgotten)

You have the right to delete Your BrilliantFIT account anytime by emailing us to do so. If You later change Your mind and decide You’d like to have a BrilliantFIT account once again, we will welcome You back with open arms. Though, You will have to recreate all of Your data via the BrilliantFIT Discovery process. When we say we deleted it, your original data cannot be refreshed and hence you will need to recreate your data.

Right to know when their personal data has been hacked

If BrilliantFIT were ever hacked and/or suffered a serious data breach, we would inform You promptly as well as notify the relevant European and or Australian data protection supervisory authority. 

2.1 How we collect, manage and use your data? 

The following points set out our Privacy Policy with respect to how we collect, manage or use Your data. 

We are committed to clearly expressing our Privacy Policy and keeping it up to date. This Policy was last updated on 23rd March 2021. 

  • Make sure we take reasonable steps to implement the practices, procedures and systems to ensure we comply with relevant Australian and European Privacy Principles and Codes.

  •  Only collect all sensitive information with Your consent, only collect information that is necessary for You or the Parties You authorise to perform the functions and activities You have agreed to.

  • Advise You of the kind of information collected and held, how we collect it and how we take care of it to protect Your privacy and Digital Rights.

  • Advise You of the purpose for which Your information is collected, stored, used and disclosed.

  • Provide access to Your personal information and seek to correct Your information stored by BrilliantFIT or within BrilliantFIT Services at any time either by You writing to us at privacy@brilliantfit.co or simply updating all the information You control through any of the BrilliantFIT Membership Services You use.

  • Do our best not to let You down, but if we inadvertently do something that makes You want to complain please let us know immediately at privacy@brilliantfit.co

  • As BrilliantFIT is part of a global community, some of the services we use to support BrilliantFIT are based in the USA and Australia and in the future may be based in other locations. We have chosen to make BrilliantFIT subject to the same Privacy commitments.

  • When we collect Your personal information, we will make it clear so you understand what is being collected.

  • The web is global, and it is important that You know that Your information may cross borders.

  • Under Australian and European regulation, we need to tell You when this happens. If You reside outside of these regions, then obviously You will be moving Your data around.

  • Your data is 100% portable. Export it, share it, or permanently delete it from BrilliantFIT, it will always be your choice. 

2.2 How does BrilliantFIT address privacy when developing BrilliantFIT software and services? 

BrilliantFIT is developed using a methodology called “Privacy by Design”. This is a way of thinking about privacy in advance and planning for it throughout the entire design and engineering process.

2.3 Will BrilliantFIT ever sell your data? 

We do not sell Your data. We will never give access to your Data to a third party (unless we are legally required to). We will always be transparent with You about our business model, terms and management of Your Data. In addition to our Privacy Policy, our Terms and Conditions also detail explicitly how our products work, including a detailed description of how Your Data is handled.

2.4 What information do we collect and process? 

When  You  use  the  Brilliantfit.co website, BrilliantFIT collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. 

When You log into the BrilliantFIT Platform Service, You provide to us Your email address, first name, last name, and the BrilliantFIT password chosen by You. Your password is encrypted and is not accessed by us. 

For the BrilliantFIT Platform Service, BrilliantFIT enables You to collect and direct us to process the data on Your behalf. This includes all of the information You, and only You, choose to put into the Application including but not limited to, personal information, open data available through Your authentication,  such as social  data, browser  history,  session  cookies,  brand associations, age, gender and geolocation. BrilliantFIT will not share this information with anyone else without Your consent. 

For the purposes of analytics on our Website, BrilliantFIT collects Your geolocation, browser and time spent on certain web pages. We only collect this information so that we can provide you with the BrilliantFIT Services, we do not sell it or provide access to it to third parties.

2.5 Why do we collect, hold, use and disclose Your personal information? 

BrilliantFIT’s purpose in collecting Your personal information is to better understand how visitors use our website, and to enable us to provide You with the BrilliantFIT Service. From time to time, BrilliantFIT may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of our website or anonymous intentions. 

BrilliantFIT holds Your personal information on its servers which are hosted by Amazon Web Services (AWS) and Backed up in Microsoft Azure Cloud, and located in Sydney, Australia.

2.6 Whom do we disclose Your personal information to and why? 

We may use the following Third Parties when providing BrilliantFIT Services: 

Third Party Supplier

Description

Country Where Data Is Physically Stored

Registered Office Country

Personal Data Stored or Processed

Mail Chimp

Email service provider

USA

USA

Your email address. When registering via a MailChimp email, the service can identify Your location, time zone and device.

Elevio

Customer service platform

Australia, USA

Australia

Support tickets and any communications with support agents

Microsoft Azure

Data hosting

Ireland

USA

All user data is encrypted and stored securely within Azure

Amazon Web Services

Data hosting

Australia

USA

All user data is encrypted and stored securely within AWS

 All of these Third Party Services will also be responsible for GDPR compliance for European Data Subjects. 

2.7 When will we notify You of the collection of Your personal information? 

BrilliantFIT has given You notification of the collection of personally identifiable information in this Privacy Policy. If We collect any information that is not notified in this Privacy Policy, we will give You notification of the collection of personally identifiable information at the time that BrilliantFIT or one of its services collects the data. 

2.8 Will we disclose Your personal information to overseas recipients? 

BrilliantFIT allows You to interact with Third Parties in data exchange – We will assist an exchange of personal information sometimes between You and an external third party. An example is you applying for a job at an organisation. Your data as a candidate will be viewable by the organisation and they may choose to communicate with you in a secure manner via the BrilliantFIT Platform.

These Third Parties can be located anywhere in the world or have subsidiaries in such locations. You will decide to exchange Your personal information with these Third Parties, BrilliantFIT will not disclose any of Your personal data unless You explicitly use our applications or tell us to. 

In some cases, overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure. 

Some of the Third Parties we use to provide the BrilliantFIT Services to You are located overseas, as detailed above. 

2.9 Can You be anonymous or use a pseudonym? 

Due to the nature of the BrilliantFIT services, which You may wish to access, you will require You to be identified. You will always have the choice, if and when You use these services. Also, if we don’t know who You are it may impact support or requests to share information with You. 

2.10 Will we direct market to You? 

BrilliantFIT will only use Your Data that we collect during registration for the purpose of ‘Direct Marketing to you’ with Your consent. BrilliantFIT will use this information to alert You of new features or features that are being under-used by You. 

As BrilliantFIT adds new services, we will communicate to You directly either through the BrilliantFIT platform or via opt-in email. 

You will always have the option to turn off notifications or opt out of any marketing.

If You do this, we will let You know how that might impact You or the functionality of BrilliantFIT. Additionally, under GDPR, You will also be given this option as part of creating an account as well as when You receive the direct marketing material. 

2.11 Can You access or change Your personal information? 

You can access and/or change Your personal information at any time using Your login. Alternatively, contact us at privacy@brilliantfit.co and we will help You access or change Your personal information. 

2.12 How do we resolve Your privacy issues and complaints? 

Have a concern regarding Your personal info? Tell us! Here’s how. 

If You have a complaint about how we handle Your personal information, we want to hear from You. You are always welcome to contact us through any of the following: 

Email

By sending an email to privacy@brilliantfit.co 

In Writing by Mail

BrilliantFIT Pty Ltd company registered in Australia. You can write to us by sending mail to either of these registered offices: 

 22 Acacia Pl, Abbotsford

Vic 3067

Australia 

If You still feel that Your issue hasn’t been resolved to Your satisfaction, then You can raise Your concern with the Office of the Australian Information Commissioner 

Online

www.oaic.gov.au/privacy

 Phone

1300 363 992

 Email

enquiries@oaic.gov.au

 Fax

+61 2 9284 9666

 Mail

GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601

3. Glossary 

Word

Plain English

The Way Our Lawyers Explained it

Data

Any data, information or image added by You or Others.

Information, data or images added by either You, BrilliantFIT, or another Third Party as applicable.

Your Data

The personal Data about You which You add.

Your data and information, including both personally identifiable information and non- personally identifiable information, about You that is uploaded by You to BrilliantFIT services. Your Data does not include Third Party Data or Third Party Content.

BrilliantFIT Services

The Dashboards and BrilliantFIT Features which enable You to create Your unique profile and manage Your Data as described in this Agreement.

All of the features of the web applications and the iOS applications, where You can aggregate, curate, store and manage Your Data, download Third Party Data and grant permission to Brands, Social Networks and Third Parties to access and use Your Data and Your Third Party Data, as more fully set forth in this Agreement.

Third Party

Someone else, who is not You or BrilliantFIT

A person or an entity other than BrilliantFIT who You allow to access Your Data or otherwise interact with or communicate with, using the BrilliantFIT Services or otherwise

Third Party Content

Content that is about or for You but has come from another source.

Content and information provided to You through a BrilliantFIT Service that is not or may not be the property of You.

Your Third Party Data

Data about You that You download with permission from the source.

Data, information and content that is downloaded or added by You through a BrilliantFIT Service from a Third Party at Your request and with the permission of such Third Party.

General Data Protection Regulation

The General Data Protection Regulation is a new European Union law designed to give increased digital rights and protections to EU citizens.

The EU General Data Protection Regulation (GDPR) replaces the Data Protection Directive 95/46/EC and was designed to harmonize data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organizations across the region approach data privacy.

Data Controller

A Data Controller is the person or entity that controls what happens with the data.

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Data Processor

A Data Processor is the person or entity that processes the data on behalf of the Controller and in accordance with their direction.

The natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Data Subject

A Data Subject is You.

The Data Subject is a living individual to whom personal data relates.

Supervisory Authority

A Supervisory Authority means an entity set up to ensure Your data rights are enforced under GDPR.

The Supervisory Authority means an independent public authority which is established by a Member State pursuant to Article 51.

 

BrilliantFIT’s approach to protecting personal information

BrilliantFIT Pty Ltd (BrilliantFIT, we, us, our) is committed to handling your personal information in a uniform, equitable and ethical manner. The protection of your personal information is something BrilliantFIT takes very seriously. Personal information is information about you that identifies you or from which you are reasonably identifiable. BrilliantFIT is bound by the Australian Privacy Principles (‘APPs’) in the Privacy Act 1988 (Cth).

Please take a moment to read our Privacy Policy as it describes what happens to your personal information, which is collected by the information technology platform here termed the BrilliantFIT Member Service or Service.

The BrilliantFIT Member Service is defined as any software offered by BrilliantFIT and accessed by consumers (consumers, customers or users) or Organisational staff via Apple iOS Apps, Android Apps, in web format at brilliantfit.co or via software installed in organizations and any other software or documentation which supports the Service.

Our Privacy Policy is divided into two parts:

  • Part 1: BrilliantFIT Consumer Members

  • Part 2: BrilliantFIT Member Organisations

Part 1 – BrilliantFIT Consumer Members

Introduction

Part 1 of our Privacy Policy describes how BrilliantFIT handles the personal information of consumers who use the BrilliantFIT Member Service.

In Part 1, ‘you’ refers mainly to consumer users of the BrilliantFIT Member Service. Collection of your personal information

BrilliantFIT will collect and hold your personal information in a fair and lawful manner, and not in an unreasonably intrusive way. Where it is reasonably practical to do so, we will collect your personal information directly from you.

Direct Collection

We may collect the personal information you directly give us through some of the following means:

  • When completing the registration process for the BrilliantFIT Member Service and other related correspondence (whether in writing or electronically).

  • When you apply for a job posted on BrilliantFIT

  • While conducting customer satisfaction and market research surveys

  • In the course of supporting you either directly or as a member of BrilliantFIT

  • When administering any of our services, and

  • As otherwise required to support or provide the BrilliantFIT Member

Automatic Collection

We may collect personal information automatically through some of the following means:

  • We may receive location data passed to us from third-party services or GPS-­enabled devices you have set up

  • We may collect information about how you use the Service to assist us to provide you with more tailored services, and to enable us to develop and improve our services

  • We may also collect information from the devices and networks that you use to access the App/s to help us develop and secure our services, and

  • We may use ‘cookies’ to store and sometimes track information about

Types of personal information we collect

To use our Service, you will need to provide us with at least your name, your email address and elect a password.

You may provide further information to allow us to tailor our services. This information can include (but is not limited to) your date of birth; your title, your gender; your postcode; your contact details including mobile phone number; and your address.

After you sign up, the BrilliantFIT Member Service will only collect information about your job application when you provide them in response to a listed job advertisement by a company participating in the BrilliantFIT Member Service.

The BrilliantFIT Member Service may also collect information that you choose to enter into it, for example, in the career learnings and experience profile, your career talent profile and your career interests survey.

Our purposes for handling your personal information

As a general rule, BrilliantFIT only processes personal information for purposes that would be considered relevant and reasonable in the circumstances of career development and direct job applications. BrilliantFIT will only collect information that is necessary for the purposes as described in this Privacy Policy, or other purposes specifically communicated to you. BrilliantFIT uses fair and lawful methods to collect personal information.

BrilliantFIT collects, holds, uses and discloses personal information to:

  • Provide the BrilliantFIT Member Service to you for your career development and job application processes

  • Share the information stored on the BrilliantFIT Member Service with any registered organization who is involved in accessing your information for applicable roles within their organization

  • With your consent, enable BrilliantFIT to access your personal information in order to assist you with a support query via voice/email/text conversation

    comply with its legal and regulatory obligations, and

    otherwise provide the BrilliantFIT Member Service in appropriate

Use and disclosure of your personal information

We may disclose your personal information to our employees, professional advisors or contractors to help us run our business. Each of our employees, advisors and contractors is bound by obligations of confidentiality and by the terms of this privacy policy.

De-identified information

We may use your personal information in de‐identified form (de­‐identification being a process by which a collection of data or information is altered to remove or obscure personal identifiers and personal information) and to assist us in running our business. We may also provide de‐identified information drawn from the BrilliantFIT Member Service in aggregated form, to third parties. This information may include (but is not limited to):

Locations of users

types of roles applied for functions accessed by users including analytics of use of the BrilliantFIT Member
When referring to the use of ‘aggregate data’, this means the aggregate of data composed of at least 10 or more member records.

When your personal information is included in de­‐identified, aggregated data, it is not possible to identify you or anything about you from that data. We may use your de­‐identified data to offer services such as sending automatic messages to you with training and career specific information relating to your needs. This service will be offered to you with an option of opting­‐out of these communications and additional services.

Value -­ Added Messages

We may provide you with information such as tips, advice about your career, and job search activities. We may also provide you with invitations to participate in research relevant to the areas you are interested in. We will not disclose your personal information to third parties for marketing purposes.

You may opt-out at any time if you no longer wish to receive commercial messages generally or about any specifically prescribed service offering. You can make this choice by selecting this “opt­‐out” feature you’re your personal settings.

Accessing and correcting your personal information

You may access your personal information that we hold about you and/or to make corrections to that information, at any time by updating these details when you login.

If you no longer wish to use the BrilliantFIT Member Service, you may opt-­out of the Service by requesting the cancellation of your use of the Service to our Privacy Officer (privacy@brilliantfit.co) and your personal information will be deleted or de­‐identified permanently.

Protection of personal information

BrilliantFIT maintains appropriate physical, procedural and technical security for its offices and information storage facilities so as to prevent any misuse, interference or loss, or unauthorized access, disclosure, or modification of personal information. This also applies to disposal of personal information.

BrilliantFIT further protects personal information by restricting access to personal information to those who need access to do their job.

Overseas Transfers of Personal Information

We do not disclose, store or transmit any of your personal information overseas.

 

Part 2 – BrilliantFIT Member Organizations

Introduction

Part 2 of our Privacy Policy describes how BrilliantFIT handles data collected and stored for participating BrilliantFIT Member Organisations, and the staff of those Member Organisations.

In Part 2, ‘you’ and ‘your’ refers to an Organisation that uses the BrilliantFIT Member Service.

Part 1 of our Privacy Policy applies equally to our handling of the personal information of member organisations and other staff at participating member organisations, except for those passages in Part 1 that clearly relate only to member users.

Collection of personal information of an Organisations staff

We may collect basic contact information from staff in the course of providing the BrilliantFIT Member Services to your Organisation. Basic contact information may include the name, role, email address, postal address or phone numbers of your staff. Where requested, supply of such information is optional but can assist us in providing better support and training services to your Organisation.

Use and disclosure of personal information of your Organisations staff

We will only use contact information of Organisational staff for the purposes of providing the BrilliantFIT Member Service to your Organisation, and in supporting and training on the use of the Service by your staff.

We will not pass on staff contact information to others, except where an Organisation staff member (or other individual) has completed a ‘Registration of Interest’ form on our website or emailed us a query regarding the BrilliantFIT Member Service. In such situations we reserve the right to pass on the contact information supplied to our distributors and partners, particularly to assist us in responding to such queries.

Collection of your Organisations business details

In subscribing to the BrilliantFIT Member Service, BrilliantFIT will collect basic information about your Organisation business such as name, address, logo, phone numbers, email addresses, opening hours, professional services offered and other information you may choose to share with your customers and prospective or existing BrilliantFIT users.

Use and disclosure of your Organisations business details

This information is considered public and will be visible to any user of the BrilliantFIT system and publically searchable on the BrilliantFIT website. Publishing this information allows prospective or existing BrilliantFIT members to locate and choose your Organisations offerings, should they wish to apply for a role within the BrilliantFIT Member Service.

Collection of customer data from your Organisation’s customers

As outlined in Part 1 of this document, the BrilliantFIT System collects, stores and utilises customer data for the purposes detailed in Part 1.

BrilliantFIT does not sell or otherwise provide your customers’ personal information to others. Any sharing of customer data is strictly limited to the purposes listed in Part 1 in “Our purposes for handling your personal information”.

BrilliantFIT Analytics Pack (BAP)

If you consent to enrol in the optional BrilliantFIT Analytics Package (BAP) service (a future service), BrilliantFIT will use de‐identified customer data to provide reporting services to your Organisation and/or your Organisational group. Such reporting is strictly de­‐identified as defined earlier in this document and contains no customer identifying information.

Such reporting is typically only available to the specific Organisations that signed­‐up to the BrilliantFIT Analytics Package, unless the Organisation explicitly consents to share their Organisation’s data with the Organisational group or a third party. A separate consent form and process must be completed to allow any sharing with a third party.

Use of de-­identified aggregate information within BAP

BrilliantFIT may use de­‐identified aggregate data obtained from Member Organisations using the BrilliantFIT BAP service to provide locational data and averages within various BAP reports. Any report utilising state or national averages must include more than 5 Member Organisations to ensure individual Organisational statistics are never inadvertently revealed.

Such use of de­‐identified aggregate data is for the purposes of tracking performance and utilisation of BrilliantFIT, including comparative benchmarks and overall measures of BrilliantFIT effectiveness.

Such reports will not identify any specific Organisational to any third party without explicit separate written consent from the Organisation.

Disclosure to third parties

Unless you provide your express written consent, BrilliantFIT will not provide information to third parties that enables any specific Organisational data to be identified (regardless of whether that information is “personal information”).

This includes information in de-identified form.

 

The BrilliantFIT Privacy Policy was last updated on 23rd September 2021.

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