Privacy Policy

1. About this policy

This Privacy Policy explains how KetoTrainer Pty Ltd (“KetoTrainer”, “we”, “us” or “our”) collects, uses, stores and discloses personal information, including health information, when you use our website, assessment, account features, program resources or contact us.

Health information is sensitive. We aim to handle personal and health information responsibly and in accordance with applicable Australian and Victorian privacy requirements, including the Privacy Act 1988 (Cth) and Australian Privacy Principles where they apply, and the Health Records Act 2001 (Vic) and its Health Privacy Principles where applicable.

2. Information we may collect

Depending on how you use KetoTrainer, we may collect:

• identity and contact information, such as your name and email address;
• age and assessment pathway information;
• health and medication information you choose to provide through the assessment or later Progress Checks;
• height, weight, waist measurement and other assessment measurements;
• dietary preferences, allergies, exclusions, eating habits, movement, sleep and lifestyle information;
• KetoTrainer eligibility, program classification, diet route, progress and program-access information generated from your assessment;
• account, program start-date and entitlement information;
• transaction and payment-status information. Card details are processed by the payment provider and are not intended to be stored by KetoTrainer; and
• technical information required to operate and secure the website, such as IP address, browser/device information and security logs.

3. Health-information consent

Before KetoTrainer collects sensitive assessment health information, the assessment presents a health-information notice and requires affirmative consent. Optional marketing consent is separate.

4. Why we use information

We may use your information to:

• operate the assessment and apply eligibility, safety and program-routing rules;
• recommend and provide your KetoTrainer program and unlocked resources;
• support later 12-week Progress Checks, repeat/progress decisions and program administration;
• create and manage your account and program access;
• process or reconcile purchases and provide transactional communications;
• respond to support, privacy and complaint enquiries;
• maintain security, investigate misuse and troubleshoot the service;
• meet legal, regulatory, accounting and record-keeping obligations; and
• send marketing only where you have made the relevant choice or where otherwise permitted by law.

5. Automated program decisions

The KetoTrainer assessment uses programmed rules to determine whether a self-guided program can be recommended, the applicable KetoTrainer classification, a Keto or Non-Keto route where suitable, and the recommended program pathway. These classifications are KetoTrainer program categories and are not medical diagnoses.

We do not intend to use health answers for advertising targeting, and sensitive assessment fields should not be placed in public URLs, payment metadata or advertising pixels.

6. When information may be disclosed

We may disclose information where reasonably necessary to providers that help us operate the service, such as hosting/security providers, payment processors, transactional email providers and professional advisers. We may also disclose information where required or authorised by law, or with your consent.

We do not sell personal or health information.

7. Overseas processing

Some technology providers may operate infrastructure or support functions outside Australia. Where health information is transferred outside Victoria or personal information is disclosed overseas, KetoTrainer will take steps required by applicable privacy law to ensure appropriate protections are in place. You may contact us for current information about relevant service providers and processing locations.

8. Security and retention

We take reasonable technical and organisational steps to protect personal and health information against misuse, interference, loss and unauthorised access, modification or disclosure. No internet service can guarantee absolute security.

Information is retained only for as long as reasonably required for the purposes for which it was collected and to meet applicable legal, accounting, dispute and record-keeping requirements. When no longer required, information should be securely destroyed or de-identified where lawful and appropriate.

9. Access and correction

You may request access to personal or health information we hold about you, or ask us to correct information that is inaccurate, incomplete or out of date. Some legal exceptions may apply.

10. Privacy complaints

If you have a privacy concern, contact us first so we can investigate and respond. If you remain dissatisfied, you may also have the right to contact the Office of the Australian Information Commissioner or, for Victorian health-information matters, the Victorian Health Complaints Commissioner.

11. Contact

12. Changes to this policy

We may update this Privacy Policy when our service, legal requirements or technology providers change. The current version and effective date will be published on this page.