Privacy Policy

Last updated February 2025.

Reformer Space Pty Ltd ACN 684 042 582 (“we”, “us” or “our”) respect your privacy and are committed to protecting your Personal Information. This Policy explains the terms on which we collect, hold, use and disclose your Personal Information, and how we protect your Personal Information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles and any other relevant privacy laws or regulations. When you visit our Website, you contact us, you become a member of Reformer Space, you attend our reformer Pilates sessions, or you otherwise engage with us in relation to our Services, you consent to our collection, use, holding and disclosure of Personal Information in accordance with this Policy.

We comply with our obligations under the UK’s Data Protection Act 2018 and the EU law retained version of the General Data Protection Regulation ((EU) (2016/679) (“data protection laws”) to the extent that any UK or EU residents engage with us, our Website, or our Services. If any of these laws are replaced or superseded, will also comply with that those.

We are registered with the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (ico.org.uk), and our registration number is ZB678593. If you have any concerns about data protection, we would appreciate if you contacted us first so we can discuss these with you before you approach the ICO. You can reach us at hello@reformerspace.com.

For the purposes of this Policy, the following definitions apply:
- Personal Information has the meaning defined in section 6 of the Privacy Act.
- Policy means this privacy policy as amended from time to time.
- Privacy Act means the Privacy Act 1988 (Cth).
- Sensitive Information has the meaning defined in the Privacy Act.
- Services means any or all of the services we offer in relation to the supply of reformer pilates sessions.
- Website means the website accessed at www.reformerspace.com and any links available from or within the Website but does not include any external websites or links to external websites not belonging to or controlled by us.

1. The Personal Information we may collect
a. What we collect from you: Personal Information means any information about an individual from which that person can be identified. It doesn’t include anonymous data. We may collect, use, store and transfer different. The kinds of Personal Information we collect from you includes:
- Identity Data includes full name, maiden name, organisation/company name, username or similar identifier, occupation, marital status, title, date of birth, gender, driver licence (or other form of photo identification) and your likeness.
- Contact Data includes your residential address, billing address, email address, facsimile numbers and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details reasonably necessary in our provision of the Services, including your Reformer Space membership.
- Technical Data includes server/internet protocol (IP) address, the date and time of your visit, the pages accessed, the information you download, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website.
- Profile Data includes your username and password (if applicable), your membership, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Data includes information about how you use our Website and Services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Health Data includes information about your physical health, medical diagnoses and history, and health risk factors such as whether you are pregnant and whether you are on any mediations. These are considered Sensitive Information and requires a higher level of protection than other types of Personal Information.

We don’t generally collect Sensitive Information about you without your consent. Sensitive information may include information regarding your racial or ethnic origins, political or religious beliefs, sexual preferences, membership of professional or trade associations or unions, health information, or criminal convictions. We do however collect information about your physical health, medical diagnoses and history, and health risk factors when you sign up to our Services.

2. What we collect from third parties
‍We may collect Personal Information from a third party where you have expressly consented to its disclosure by that third party.

3. What we collect from the Website
When you use the Website, we collect Technical Data and Usage Data. We collect this information to help us determine how and why people visit the Website and to improve the Services we offer.

4. How is your Personal Information collected?
We may use different methods to collect Personal Information from and about you, including through:
- Direct interactions. You may give us your Identity Data, Health Data and Contact Data by filling in forms/applications required for the provision of the Services or by corresponding or engaging with us by post, phone, email, social media or otherwise.
- Automated technologies or interactions. As you interact with our Website, we will automatically collect Usage Data and Technical Data about your equipment, browsing actions and patterns.
- CCTV: You will give us your Identity Data by attending classes within our studio premises where CCTV is in operation for security and safety purposes.
- Third parties or publicly available sources. We may receive Personal Information about you from various third parties (but only if you have consented to us collecting the information this manner or you would reasonably expect us to collect information about you from a third party) and publicly available sources, such as Google.

As mentioned above, Technical Data and Usage Data is collected when you use the Website. When accessing the Website, pieces of information called “cookies” will be transferred to your hard drive which will allow the Website to remember important information, make your use of the Website more efficient and also allows us to improve our Website.

We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Please note that third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies or performance cookies or targeting cookies:
- Google Analytics: Google Analytics is a web analytics service provided by Google that tracks and reports website traffic. This service uses cookies to collect information about how users interact with our websites, providing us insight on how many users are visiting our websites, which pages they visit, how long they stay on our websites, and where they are coming from (for example, from a search engine, direct link, or referral from another website). This information helps us understand our audience and improve our websites to enhance user experience.
- Google AdWords – Google AdWords uses cookies to track conversions and website traffic. These cookies help businesses measure the effectiveness of their ads and provide a better experience for users by showing them more relevant ads.
- Meta Pixel – Meta Pixel is a tracking technology provided by Meta (formerly Facebook) which helps businesses understand how users interact with websites to improve advertising effectiveness. Meta Pixel allows us to measure the effectiveness of our ads, optimise targeting, and deliver relevant promotions across Meta platforms, including Facebook and Instagram.

We will always ask for your consent to use non-essential cookies. You are free to withhold consent to this, but it means that we might not be able to provide the full website experience to you. If at any time you wish to disable our cookies, you can do so through the settings on your browser, or whenever the pop-up appears on the website (each time you access the Website).

5. Browser cookie controls
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.

6. How we use your Personal Information
Generally, any Personal Information we collect will be used or disclosed for the purpose stated below and/or at the time of collection (Primary Purpose). We will seek further consent from you if we want to use your Personal Information for a purpose other than the Primary Purpose unless that other purpose is permitted by this Policy, authorised by the Privacy Act or required by law, or related to one of the original purposes of collection and you would reasonably expect us to use your Personal Information for that other purpose.

We have set out below the ways we may collect, hold, use and disclose your Personal Information:
- as is reasonably necessary for our provision of the Services;
- to provide you with information about us and the Services, including via email, SMS, post, telephone or any other method of communication;
- to enable you to submit an enquiry to us, whether via email, through our Website or via social media, including but not limited to LinkedIn, Facebook and Instagram;
- to process and enable you to benefit from the Services, including:
-- manage payments, fees, and charges;
-- collect and recover money owed to us; and
-- to keep our premises secure by using CCTV;
- to manage our relationship with you which will include:
-- notifying you about changes to our terms and conditions or this privacy policy; and
-- asking you to leave a review, provide feedback or take a survey;
- to undertake marketing and promotion of us and the Services and to enable you to register for our mailing list/email marketing;
- to administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data); to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
- to use data analytics, information gathering or statistical assessment to assist us in improving our Website, Services, marketing, customer relationships and experiences;
- to make suggestions and recommendations to you about goods or services that may be of interest to you;
- to comply with any applicable laws, regulations, codes and requirements of any relevant body or authority which regulates the Services; and
- any other purpose which you have consented to.

If you do not provide us with the Personal Information we request, we will not be able to provide the Services to you. You also can refuse to give, or withdraw, your consent in relation to any particular use of your Personal Information at any time. However, again, if you refuse to give your consent or withdraw your consent for particular uses we will not be able to provide you with the Services.

7. CCTV
We use CCTV in our reformer Pilates studio to ensure the safety and security of all members, staff, and visitors. The primary purposes of CCTV monitoring are to:
- Ensure the safety and security of members, staff, and visitors;
- Prevent and detect crime; and
- Monitor and enhance operational and safety procedures within the studio.

CCTV cameras are positioned to monitor key areas within the studio premises, including entrances, exits, and common areas. The cameras are not placed in locations where individuals would have a reasonable expectation of privacy, such as changing rooms or restrooms.The CCTV system captures video footage which may include images of members, staff, and visitors. These recordings constitute Personal Information and are subject to data protection laws. CCTV footage is securely stored and retained for a limited period, typically 30 days, unless a longer retention period is required for incident investigation or legal purposes.

8. Marketing
Using the Personal Information you provide, we may send you information relating to us and our Services, which includes marketing and promotional communications, if you have requested information from us or purchased Services from us and you haven’t opted out of receiving those communications. For example, we may provide information to you via an electronic mailing list. This is an opt-in service meaning we will not add your email address to the mailing list without your prior consent. You can only be added to the mailing list if you elect to receive emails from us.

We may also use Sensitive Information we collect from you for the purpose of marketing and promotion in circumstances where you have consented to our use or disclosure of information for that purpose. We will get your express opt-in consent before we share your Personal Information with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

9. Disclosures of your Personal Information
We may disclose your Personal Information we collect for the Primary Purpose, or for a purpose other than the Primary Purpose where we have obtained your consent, for a purpose permitted by this Policy or are otherwise authorised by the Privacy Act or required by law. These include:

Other organisations: We may disclose Personal Information to our related entities and related bodies corporate (as those are defined in the Corporations Act 2001 (Cth)) who act on our behalf in connection with the Services or undertake marketing and promotion.If we want to sell our business, or our company, we can disclose your Personal Information to the potential buyer which will be on a confidential basis.

Government bodies or non-government agencies: We may be required to disclose Personal Information to statutory bodies or agencies.

Third parties: We may share Personal Information with third parties. We use a variety of third party services (sub-processors) as part of our business activities and you/we will therefore share your Personal Information with these sub-processors. The types of sub-processors we might use fall into different categories, as follows:
- Management, communication, and automation services;
- Payment processing services;
- Order fulfilment service providers;
- Analytics service providers;
- Event/campaign management service providers;
- Website management service providers;
- Information technology and related infrastructure provision;
- Email delivery services; and
- Our auditors and legal advisors.

It is important to note that all third parties and sub-processors are bound by data protection obligations and, in the case of any third parties we sub-contract our services to, we will enter into a contract with them with comprehensive data protection obligations to ensure the security of your Personal Information.We may also share Personal Information with third party financiers which provide finance with respect to your purchases of products or Services from us.

10. Overseas recipients
Your Personal Information may be stored or accessed outside of Australia where we engage third parties to provide services on our behalf, such as to receive services or deal with payment, or if we use cloud-based storage and IT servers which may be located outside Australia to store the Personal Information we hold about you.

Whenever your Personal Information is stored or accessed outside of Australia, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- we will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information; or
- our contracts with overseas entities with whom we share your Personal Information require them to maintain the confidentiality of such information.

11. Other Disclosures
Personal Information will only be disclosed to third parties, other than those listed above, if:
- you have expressly consented to Your Personal Information being supplied to others;
- you would reasonably expect us to disclose information of that kind to a third party; or
- we are authorised or required to do so by law or if it is necessary to assist with law enforcement.

12. Access and correction
Where you request access to your Personal Information held by us, we will provide access to you within a reasonable time after the request is made.

However, we may deny access to your Personal Information to the extent permitted under the Privacy Act, which includes in circumstances where we consider providing access would pose a serious threat to the life, health or safety of an individual or there would be an unreasonable impact on the privacy of others. In circumstances where access is refused, we will advise you with a written explanation as to the reason/s as to why we refused access and how you may make a complaint concerning our refusal.

If at any time you believe that our record of your Personal Information is not correct or out-of-date, please contact us using the details below to arrange for correction of that Personal Information. In those circumstances or where we are satisfied that the Personal Information held is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that Personal Information so that it is accurate, up-to-date, complete, relevant and not misleading within a reasonable timeframe.
Before we provide access or make any corrections regarding your Personal Information as referred to above, we will require proof and verification of your identity.

13. Data security
Data security is of great importance to us, and to protect your Personal Information we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data we collect. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business to know. They will only process your Personal Information on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Information breach. Where your Personal Information held by us has been lost, accessed or disclosed without our authorisation and that loss, access or disclosure is likely to cause serious harm to you, we will comply with the relevant notification requirements pursuant to Part IIIC of the Privacy Act.

14. Data retention
We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

15. Your legal rights
We respect your rights in relation to your Personal Information. To the extent required by law, we will comply with any request made by you to:
- know how we are using your Personal Information;
- know what Personal Information is being held about you;
- correct inaccurate Personal Information held by us about you;
- erase Personal Information about you (subject to any requirement for us to keep records under other laws, such as taxation legislation);
- restrict the use of your Personal Information (understanding that this may affect our ability to provide products or services to you); and
- obtain a digital copy of your Personal Information.

You may direct any request to our Privacy Officer, whose contact details are listed below.

16. Third party links
This Policy only relates to our Website and our Services. Our Website contains links to websites controlled by third parties (“Third Party Websites”). In visiting Third Party Websites, the collection, use or disclosure of any Personal Information will not be subject to this Policy. We are not able to determine or control how a third party will collect or use your Personal Information and are not responsible for the privacy practices of Third Party Websites.

Before using any Third Party Websites, we recommend that you examine the privacy policy and any other terms and conditions of using those Third Party Websites as they may differ from our Website.

17. Changes to this policy
We can update this Policy from time to time and, when we do, we will post the updated Policy on our Website. If we make material changes to this Policy, and we need your consent to those changes, we will contact you by email to do so.

18. Questions or complaints
If you are concerned about how we have dealt with Your Personal Information, or otherwise have a complaint about a breach by us of the Privacy Act and the Australian Privacy Principles, please contact us using the following details:
Att: Annie Garnham (Privacy Officer)
Reformer Space Pty Ltd
37 Duffy Street, Portsea VIC 3944
Email: hello@reformerspace.com

We will endeavour to address your complaint efficiently and within a reasonable timeframe. However, if you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner via its website at https://www.oaic.gov.au/ or 1300 363 992.More on PrivacyYou can obtain further information above privacy in Australia and the protection of Personal Information by visiting the Office of the Australian Information Commissioner’s website at https://www.oaic.gov.au/.

19. More on Privacy
You can obtain further information above privacy in Australia and the protection of Personal Information by visiting the Office of the Australian Information Commissioner’s website at https://www.oaic.gov.au/.
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