Privacy Policy

PrimalThenics® , its subsidiaries and affiliates are committed to managing personal information in accordance
with the Australian Privacy Principles under the Privacy Act 1988 (Cth), the General Data Protection Regulation
(EU) 2016/679 (GDPR) and in accordance with other applicable privacy laws.

This document sets out our policies for managing your personal information and is referred to as our Privacy
Policy.

In this Privacy Policy,
“we”, “us” and “our” refers to PRIMALTHENICS® and
“you” refers to any individual about whom we collect personal information.

ABOUT

PRIMALTHENICS® is an online fitness and wellness program.

PRIMALTHENICS® offers a range of services, including online workouts and nutrition tutorials.

WHAT INFORMATION DOES PRIMALTHENICS® COLLECT ABOUT YOU?

Members and prospective members

When you enquire about our services or when you subscribe or become a member of PRIMALTHENICS®, a record is made which includes
your personal information. The type of personal information that we collect will vary depending on the circumstances
of collection and the kind of service that you request from us, but will typically include:

• a)Your age;
• b) Your fitness and nutrition statistics which you provide to us;
• c)Your login details and passwords which you use to access your account with us as well as your
  online interactions with us;
• d)Details of the products and services (such as membership options) you have purchased from us or
  which you have enquired about, together with any additional information necessary to deliver those products
  and services and to respond to your enquiries;
• c)Any additional information relating to you that you provide to us directly through our websites
  or by other means such as over the phone, via email or in person;
• d)Information you provide to us via voluntary members feedback or engagement surveys;
• g)Any additional personal information you provide to us, or authorise us to collect, as part of
  your interaction or membership with PRIMALTHENICS®.

Prospective employees/applicants

We collect personal information when recruiting personnel, such as your name, contact details, qualifications
and work history. Generally, we will collect this information directly from you. 

We may also collect personal information from third parties in ways which you would expect (for example, from recruitment
agencies or referees you have nominated). Before offering you a position, we may collect additional details
such as your tax file number and superannuation information and other information necessary to conduct background
checks to determine your suitability for certain positions.

We may also collect relevant information from third party sources such as [LinkedIn] and other professional
websites.

Other individuals

PRIMALTHENICS® may collect personal information about other individuals who are not members of PRIMALTHENICS®. This includes
customers and members of the public who participate in events we are involved with; individual service providers
and contractors to PRIMALTHENICS®; and other individuals who interact with PRIMALTHENICS® on a commercial
basis. The kinds of personal information we collect will depend on the capacity in which you are dealing
with PRIMALTHENICS®. Generally, it would include name, contact details, and information regarding our interactions
and transactions with you.

If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings
which identify you.

You can always decline to give PRIMALTHENICS® any personal information we request, but that may mean we cannot provide you
with some or all of the services you have requested. If you have any concerns about personal information
we have requested, please let us know.

Your sensitive information

PRIMALTHENICS® may collect and process your sensitive information or special category data, such as your health information,
generally with your express consent and only as reasonably necessary in order for us to provide our services
to you. We may also collect such information about you in an emergency or otherwise with your consent or
in accordance with applicable laws.

Visitors to our websites

The way in which we handle the personal information of visitors to our websites is discussed below

What happens if you don’t provide your personal information?

You can always decline to give PRIMALTHENICS® any personal information we request, but that may mean we cannot
provide you with some or all of the services you have requested or we may not be able to do business with
you effectively. If you have any concerns about personal information we have requested, please let us know.

HOW AND WHY DOES PRIMALTHENICS® COLLECT AND USE YOUR PERSONAL INFORMATION?

PRIMALTHENICS® collects personal information reasonably necessary to carry out our business, to assess and manage our members’
needs, and provide our services to you. We may also collect information to fulfil administrative functions
associated with these services, for example billing, entering into contracts with you and/or third parties
and managing member relationships.

The purposes for which PRIMALTHENICS® usually collects and uses personal information depends on the nature of your interaction
with us, but may include:

• a)to fulfil obligations under a membership agreement and/or any other contract you may have with
  us;
• b) to provide information about products, services and/or special offers to members;
• c)to obtain opinions or comments about products and/or services from members;
• d) to record statistical data for marketing analysis from members; responding to requests for information
  and other general inquiries;
• e)managing, planning, advertising and administering programs, events, competitions and performances;
• f) researching, developing and expanding our facilities and services;
• g)informing you of our activities, events, facilities and services; recruitment processes; and
• h) responding to enquires and complaints.

In addition, some of your personal information may be used for other business purposes. Examples of the types
of uses are set out below:

• a)for our reasonable commercial purposes (including quality control and administration and assisting
  us to develop new and improved products and services);
• b) to follow up with you after you request information to see if we can provide any further assistance
  (for example if you enquire about a membership package);
• c) to comply with any requirement of any applicable statute, regulation, rule and/or good practice,
  whether originating from [Australia] or elsewhere;
• d)to fulfil our obligations under any reporting agreement entered into with any tax authority or
  revenue service(s) from time to time;
• e) to check your instructions to us, to analyse, assess and improve our services to members, as
  well as for training and quality purposes, we may monitor, record and analyse any communications between
  you and us, including phone calls;
• f)to prevent or detect abuse of our services or any of our rights (and attempts to do so), and to
  enforce or apply our Privacy Policy and/or any other agreement (such as your membership agreement with
  us) and to protect our (or others’) property or rights;
• g) to share information with relevant third parties in the context of a sale or potential sale of
  a relevant part of our business, subject always to confidentiality obligations;
• h)if instructed to do so by you or where you give us your consent to the use and/or processing involved;
• i)to bring to your attention (in person or by post, email or telephone) information about additional
  services offered by us and/or our [global affiliates], which may be of interest to you, unless you indicate
  at any time that you do not wish us to do so; and
• j)to improve the relevance of marketing messages we may send you (which you can opt out of as explained
  below).

PRIMALTHENICS® generally collects personal information directly from you. We may collect and update your personal
information over the phone, by email, over the internet or social media, or in person. We may also collect
personal information about you from other sources, for example:

• a)our affiliated and related companies;
• b) third party suppliers and contractors who assist us to operate our business.

PRIMALTHENICS® also collects and uses personal information for market research purposes and to innovate our delivery of products
and services.

We have a legitimate interest in using your information in the ways listed above. In some cases it will be lawful for us
to collect and use your personal information, for example where it is necessary as part of our, or a third
party’s, statutory or public functions or because the law permits or requires us to.

HOW DOES PRIMALTHENICS® INTERACT WITH YOU VIA THE INTERNET?

You may visit our website without identifying yourself. If you identify yourself (for example, by providing your contact
details in an enquiry / logging into our online membership portal), any personal information you provide
to PRIMALTHENICS® will be managed in accordance with this Privacy Policy.

PRIMALTHENICS’s® websites may contain links to third-party websites. PRIMALTHENICS® is not responsible for
the content or privacy practices of websites that are linked to our website.

PRIMALTHENICS’s® cookies policy

What is a cookie?

PRIMALTHENICS’s® websites use cookies. A ‘cookie’ is a small file stored on your computer’s browser, which
assists in managing customised settings of the website and delivering content. We collect certain information
such as your device type, browser type, IP address, pages you have accessed on our websites and on third-party
websites.

While the cookie may identify your computer, it should not identify you unless you are registered with our website (for example,
because you are a member and subscribe to our website) or logged in using your social media profile. In that
case, the cookie will be linked to your profile so that we can identify you and provide more relevant content.

Why we use cookies

We use cookies to personalise your browsing experience (for example, by remembering your preferences and recognising you
as a repeat visitor to our website), and to track statistics about the usage of our website. This allows
us to better understand our members and improve the layout and functionality of our websites.

The types of cookies we use

Specifically, we use the following cookies:

These Third Party Providers may

• a) use Third Party Cookies, web beacons, and other storage technologies to collect or receive information
  from our Websites and elsewhere on the internet;
• b) compare de-identified information from us with information collected elsewhere on the internet;
  and use that information to provide measurement services and target ads to you.

How long cookies will be stored on your device

Session cookies are temporary. They allow website operators to link the actions of a user during a browser
session, the time period between a user opening a browser window and closing it. Once closed, the cookies
are deleted. Persistent cookies remain on a user’s device for the period of time specified in the cookie.

How you can manage your cookies

If you do not wish to receive any cookies (other than those which are strictly necessary) you may set your browser (such
as Firefox, Google Chrome, Internet Explorer or Safari) to either prompt or refuse cookies. Please note that
rejecting cookies may mean that not all the functions on our Websites you visit will be available to you.
Some of the websites that let you control what information is collected about you are:

your onlinechoices.com.au allaboutcookies.org youronlinechoices.com If you do not wish to receive any cookies (other than
those that are strictly necessary) you can use the settings in your browser to control how your browser deals
with cookies (e.g. to either prompt or refuse cookies). However, in doing so, you may be unable to access
certain pages or content on our website.

CAN YOU DEAL WITH US ANONYMOUSLY?

PRIMALTHENICS® will provide you with the opportunity of remaining anonymous or using a pseudonym in your dealings
with us where it is lawful and practicable (for example, when making a general enquiry). Generally it is
not practicable for PRIMALTHENICS® to deal with you anonymously or pseudonymously on an ongoing basis. If
we do not collect personal information about you, you may be unable to utilise our services or participate
in our events, programs or activities we manage or deliver.

HOW DO WE HOLD INFORMATION?

PRIMALTHENICS® stores information in paper-based files or other electronic record keeping methods in secure
databases (including trusted third party storage providers based in Australia and the United States). Personal
information may be collected in paper-based documents and converted to electronic form for use or storage
(with the original paper-based documents either archived or securely destroyed). We take reasonable steps
to protect your personal information from misuse, interference and loss and from unauthorised access, modification
or disclosure.

PRIMALTHENICS® maintains physical security over paper and electronic data stores, such as through locks and
security systems at our premises. We also maintain computer and network security; for example, we use firewalls
(security measures for the Internet) and other security systems such as user identifiers and passwords to
control access to our computer systems.

Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via
the internet. Users of our websites are encouraged to exercise care in sending personal information via the
internet.

HOW LONG WILL YOUR PERSONAL INFORMATION BE KEPT BY PRIMALTHENICS®

We will only keep the personal information we collect about you for as long as is necessary for the purposes
set out in this Privacy Policy or as required to comply with any legal obligations to which we are subject.
The retention periods we apply take account of:

• a)
  legal and regulatory requirements and guidance;
• b)
  limitation periods that apply in respect of taking legal action;
• c)
  our ability to defend ourselves against legal claims and complaints;
• d)
  good practice; and
• e)
  the operational requirements of our business.

We take steps to destroy or de-identify information that we no longer require or as required by an applicable law.

DOES PRIMALTHENICS® USE OR DISCLOSE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?

PRIMALTHENICS® may use or disclose your personal information for the purpose of informing you about our services, upcoming
promotions and events, or other opportunities that may interest you or as otherwise permitted under applicable
privacy laws.

This means under certain privacy laws we do not always need your consent to send you marketing communications such as our
member newsletter. However, where consent is required under applicable privacy laws, we will ask for this
consent separately and clearly. If you do not want to receive direct marketing communications, you can opt-out
at any time by contacting us using the contact details below or using the opt-out functionality contained
in the electronic message.

If you opt-out of receiving marketing material from us, PRIMALTHENICS® may still contact you in relation to its ongoing relationship
with you.

We will not use or share your Apple Health Data with advertising platforms, data brokers or information resellers

HOW DOES PRIMALTHENICS® USE AND DISCLOSE PERSONAL INFORMATION?

For members

The purposes for which we may use and disclose your personal information will depend on the services we are
providing you. For example, if you have engaged us to deliver a service, we may disclose information about
you to service providers (including a personal trainer who is a contractor) where this is relevant to our
services. We will use Apple HealthKit Data for customer relationship management purposes as well as to improve
our services including providing tailored services, i.e. using your data to provide you with information
we believe will be of interest to you (excluding marketing communications) prior to, during, and after your
interactions with us.

For customers and participants

If you are a customer or participant in an event, we may disclose your personal information to venues where this is reasonably
necessary for, and relevant to, the delivery of the event. We may use images or audio-visual recordings which
identify you for promotional purposes where you would reasonably expect this to occur.

Disclosure to contractors and other service providers

PRIMALTHENICS® may disclose information to third parties we engage in order to provide our services, including
contractors and service providers used for data processing, data analysis, customer satisfaction surveys,
information technology services and support, website maintenance/development, printing, archiving, mail-outs,
and market research. Personal information may also be shared between related and affiliated companies of
PRIMALTHENICS®, located in [Australia and overseas]. Third parties to whom we have disclosed your personal
information may contact you directly to let you know they have collected your personal information and to
give you information about their privacy policies.

Use and disclosure for administration and management

PRIMALTHENICS® will also use and disclose personal information for a range of administrative, management and
operational purposes. This includes: administering billing and payments and debt recovery; planning, managing,
monitoring and evaluating our services; quality improvement activities; statistical analysis and reporting;
training staff, contractors and other workers; risk management and management of legal liabilities and claims
(for example, liaising with insurers and legal representatives); responding to enquiries and complaints regarding
our services; obtaining advice from consultants and other professional advisers; and responding to subpoenas
and other legal orders and obligations.

Other uses and disclosures

We may use and disclose your personal information for other purposes explained at the time of collection (such as in a specific
privacy collection statement or notice) or otherwise as set out in this Privacy Policy.

DOES PRIMALTHENICS® DISCLOSE YOUR PERSONAL INFORMATION OVERSEAS?

PRIMALTHENICS is a global organisation and works with members, service providers, sponsors and commercial interests across
the globe. It is likely that your personal information will be disclosed to overseas recipients including
service providers who may handle, process or store your personal information on our behalf.

The recipients of such information may be located in USA or Australia.

Entities, which are related entities of PRIMALTHENICS®, or are otherwise affiliated with PRIMALTHENICS®,
have operations in USA and Australia. We generally collect personal information about you in Australia
or the jurisdiction in which the PRIMALTHENICS® affiliate you are dealing with is located.

It is likely that your personal information will be transferred outside of the jurisdiction it was collected. We only ever
disclose your personal information outside the jurisdiction it was collected where we are permitted to do
so under applicable privacy laws. Generally this means we will take reasonable steps to ensure your personal
information is treated securely and in accordance with applicable privacy laws, including, where relevant,
by entering into EU standard contractual clauses (or equivalent measures) with the party outside the European
Economic Area.
EU standard contractual clauses are available here.

There are circumstances where we may disclose your personal information to an overseas recipient. For example, you have provided
your consent or we are otherwise permitted to do so under the Australian Privacy Principles or other relevant
laws.

RESIDENTS IN THE EUROPEAN ECONOMIC AREA

We have described the purposes for which we may use your personal information. If the GDPR applies to you,
we are permitted to process your personal information in this way, in compliance with the GDPR, by relying
on one or more of the following lawful grounds:

• a)
  you have explicitly agreed to us processing your information for a specific reason;
• b)
  the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
• c)
  the processing is necessary for compliance with a legal obligation we have; or

• d)
  the processing is necessary for the purposes of a legitimate interest pursued by us, which might be:

  • i) to prevent fraud;
  • ii) to protect our business interests;
  • iii) to ensure that complaints are investigated;
  • iv) to evaluate, develop or improve our products; or
  • v) to keep our clients informed about relevant products and services, unless you have indicated
    at any time that you do not wish us to do so.

If the GDPR applies to you, you have the following additional and specific rights in relation to your personal
information (where applicable)

If you have consented to our processing of your personal information, you have the right to withdraw, at any
time, any consent that you have previously given to us for use of your personal information. In certain circumstances
even if you withdraw your consent we may still be able to process your personal information if required or
permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and
regulatory obligations. To make a request to exercise any of these rights (where applicable) in relation
to your personal information, please contact us using the contact details below.

HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?

You are entitled to access your personal information held by PRIMALTHENICS® on request. To request access to
your personal information please PrimalThenics® headquarters at HQ@primalthenics.com. We will take reasonable
steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date.
You can help us to do this by letting us know if you notice errors or discrepancies in information we hold
about you and letting us know if your personal details change. However, if you consider any personal information
we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request
correction of the information. After receiving a request from you, we will take reasonable steps to correct
your information. We may decline your request to access or correct your personal information in certain circumstances
in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with
a reason for our decision and, in the case of a request for correction, we will include a statement with
your personal information about the requested correction.

WHAT SHOULD YOU DO IF YOU HAVE A COMPLAINT ABOUT THE HANDLING OF YOUR PERSONAL INFORMATION?

You may contact PRIMALTHENICS® at any time if you have any questions or concerns about this Privacy Policy
or about the way in which your personal information has been handled.

You may make a complaint about privacy to the Privacy Officer at the contact details set out below.

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps, which can
be taken to resolve the complaint. We will generally respond to your complaint within a week.

If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within
a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide
further information about your complaint and the outcome you are seeking. We will then typically gather relevant
facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is
more complex or our investigation may take longer, we will let you know.

If you are not satisfied with our response to your complaint, or you consider that PRIMALTHENICS® may have breached the Australian
Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information
Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300
363 992 or by using the contact details on the website

HOW CHANGES ARE MADE TO THIS PRIVACY POLICY?

PRIMALTHENICS® may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit
our website regularly to keep up to date with any changes. We also try to let you know about major changes
to our Privacy Policy (for example by putting a notice up on our website).

HOW CAN YOU CONTACT PRIMALTHENICS®?

The contact details for PRIMALTHENICS® are:

This Privacy Policy was last updated in May 2019.