Diabetes Meal Plans (DMP) is committed to protecting and respecting your privacy.
DMP may collect personal identification information from you in a variety of ways. This privacy notice provides you with details of how we collect, process and protect your personal data through your use of our websites https://diabetesmealplans.com and https://dmpmembers.com, and any associated products and services owned by DMP.
Diabetes Meal Plans is the data controller and we are responsible for your personal data (referred to as “we”, “us” , “our” or “The Websites” in this privacy notice).
- WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND DO WE PROCESS IT
We may process the following categories of personal data about you:
- Communication Data that includes any communication that you send to us whether that be through the contact form on our website or support center, through email, blog comments, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Customer Data that includes data relating to any purchases of goods and/or services such as your name, email address, address or country of residence, login data, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
- User Data that includes data about how you use our website and any online services, together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain backups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
- Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking systems. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our products, services and advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to make decisions about our content and marketing strategy.
- Feedback Data that includes data you voluntarily submit to us via email, feedback surveys, your recipe ratings, questions, reviews, words of praise, social media comments, blog comments and similar. We process this data to communicate with you and to improve and/or promote our business. By submitting such feedback, you give your explicit consent that any such voluntary submissions, which may include sensitive data you submit to us (such as aspects of your health or biometric data), may be used for public or direct marketing purposes without any further written permission from you (for example, as a testimonial on our website or within public email communications). We will never share your email address publicly. And we will not share your full name, only first name and first letter of surname (for example, Maria G), unless given explicit consent from you to do so. Our lawful ground for processing this data are legitimate interests in gaining your feedback in order to understand our audience so we can improve our service and help you improve your health, and in the pursuit of growing our business. You can ask us to remove your submissions from our marketing and communications at any time by contacting us at firstname.lastname@example.org.
- Newsletter/ Marketing Data that includes data you provide to us through our signup or opt-in forms such as your name and email address which in this case is to receive our freebie pack, weekly newsletters, and information about DMPs or third parties products and services. We process this data to enable us to send you ‘get started’ educational health information, to enable you to partake in our promotions such as as product and service specials, competitions, prize draws and free giveaways, to deliver our weekly newsletter, and to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for processing this data are consent and legitimate interests, as follows:
- Legitimate interest on behalf of our business to provide high quality evidence-based health education and information to people with type 2 diabetes and prediabetes, their carers and health professionals, which we hope will make a real difference in your life and the lives of others.
- Legitimate interests from you seeking evidence-based and beneficial information that you can use to help improve and better your health.
- Legitimate commercial interests to sell products and services to you to help support our mission and grow our business, if you choose to purchase. While products and services are included in our weekly newsletters, our websites and specific periodic promotions, you are under no obligation to purchase and can opt-out of our communications as any time.
- We may use Customer Data, User Data, Technical Data, Feedback Data and Newsletter/ Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is consent and/or legitimate interests as outlined above.
You may voluntarily submit sensitive data (such as aspects of your health or biometric data) to us via forms on our website, support center, through email, blog comments, social media messaging, social media posting or any other communication that you send us. Our lawful grounds for this processing is your legitimate interest to share with us or obtain information from us, in which case you have chosen to make your sensitive data public, and in which case our legitimate interest is to administer the necessary functions and activities of our business.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. In case we need to use your details for an unrelated new purpose we will let you know.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
- HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example, by filling in forms on our sites, contacting us via our support center, by submitting feedback via surveys, by posting your blog comments, by sending us emails or by engaging with us on social media, and so forth).
We may receive data from third parties such as analytics providers such as Google, along with Google, Facebook, and Amazon advertising networks, and providers of technical, payment and delivery services.
We may collect data about customer transactions via third parties such as Stripe and Paypal.
- MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is your consent and our legitimate interests, as outlined above under ‘Newsletter/ Marketing Data.’
Under the Privacy Act 1988, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time. You can unsubscribe from our communications on your own using the “Unsubscribe” link in the contents and footer of all email communications you receive from us, or by emailing us at email@example.com at any time and we can do it for you manually.
If you opt out of receiving newsletter or marketing communications this opt-out does not automatically apply to personal data provided as a result of other transactions, such as purchases, customer support communications, blog comments, feedback submitted, ratings, favorites, questions, and similar.
- DISCLOSURES OF YOUR PERSONAL DATA
In general, we do not sell, trade, or rent your personal identification information to third parties unless required to do so by law. However, although you are entering into an agreement with us to disclose your information, we do use third-party organizations to help us operate our business and provide our services to you.
The following is a non-exhaustive list of other entities that we may use to collect, store, share, transfer or protect your information, along with their Privacy Policies:
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We may also have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers.
- Government bodies that require us to report processing or data breach activities.
- Fraud prevention agencies that require us to report processing or data activities.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
- GOOGLE ANALYTICS & ADVERTISING
Google Analytics is a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of our websites, to prepare reports on its activities and share them with other Google services.
Google may use advertising cookies to enable the use of advertising features our websites may use including:
- Remarketing with Google Analytics
- Google Display Network Impression Reporting
- Google Analytics Demographics and Interest Reporting
Users can choose to opt-out of all Google browser cookies at anytime by visiting this link.
- DATA TRANSFERS
We are subject to the provisions of the General Data Protection Regulations and the Privacy Act 1988 that protect your personal data. Where we transfer your data to third parties, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:
- We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
- Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- The level of data protection is acceptable under the Privacy Act 1988.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
- DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We allow access to your personal data only to those contractors and partners who need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
- DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for five years after they stop being customers.
In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the appropriate authorities:
AUS: Office of the Australian Information Commissioner (OAIC) (https://www.oaic.gov.au/)
US: Federal Trade Commission (https://www.ftc.gov/)
UK: Information Commissioner’s Office (ICO) (www.ico.org.uk).
CANADA: Office of Information Commissioner Canada (http://www.oic-ci.gc.ca/eng/)
We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
- THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
- COMPLIANCE WITH CHILDREN’S ONLINE PRIVACY ACT
Protecting the privacy of the young is especially important. We intend to fully comply with international laws respecting children’s privacy. For that reason, we do not collect or maintain information from those we actually know are under 18, unless given parental consent, and no part of our website is structured to attract anyone under 18.
We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on DMP and our websites.
TERMS AND CONDITIONS
DMP has specific Terms and Conditions and if you choose to use our websites, you agree to those terms and conditions by doing so.
Your acceptance of these terms
Diabetes Meal Plans (ABN:81438771508)
Last updated: May 2018.