Growing Strong Ideas P/L trading as Steps to Change is committed to complying with the Privacy Act 1988, the Australian Privacy Principles 2014 and the privacy provisions of all applicable legislation.
When we collect personal information from an individual, we will ensure that we do so in a fair manner and that we let the individual know where and how to contact our organisation. We will only collect information that is necessary for one or more of our functions or activities.
The personal information that we collect will depend on your relationship with us and the service you have requested. It may include:
If we collect sensitive information (as defined under the Act), we will treat it with the utmost security and confidentiality. We will ensure that it is not collected for any purposes, other than those for which we have obtained the individual’s consent, unless the law requires otherwise, or other exceptional circumstances prevail as described under the Act.
We may collect information about you which is considered sensitive under applicable privacy and data protection laws. This information may include:
Where an individual chooses not to provide requested information, we will advise that individual of what consequences this non-disclosure may have. For example, withholding certain information may limit our ability to provide relevant offers or services to individuals in a safe manner, or tailored to their individual needs.
We will not use your health or other sensitive information for marketing purposes.
How we collect your personal information
We collect your personal information in a number of ways. We may collect your personal information directly from you or in the course of our dealings with you, for example when you:
Why we collect personal information
We collect your personal information for a variety of purposes and on different legal grounds. Most of the time, we collect your personal information so that we can provide you with our services and any products that you may have requested and to enter into and perform our contract with you. This may include:
We will only disclose personal information in accordance with the Privacy Act.
This means that personal information may be disclosed:
What would happen if we did not collect your personal information?
If we cannot collect your personal information as described above, we may not be able to process your booking, organise support products or persons or other requests made by you. We also may not be able to fully investigate an incident, complaint or claim, or provide you with all or some of our other products and services.
You may not need to provide some of the information that we use on the basis of our legitimate interests. For example, you can disable cookies in your browser.
How long do we keep your personal information?
We will keep your personal information for as long as we reasonably require your personal information for any valid and lawful purpose. These purposes include to provide you with our services and any products that you have requested, exercise our rights and perform our obligations under a contract, investigate and defend actual or potential claims, comply with our legal obligations and other purposes permitted by law.
When it is no longer reasonably necessary for us to keep your personal information, your information will be destroyed or put beyond use. However, we may de-identify data and retain such data for statistical purposes only.
We are based in Australia, so your personal information will be processed in Australia. However, we may disclose your personal information to organisations or persons located outside of Australia. The countries in which these organisations or persons are located will depend on the circumstances, but in the course of our ordinary operations, we generally disclose personal information to third parties located in the countries where:
We also use web tracking/analytic tools that generate detailed statistics about traffic to our websites, traffic sources and how you interact with advertisements on our websites and third party websites. These tools can also measure and record conversions and sales.
The cookies and web-tracking tools allow our websites and mobile applications to interact more efficiently with the device you are using and to help us improve the content and functioning of our websites and mobile applications.
Our marketing and your personal information
We use personal information that we hold about you to identify services and products that may be of interest to you.
We may contact you by email, text message or other digital service (such as through our applications that you install on your device such as mobile or iPad), phone or post to let you know about services, offers and promotions, for new or existing products or services that may be of interest to you.
You can contact us at any time if you no longer wish to receive marketing materials from us. If you receive a marketing email from us, you can opt-out from that particular category of marketing email by clicking on the "Manage Preferences" link or the “Unsubscribe” link at the bottom of the email.
Storage and security of your personal information
We mostly hold personal information electronically in Healthkit.com and databases. We also hold personal information in telephone recordings and in hard copy paper files. We use third party service providers to store some personal information.
We take reasonable steps to protect the information that we hold about you from misuse, interference and loss, and from unauthorised access, modification or disclosure.
We do this by having physical and electronic security systems and by limiting who can access your personal information. We also have online and network security systems in place for our websites, so that the information you provide us online is protected and secure. However, because of the nature of the internet, we cannot guarantee the security of your personal information.
Please contact us if you become aware of any breach of security.
10.2 Keeping your booking safe
Your Booking Reference (located at the top of your itinerary) or your Velocity PIN (if you are a Velocity Frequent Flyer member) is like your password for your booking.
You can help us protect your privacy by keeping your Booking Reference and your Velocity PIN safe. Don’t share your Booking Reference or Velocity PIN with any other person, unless you are happy for them to receive information from us about your booking and travel arrangements and to make changes to your booking.
We will only update a flight booking or otherwise provide information in relation a booking (including passenger names, destinations, changes or interruptions to travel or no-shows) or provide copies of itineraries or tax invoices, if our verification criteria are met.
If you believe your Booking Reference or Velocity PIN has been obtained by someone who you do not want to have access to your booking, please notify us immediately.
11. Rights in respect of your personal information11.1 General – access to and correction of personal data
You have a right to request access to or correction of your personal information held by us.
If you wish to access, correct or update any personal information that we hold about you, please contact us on the details below. We will need to verify your identity before we can process your request.
We will respond to your request within a reasonable time of you making the request and give you access in the manner you requested, unless it is unreasonable or impracticable for us to do so.
Sometimes we will be able to respond to your query over the phone, but sometimes we may need your request in writing and we might need some time to gather the requested information and get back to you. These more complex requests usually take us between 14 and 30 days. We might need to send a copy of the information to you by post or we might ask you to come and see us to have a look at the information.
Making a request is free. But depending on what information you request access to, we may need to charge you for giving you access to the information. The charges will not be excessive and we'll let you know if a charge will apply before we proceed with giving you access. There is no charge for correcting your personal information. Please note that if you are making a request from the European Union, your request will be completely free apart from in a very limited number of circumstances. This might include if your request is repetitive or if you have requested further copies of the same information. The fee will be based on the administrative cost of providing the information.
If we refuse to correct your personal information that we hold, you can ask us to associate with that information a statement that the information is inaccurate, out-of-date, irrelevant or misleading.
11.2 Specific rights for EU residents only
If you are located in the European Union, then you may have additional rights. Some of these rights will only apply in very limited circumstances.
Once we have received your complaint, we will investigate and respond to you within a reasonable period of time.
We take any privacy complaint seriously and will deal with your complaint fairly and promptly. However if you are not satisfied with our response or how we handled your complaint, you may complain to the Office of the Australian Information Commissioner at:
Office of the Australian Information Commissioner (OAIC)
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
TTY: 1800 620 241
If your complaint relates to our airline services (rather than being privacy-related), you can contact the Airline Customer Advocate, which provides a complaint handling and dispute resolution process for eligible airline customers.
If you are located in the European Union, you have the right to complain to the local data protection authority within the EU. You can find the details of your local DPA here.
We will post all updates to our privacy page.
Unauthorised disclosure or access
As Growing Strong Ideas P/L trading as Steps to Change s is committed to protecting the privacy of individuals, we will view unauthorised disclosure of, or access to, personal information by our employees or contractors, as a serious breach of this policy. Appropriate action (which may include disciplinary or legal action) will be taken in such cases.
We will always provide individuals with a nil-cost way of contacting us to register a request to “opt -out” from receiving any product offers. To opt out please email firstname.lastname@example.org or complete a contact form or unsubscribe from a recent email.
Access to personal information
Individuals will be able to access their personal information upon request. However, Growing Strong Ideas P/L trading as Steps to Change may occasionally need to deny access to information in accordance with the exemptions contained in the Act.
Our goal is to protect the personal information collected by Growing Strong Ideas P/L and its associations. Personal information will be managed confidentially and securely and destroyed appropriately when no longer required.
We will monitor and implement appropriate technical advances or management processes, to safeguard personal information.
We will take all reasonable steps to ensure that the data we collect, use or disclose is accurate, complete and up to date, and has been obtained directly from individuals or other reputable sources.
Privacy related inquiries or concerns can be directed to Growing Strong Ideas P/L by contacting them directly via the contact page.
Availability and review of Policy
This policy will be reviewed from time to time and any amendments will be incorporated into the updated policy.
MEDICAL DISCLAIMER: Any significant health change takes time to heal. Quick changes are possible, but not the norm. Please be prepared to allow the process time to transform, heal and calibrate over time and not overnight.
The contents of this website are for informational purposes only and are not intended to be a substitute for professional medical advice, diagnosis, or treatment. Always seek the advice of your physician or other qualified health provider with any questions you may have regarding a medical condition.