Privacy Policy
Three Tulips Healing takes privacy very seriously in accordance with Australian privacy legislation and principles. Please see our policy below.
Collection of your personal information
Three Tulips Healing collects personal information via the following methods:
Website visitors
There are many aspects of Three Tulips Healing's website, located at www.threetulipshealing.com.au (the Website), which can be viewed without providing any personal information to Three Tulips Healing. However, to contact us, a potential client is required to submit personal information, such as a name, email and phone number, this information is collected to enable Three Tulips Healing to provide a response to the enquiry.
Client bookings and registrations
Upon booking an appointment Three Tulips Healing may collect personal information about you for the purpose of providing its energy healing services to you, including required fields of name, email address and phone number. Optional information that may be provided in a following client registration form, developed to support the provision of energy healing services includes information such as your pronouns, suburb, state, postcode, relevant health information and details of your GP. Three Tulips Healing may also use your contact details to provide you with information about the activities and new services offered by Three Tulips Healing. You have the option to opt out of communications.
Types of personal information collected and held
In the course of the provision of services by Three Tulips Healing, Three Tulips Healing may collect and hold:
Personal Information including names, addresses (including residential, business, email) and other contact details, dates of birth; and financial information. For clients this may also include sensitive health information for the purposes of understanding the context and any areas of focus to be considered from an energy healing perspective - noting this information is provided on an optional basis.
Recordings
Three Tulips Healing may make audio and video recordings for the purposes of providing information on the results of sessions to clients. These recordings are optional and results can be provided via email if preferred. Recordings are stored on the Power Diary secure platform.
Solicited Information
Three Tulips Healing has, where possible, attempted to standardise the collection of personal information by using specifically designed forms. However, given the nature of our operations Three Tulips Healings often also receives personal information via methods other than those outlined above.
Three Tulips Healing may also collect personal information from other people (e.g., a third-party administrator or independent sources). However, Three Tulips Healing will only do so where it is not reasonable and practical to collect the personal information from the individual directly.
Three Tulips Healing may collect information based on how individuals use our Website (See Cookies, below).
Unsolicited information
Three Tulips Healing may be provided with personal information without having sought it through the means of collection outlined in this Policy. This is known as ‘unsolicited information’ and is often collected by the following:
- postal– letters, notes, documents (either misdirected or otherwise).
- electronic– emails, SMS, electronic messages (either misdirected or otherwise).
- Telephone enquiries
- Employment and contractor applications sent to Three Tulips Healing that are not in response to an advertised vacancy
- Additional information provided to Three Tulips Healing that was not requested. This may include information supplied by police, government agencies, and medical professionals, including in emergency situations.
Unsolicited information collected by Three Tulips Healing will only be held, used and or disclosed if it is considered as personal information that could have been collected by the means outlined in this Policy. If that unsolicited information could not have been collected by normal means, then Three Tulips Healing will destroy, permanently delete or de-identify the personal information as appropriate unless it is otherwise lawful and reasonable for Three Tulips Healing to hold, use and disclose that personal information.
Collection and use of sensitive information
Three Tulips Healing only collects sensitive information if:
- It is fair and reasonable for one or more of its functions, activities and operations, and Three Tulips Healing has the individual’s consent.
- It is fair and reasonable to protect the welfare of a client, including by preventing a serious medical or health scenario or threat to life, health, safety and physical and mental wellbeing of that individual.
- a permitted general situation exists.
- a permitted health situation exists.
Disclosure of your personal information
Three Tulips Healing may disclose your personal information to other entities and persons for the purposes specified in the section above (‘Collection of your personal information’). For example, we may occasionally use other entities to provide services on our behalf, such as for related business management systems such as Xero, Stripe or Power Diary.
Three Tulips Healing will provide those entities with only the personal information they need to deliver the service. Three Tulips Healing takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
Three Tulips Healing will only disclose your personal information to another person for the purpose Three Tulips Healing collected the information or for purposes that are related to that purpose. Three Tulips Healing will only disclose your personal information to another person for another purpose if you provide consent or where Three Tulips Healing is required or authorised by law to disclose it for that purpose and if it is fair and reasonable for Three Tulips Healing to do so.
Three Tulips Healing may disclose personal information without consent or in a manner which an individual would reasonably expect if:
- The disclosure will lessen or prevent a serious threat to the life, health, or safety of an individual or to public safety.
- Another permitted general situation applies.
- Disclosure is reasonably necessary for a law enforcement related activity.
- A permitted health situation exists.
Three Tulips Healing may disclose personal information, held about an individual for the purposes of delivering its services, for administrative and support purposes. This may include to disclosure to the following:
- nominated contacts including for emergency or welfare purposes.
- people providing administrative, marketing and financial services to Three Tulips Healing
- testimonials for the purpose of anonymous endorsement
- anyone who an individual authorises Three Tulips Healing to disclose information to; and
- anyone to whom Three Tulips Healing is required or authorised to disclose the information to by law.
In addition, Three Tulips Healing uses services that requires personal information to be disclosed to those service providers, including service providers located overseas. That is, personal information about an individual may be disclosed to an overseas organisation in the course of the provision of services, for example:
- Power Diary and similar third-party system software platforms;
- Xero and similar accounting software;
- Sharepoint and similar third-party information management/ record keeping platforms;
- Loom for recording sessions;
- Stripe for payment processing;
- Zoom for video conferencing.
Three Tulips Healing will however take all reasonable steps not to disclose an individual’s personal information to overseas recipients unless Three Tulips Healing:
- has the individual’s consent (which may be implied);
- has satisfied itself that the overseas recipient is compliant with the Australian Privacy Principles, or a similar privacy regime, or if there is a suitable agreement in place with the overseas recipient;
- has formed the opinion that the disclosure will lessen or prevent a serious threat to the life, health, or safety of an individual or to public safety; or
- is taking appropriate action in relation to suspected unlawful activity or serious misconduct.
Use of your personal information
The purposes for which we will use personal information will depend on our interaction with you. Three Tulips Healing will only use your personal information for the purpose Three Tulips Healing collected the information or for purposes that are related to that purpose and provided it is fair and reasonable for us to do so. Three Tulips Healing will only use your personal information for another purpose if you provide consent or Three Tulips Healing is required or authorised by law to use it for that purpose and provided it is fair and reasonable for us to do so.
Subject to the below, Three Tulips Healing uses personal information for a purpose that is reasonably necessary for operating its services in providing distributing donated goods (the primary purpose) or for a related secondary purpose that would be reasonably expected to support that purpose, or for an activity or purpose to which a relevant individual has consented.
In relation to personal information of clients, Three Tulips Healing’s primary purpose of collection is to enable Three Tulips Healing to deliver its services, maintain relationships with clients and to perform related administrative activities.
Three Tulips Healing engages in marketing for its growth and development and as an important part of ensuring that it continues to provide quality services. Personal information held by Three Tulips Healing may be disclosed to organisations that assist in marketing activities such as Mail Chimp.
Please be aware that Three Tulips Healing may use the personal information you provide to Three Tulips Healing to provide you with information about Three Tulips Healing via our social media channels and to promote Three Tulips Healing's purpose of helping people on their healing journey. If you do not wish to receive promotional material, you may contact Three Tulips Healing using the contact details listed below in the ‘Contact us’ section.
In some instances where Three Tulips Healing requests personal information and that information requested is not provided, Three Tulips Healing may not be able to provide, or continue to provide, services to an individual.
Three Tulips Healing will only use or disclose sensitive or health information for a secondary purpose if it would be reasonable to expect Three Tulips Healing to use or disclose the information, the secondary purpose is directly related to the primary purpose, and it is fair and reasonable for us to do so or where we are permitted under law to do so. For example, we may need to disclose health information in the case of medical emergency.
Storage of your personal information
Three Tulips Healing holds your personal information in electronic files.
Three Tulips Healing stores personal information in a variety of formats including, but not limited to:
- personal devices, including laptop computers and mobile phones.
- third party storage providers such as cloud storage facilities.
We will take steps to destroy or de-identify your personal information where we no longer require it, save where Three Tulips Healing is required by law or a court order to retain the personal information.
Three Tulips Healing takes all reasonable steps to protect the personal information it holds from misuse, loss, unauthorised access, modification, or disclosure. Three Tulips Healing staff are required to respect the confidentiality of an individual’s personal information that they access, and the privacy of individuals, in the provision of services by Three Tulips Healing.
These steps include, but are not limited to:
- restricting access and user privilege of information being dependent on the person’s role and responsibilities.
- ensuring staff do not share personal passwords and update their passwords regularly and using multi-factor authentication
- ensuring access to Three Tulip's premises are always secured.
- undertaking due diligence with respect to third party service providers who may have access to personal information, third party contractors who are engaged to facilitate services and cloud service providers, to ensure as far as practicable that they are compliant with the Australian Privacy Principles or a similar privacy regime.
- the destruction, deletion, or de-identification of personal information it holds that is no longer required for the purpose that it was collected unless required to be retained by any other laws.
The Website may contain links to other third-party websites outside of Three Tulips Healing. Three Tulips Healing is not responsible for the information stored, accessed, used, or disclosed on such websites and Three Tulips Healing cannot comment on their privacy policies.
Responding to data breaches
Three Tulips Healing will take appropriate, prompt action if it has reasonable grounds to believe that a data breach may have or is suspected to have occurred. Depending on the type of data breach, this may include a review of our internal security procedures, taking remedial internal action, notifying affected individuals and the Office of the Australian Information Commissioner (OAIC). If Three Tulips Healing is unable to notify individuals, it will publish a statement on the Website and take reasonable steps to publicise the contents of this statement.
Cookies
We may collect information in the form of ‘cookies’ about your visit to the Website via ‘cookies’. Cookies are non-personally identifiable information, and include information about the device you used to browse the Website (such as browser type, version and language, and operating system), information about the pages viewed while browsing the Website (pages visited, day and time of your visit, whether you used a search engine to find us, and referring website address), and some geographical information about what country and state you are in. This collected information is used solely for Three Tulips Healing’s internal purpose of gauging visitor traffic, trends and delivering personalised content to you while you are at the Website.
If you wish, you can set your browser to reject cookies, or to notify you when you receive one in order to accept or reject such receipt in each instance.
Quality of personal information
Three Tulips Healing takes all reasonable steps to ensure the personal information it holds, uses, and discloses is accurate, complete, and up to date, including at the time of using or disclosing the information.
If Three Tulips Healing becomes aware that the personal information is incorrect or out of date, Three Tulips Healing will take reasonable steps to rectify the incorrect or out of date information
.
Accessing and correction of your personal information
You have a right to access and correct your personal information that is held by Three Tulips Healing, subject to exceptions allowed by law. If you would like to do so, please contact Three Tulips Healing using the contact details listed below in the ‘Contact us’ section. Three Tulips Healing reserves the right to charge a fee for searching for, and providing you with access to, your personal information on a per request basis.
Upon receiving such a request, Three Tulips Healing may take steps to verify the individual’s identity before granting access or correcting any perceived inaccuracy. If the rejection relates to a request/ application to change personal information, an individual may make a statement about the requested change and Three Tulips Healing will include this statement with the relevant record.
To make a request/ application to access or to update any personal information Three Tulips Healing holds about an individual, please contact Three Tulips Healing's Privacy Officer in writing via the contact form below. An applicant for access will be required to specify what information is sought to be accessed, corrected, or updated. Three Tulips Healing may charge a fee to cover the cost of verifying an application and locating, retrieving, reviewing, and copying any material requested. If the information sought is extensive, Three Tulips Healing will advise the likely cost in advance.
There may be occasions when access is denied. Such occasions would include where release of the information would have an unreasonable impact on the privacy of others, or where the release may result in a breach of Three Tulips Healing’s duty of care to the client. If Three Tulips Healing cannot provide an applicant access to that information, it will provide the applicant with written notice explaining the reasons for refusal.
There are some exceptions to these rights regarding access and correction, as set out in applicable legislation.
Privacy complaints and further information
If you have a concern about your privacy, Three Tulips Healing's compliance with the Australian Privacy Principles, or a query on how Three Tulips Healing handles your personal information, please contact us using the contact details listed below in the ‘Contact us’ section. We will respond to your query or complaint as soon as reasonably practicable. Three Tulips Healing may seek further information in order to provide a full and complete response.
Three Tulips Healing does not charge a fee for the handling of complaints.
If you are not satisfied with our response, you may also contact the Office of the Australian Information Commissioner. A complaint can be made using the OAIC online Privacy Complaint form or by mail or email. A referral to OAIC should be a last resort once all other avenues of resolution have been exhausted.