ELIA Wellness Privacy Policy

Who we are
The Trustee of ELIA Wellness Trust is a registered charity and division of Adventist HealthCare Limited (AHCL) (ABN 76 096 452 925). This document sets out the principles that the Trustee of ELIA Wellness Trust (ABN 23 384 623 487) trading as ELIA® Wellness (referred to as “ELIA®, “ELIA® Wellness”, “we,” “us,” and/or “our”) adopts in relation to the protection and handling of personal data (also referred to as “Personally Identifiable Information” or “PII”) that is collected from Individuals and Participating Organisations through various websites, mobile applications, events, programs and social profiles owned and operated by us, which include, but are not limited to eliawellness.com, elialmc.com, eliawellness.org. elia.events, elia.to, Wellness (Mobile App) and Wellness Snapshot.

ELIA Wellness is a registered Australian charity, ELIA® is committed to protecting your personal information, and does so in accordance with the Australian Privacy Principles, which are set out in Schedule 1 of the Privacy Act 1988 (Cth), and any other applicable state or territory legislation.

For more information on our ACNC Charity Registration Details: https://www.acnc.gov.au/charity/charities/ec87b5e5-09b6-ec11-9841-002248941cc3/profile

ELIA Wellness  is owned by AHCL who operate a number of healthcare businesses including the Sydney Adventist Hospital (known as The San or SAH) and San Day Surgery Hornsby. The San includes the teaching hospital, Sydney Adventist Hospital Clinical School (in collaboration with the Australian National University and Avondale University), San Pharmacy and San Diagnostics. San Diagnostics services include San Radiology and Nuclear Medicine and our partnership with San Ultrasound for Women. AHCL is Trustee for Sydney Adventist Hospital Trust and ELIA Wellness Trust. 

Controller of Personal Data
We act as the controller of any personal information provided to or gathered by our websites, applications and events (our “Services”). This Privacy Statement describes the choices available to you regarding the use of your Personal Data, and how you can access this information to update and correct it. 

It is important to note that the privacy practices of Participating Organisations and Partners may differ from those of ELIA®. We are a separate entity from those that participate in our Services and thus do not have control over their privacy practices. We encourage you to review the privacy policies of Participating Organisations’ before submitting any Personal Data to them.

What personal data we collect and why we collect it
This Privacy Policy explains how ELIA® manages the personal information it holds. 

ELIA® complies with the requirements of the Australian Privacy Act 1988 and the Australian Privacy Principles in the collection, management, use and disclosure of personal information.

We recognise the sensitive nature of your Personally Identifiable Information. It is our highest priority to ensure the confidentiality of any Personally Identifiable Information you provide and take a proactive approach in protecting your privacy. Personally Identifiable Information is information or an opinion that can be used to identify you. This includes any personal information we collect from you when dealing with you in relation to ELIA® services. 

ELIA® provides comprehensive wellness products and services, so the quantity and detail of Personally Identifiable Information will directly correlate to the engagement you have, and what you choose to provide to ELIA® services. 

Personally Identifiable Information may include, but is not limited to, your name, address, contact details including your email address, and any additional information you provide to us directly or indirectly through a website, apps, services or via a representative.

What other data we collect and why we collect it
ELIA® services require the collection and analysis of non-personally identifiable information including health and wellness data which may include but not limited to health data, lifestyle habits and opinions, relationship information and the recording of completion of challenges. This data is collected by your voluntary responses and inputs to our services, and also by connecting third party devices like wearable health hardware, that through your authorisation, share health data to our services. Although this data is not able to personally identify you, we recognise the sensitive nature of this information and take a proactive approach in protecting this information. All account holders have the capacity to self manage their online non-PII wellness data 

When you interact with our Services, we may also automatically collect and store information through various technologies used on our websites. This information is used to provide us with statistical information such as the number of visitors to a website (or multiple websites) or the number of visitors to each page of our Services. Other information collected may include your public IP Address, browser type, ISP, pages you visit, your operating system, and date/time stamps. This information is merely statistical and not used to identify you. 

In operating our Services as described above, we and our third party partners use cookies and similar technologies. These technologies are used to provide additional functionality, analyse usage and behaviour more accurately, temporarily store our pages and images, and store content and preferences. 

For more information on the cookies we use, please check our Cookie policy below.

Sharing your Information
ELIA is owned by AHCL which owns various healthcare businesses of whom are Participating Organisations. We integrate and share your information with various Participating Administrations to allow us to perform the various duties discussed above and provide you with valuable Services. Whenever we are required to do so, we shall take steps to ensure that necessary level of protection, so the disclosure will occur in compliance with applicable laws and regulations. 

We may provide your Personal Data to third party service providers that help us with our business activities such as shipping, marketing, and processing of credit cards. These companies are authorised to use your Personal Data only as necessary to provide these services to us and in line with relevant data processing agreement(s). 

We may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation such as a subpoena or a similar legal process; (ii) protect and defend the rights or property of AHCL; or to (iii) act in urgent circumstances to protect against legal liability or protect the personal safety of users of the Services, visitors to our centres, or the public. 

If the organisation is involved in a merger, acquisition or sale of all or a portion of its assets, you will be notified with a notice on our website of any change in ownership or uses of your information, as well as any choices you may have. 

ELIA® organises, manages and participates in ongoing Lifestyle Medicine Research. The data collected by our services is de-identified for the purpose of use in medical research. The data is considered Non-PII, as no information that can identify an individual, including but not limited to name, contact details, street, or relationships, is included in the data-donation. ELIA Medical Research is not a third party, and compromises as an ELIA Wellness activity..

ELIA Wellness  holds the data in isolation from all public engagement platforms, and there is no capacity to track, trace, or connect the lifestyle data back to an individual. The act of holding an ELIA® account and using ELIA® products and services, constitutes a users authority for ELIA® to de-identify and use data in medical research as part of the ELIA® Terms and Conditions of Use. 

Contact forms
If you leave information on the contact forms on this site, it will only be used for contacting you and will not be disclosed to any third party other than as described in this Privacy Policy.

We use ‘cookies’ (small files) to store information provided by your browser when you visit our website. This includes the date and time of your visit, the pages accessed and any documents downloaded. We also use cookies to measure demographic usage patterns to determine which areas of our website have been visited. 

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

How long we retain your data
For users who register to have an account and utilise our products and services, we store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time. ELIA® administrators can also see and edit that information. This data is kept indefinitely until a user either self-removes or requests the data to be removed. 

Data that is de identified for medical research is no longer considered ‘personal’ as the data is not able to be used to identify an individual. This data remains within the ELIA Wellness data pool indefinitely, and if requested, there is no way to identify which data is associated with an individual, and therefore cannot be selected for removal.

Your rights over your data
ELIA® will take reasonable steps to ensure the quality of your personal information at two points in the information handling process: (i) collection and (ii) use or disclosure.

If you have an account on this site, or have left comments, you can request to receive from us an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we correct, up-date, complete or erase any personal data we hold about you by contacting us (see the ‘Contacting Us’ section below). We will need to establish the identity of the individual requesting the information prior to providing it. Your right to require us to erase your personal data does not include any data we are obliged to keep for administrative, legal or security purposes. There are a number of situations where we may deny an individual access to personal information. These can include where it would have an unreasonable impact on the privacy of other individuals, the information relates to existing or anticipated legal proceedings, we have reason to suspect that unlawful activity or misconduct of a serious nature is being or may be engaged in, or where the law requires or authorises such access to be denied. We will advise you if any of these circumstances apply.

How we protect your data
We take reasonable steps to ensure that your personal information is secure. We maintain appropriate safeguards to prevent misuse, loss, unauthorised access, modification or disclosure. We implement administrative, physical and technical safeguards to protect the confidentiality and integrity of your personal information and data that we use and hold. Where practical, your personal information is de-identified or destroyed when it is no longer required. The security of information transmitted on the internet will require you to take specific measures to protect against unauthorised access or use. These include:

  • ensuring that you do not divulge your password or PIN to anyone;

  • ensuring that your access codes and passwords are kept secure; and

  • notifying us immediately if you believe that your access codes, password or PIN have been compromised.

Data breach procedures we have in place
If ELIA® becomes aware of an actual or potential unauthorised access to or disclosure of your personal information, we will manage the unauthorised access in accordance with the Notifiable Data Breach requirements under Part 3C of the Privacy Act. This may include notifying both you and the Privacy Commissioner where that breach is likely to result in serious harm as defined by the Privacy Act.

What automated decision making and/or profiling we do with user data
ELIA® may apply analytics to data from our website (including your personal information) to describe, predict, and improve products and services delivered to you via our digital programs and applications.

Direct Marketing
ELIA® may send you direct marketing information about our products and services that may be of interest to you. These communications may be sent in various forms including mail and electronic media which do not infringe marketing laws such as the Australian Spam Act 2003. If you indicate a preference for a method of communication, we will endeavour to use that method. In addition, at any time you may opt-out of receiving marketing information from ELIA® by using the opt-out facilities provided within the account profile settings and within digital marketing communications. 

Contacting Us
If you have any questions about this privacy policy, would like to know more about ELIA® privacy policy, or if you have any concerns or would like to make a complaint regarding the treatment of your personal information, you can contact us using the details set out below. We treat any concerns or complaints that you may have with respect and confidentiality. An ELIA® representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner. Please contact us by:

  • Email [email protected]

  • Phone +61 2 9847 3242

  • Or write to The Privacy Officer, ELIA Wellness, 148 Fox Valley Road (Locked Bag 2014), Wahroonga, NSW, 2076, AUSTRALIA.

If your concerns are not resolved to your satisfaction or you would like further information in regards to the Privacy Act, the matter can be referred to the Office of the Australian Information Commissioner on 1300 363 992.

Changes to Our Privacy Policy
ELIA Wellness reserves the right to change this policy from time to time as necessary. This privacy policy was last updated on 20 December 2022.