Privacy Policy

1. Introduction

Project Train Pty Ltd -ACN 659 961 369 (referred to as "we," "us," or "our") is committed to safeguarding the privacy of individuals and complying with data protection laws. This Privacy Policy outlines how we collect, use, disclose, and protect your Personal Information. By using our services, you consent to the practices described in this policy.

2. Applicability and Compliance

We adhere to the Australian Privacy Principles (APPs) as per the Privacy Act 1988 (Cth) and are committed to complying with relevant European Union (EU) data protection laws, including the General Data Protection Regulation (GDPR).

3. Definitions

Personal Information: Refers to any information that identifies an individual, including but not limited to name, address, email address, phone number, date of birth, fitness and nutrition statistics, log in details, device information, location data, and browsing history.

Sensitive Information: Includes information about racial or ethnic origin, political opinions, religious or philosophical beliefs, membership of a trade union, criminal record, health information, or any special category of personal data as defined by applicable laws.

4. Collection of Personal Information

We collect Personal Information through various means, such as interviews, correspondence, telephone, email, our website (www.projecttrain.com.au or www.projecttrain.com), our app, and third parties. We will clearly communicate the purpose of collecting the information at the time of collection, ensuring data minimization principles are upheld.

5. Purpose of Collection

We collect Personal Information for the primary purpose of providing our services to you and for marketing purposes. Secondary purposes, closely related to the primary purpose, may also be considered. You can unsubscribe from our mailing/marketing lists at any time.

6. Consent and Notification

When collecting Personal Information, we will explain why we are collecting it and how we plan to use it. Your explicit consent will be sought where required by law, including consent for the processing of special categories of personal data.

7. Sensitive Information

Sensitive information will only be used for the primary purpose for which it was obtained, for a directly related secondary purpose, with your explicit consent, or as required or authorised by law. We adhere to lawful bases for processing special categories of personal data as per the GDPR.

8. Third Parties

We will collect Personal Information directly from you whenever reasonable and practicable. In cases where information is provided by third parties, we will take reasonable steps to ensure your awareness of such information.

9. Disclosure of Personal Information

Your Personal Information may be disclosed to third parties with your consent or where required/authorised by law. For European residents, please note that your information may be transferred outside of Europe, including to Canada and the United States. International data transfers are conducted with appropriate safeguards, such as standard contractual clauses.

10. Security of Personal Information

We take reasonable steps to protect Personal Information from misuse, loss, unauthorised access, modification, or disclosure. When no longer needed, information will be securely destroyed or de-identified.

11. Access and Correction

You have the right to access, update, or correct your Personal Information, subject to certain exceptions. European residents can exercise this right by contacting us. Identification may be required for access requests.

12. Maintaining Data Accuracy

We strive to ensure your Personal Information is accurate, complete, and up-to-date. If you find inaccuracies, please inform us promptly.

13. Privacy by Design

We are committed to privacy by design principles, integrating data protection considerations into the development of our products and services.

14. Cookies and Tracking Technologies

We use cookies and tracking technologies for various purposes, such as improving user experience and analytics. Details on purposes and how users can manage preferences are outlined in our separate Cookie Policy.

15. Data Retention Policy

Personal information associated with user accounts will be retained for the duration of the user's engagement with our services. Upon termination of the user account or withdrawal of consent, this information will be securely deleted within a 60-day time frame. Retention periods for other categories of personal information are outlined in our Data Retention Policy, specifying when data will be deleted or anonymized.

16. International Data Transfers

We ensure that adequate protections are in place when transferring personal information internationally. Individuals have the right to obtain a copy of these safeguards upon request. Our standard practices include the use of mechanisms such as standard contractual clauses or binding corporate rules to uphold data protection standards during international data transfers

17. Data Breach Notification

In the event of a data breach, we are committed to promptly informing affected individuals within a 30-day period about any breaches that may pose a risk to their rights and freedoms. Additionally, we will take immediate action to remediate the risk and implement necessary measures to prevent further unauthorised access or disclosure of personal information. Simultaneously, we will communicate the breach to the relevant regulatory authorities in accordance with legal requirements.

18. Policy Updates

This Policy may be updated from time to time. Please visit our website to stay informed about any changes.

19. Contact Information

If you have any questions about our Privacy Policy, please contact us at projecttrain.info@gmail.com