Privacy Policy
Equalution PTY. LTD. (ACN 613 448 418) (equ, or ‘our’ or ‘we’) is in the business of a subscription-based diet and nutrition service and other ancillary services provided offline or online, including through our mobile application and our website (located at www.joinequ.com.au) (Services).
This Policy governs how equ will deal with your Personal Information collected in connection with the Services.
This Policy applies to Personal Information collected by equ in connection with its website, social media accounts, applications, software and other technological means (Online Platforms), as well as in connection with any direct communication between you and equ.
Please read this Policy carefully. By using the Services and our Online Platforms, you consent to us collecting, holding, using and disclosing your personal information in accordance with this Policy.
DEFINITIONS
In this Policy, the following defined terms are used:
Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
Privacy Act means the Privacy Act 1988 (Cth).
Sensitive Information means Personal information that includes information or an opinion about an individual’s:
• racial or ethnic origin.
• political opinions.
• membership of a political association.
• religious beliefs or affiliations.
• philosophical beliefs.
• membership of a professional or trade association.
• membership of a trade union.
• sexual orientation or practices.
• criminal record.
• health information.
• genetic information about an individual that is not otherwise health information.
• biometric information that is to be used for the purpose of automated biometric verification or biometric identification.
• biometric templates.
1. SCOPE OF THIS PRIVACY POLICY
1.1. We understand that when accessing our Services, the privacy and confidentiality of Personal Information (as defined under the Privacy Act 1988 (Cth) (Privacy Act)) is important to you. That’s why we fully respect your rights to privacy and are committed to protecting the personal and financial details you provide us in line with this Privacy Policy. This Privacy Policy applies to our Services and all individuals who use our Services or whose Personal Information is processed by equ.
1.2. We are committed to protecting the privacy of everyone who uses our Online Platforms and/or our Services, for them to understand what Personal Information we collect and store, and why we do so, how we receive and/or obtain that information, the rights an individual has with respect to their Personal Information in our possession, and with complying with the Australian Privacy Principles set out in the Privacy Act and the General Data Protection Regulation (EU) 2016.679 (GDPR).
2. THE INFORMATION WE COLLECT
We may collect Personal Information that allows us to identify who an individual is and share Personal Information. This information may be collected directly from you or from third parties, such as social media platfroms or your healthcare providers (including your GP where you consent).
The type of information we may collect includes:
- Content you upload to the Online Platforms - We collect your name, images or videos, location, date of birth, your preferences and/or opinions, health information and any other information you upload, share or submit to our Online Platforms;
- Contact Information – We collect information such as an your email address, telephone & fax number, third-party user names, residential, business and postal address and other information that allows us to contact you;
- Financial Information – We collect financial information such as any bank or credit card details used to transact with us and other information that allows us to transact with you and/or provide you with our Services;
- User Information – We may also collect any information you provide to us including through customer surveys and health assessment questionnaires, our communications with you, your browser session and geo-location data and other network information, information about your access to and use of our Online Platforms, including through the use of cookies;
- Statistical Information – We collect behavioural and statistical information about an individual and businesses in connection with the Services and/or the Online Platforms; and
- Any other Personal Information you share with us.
We may collect Sensitive Information including:
• height and weight;
• personal medical history;
• use of medication;
• food and nutritional consumption; and
• allergies and food preferences.
We will not collect Sensitive Information about you without first obtaining your consent. Your consent will be implied where, for example, you upload Sensitive Information into our Online Platforms like our nutrition chatbot.
We will primarily collect Sensitive Information from you when you complete our health assessment questionnaire and if you upload any Sensitive Information (e.g. about your health conditions and allergies) on our nutrition chatbot.
3. HOW INFORMATION IS COLLECTED
Personal Information may be collected directly from you when you use our Services or Online Platform, or from third parties, such as social media platforms or your healthcare providers where you provide us with their contact details and consent to us contacting them .
4. WHY WE COLLECT PERSONAL INFORMATION
4.1. We collect your personal information so that we can carry out the following actions:
- to provide our Services including formulating custom meal plans and personalised nutrition information for you;to enable you to use our Online Platforms;
- to enable you to use our Online Platforms;
- to verify your identity and maintain your user account on our Online Platforms;
- to communicate with you, including about our Services and offers which might interest you or services and information about third parties that we consider may be of interest to you;
- to run competitions;
- to provide customer service functions, including handling customer enquiries, complaints and feedback;
- to facilitate proper governance processes such as risk management, incident management, internal audit and external audits;
- to gather feedback from you and other individuals about the quality of Services and Online Platforms so that these can be continuously improved, and to deal with any complaints made (for example, complaints on the decisions generated by our AI nutrition chatbot or content uploaded to a Community Group);
- to process payments by or to you in connection with our Services;
- for analytics, market research and business development, including to operate and improve our Platform, associated applications and associated social media platforms;
- for marketing, for example, on our social media to show your weight loss or nutrition progress;
- to consider any application you make to work with us;
- to develop our Online Platforms including the artificial intelligence tools (AI Tools) we use to operate our AI Nutrition Chatbot and AI Photo and Menu Scanner, addressed further at section 6 of this Policy;
- to comply with our legal obligations, exercise our legal rights and to resolve any disputes that we may have; and
- to fulfill other purposes which you have consented to.
4.2. Your Sensitive Information may be used or disclosed:
• for a purpose described in this Policy;
• for another purpose, with your consent; and
• as required or permitted by law.
4.3 We may set out additional purposes for collection of your Personal and Sensitive Information in collection statements at the point of collection.
4.4 We will only process your Personal Information for our legitimate interest if we receive any requests, or we must perform a service in relation to, for example, any of our products or services.
5. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
5.1. We will disclose your Personal Information to third parties outside of our organisation, either:
- with your consent;
- as required or permitted by law; or
- for a purpose described in this Policy.
5.2. Examples of third parties that your Personal Information may be disclosed to include:
• third party service providers and contractors for the purpose of assisting us in the delivery of the Services and operation of the Online Platforms, including IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers and payment systems operators;
• any of our related entities;
• our existing or potential agents or business partners;
• sponsors or promoters of any competition we run;
• anyone to whom our business or assets (or any part of them) are, or may be, transferred;
• credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for the Services we have provided to you or use of our Online Platforms;
• courts, tribunals, regulatory authorities and law enforcement officers, as required by law, or our lawyers in connection with any actual or prospective legal claim, or in order to establish, exercise or defend our legal rights;
• third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia;
• professional service providers; and
• as otherwise required, authorised or permitted by law.
6. AI TOOLS
6.1. We use artificial intelligence tools (AI Tools) to provide certain features of our Online Platforms and Services, including:
• our AI Nutrition Chatbot that responds to your queries; and
• our AI Photo and Menu Scanning Tool.
6.2. The AI Tools rely on automated processing, pattern recognition and statistical models to generate outputs. AI Tools outputs may contain errors and should be used for general informational purposes only. More information about using our AI Tools and their limitations is set out in our Terms and Conditions.
6.3. When you use the AI Tools:
• Information you input (including your Personal and Sensitive Information) is processed by the AI Tools to generate responses.
• Information you input will be shared with the third party AI service providers who provide our AI Tools including OpenAI, Langchain and Gemini. To understand how these AI service providers process your Personal and Sensitive Information, you should consult their privacy policies, available on their websites.
• Your Personal and Sensitive Information will not be used to train a third party service provider's AI without your consent. This is requested upon use of AI Coach with an active Acceptance to continue using Coach.
6. WHEN PERSONAL INFORMATION IS USED & DISCLOSED
6.1. We will not use any Personal Information other than for the purpose for which it was collected other than with the individual’s permission.
6.2. We will retain Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
6.3. There are some circumstances in which we must disclose an individual’s information:
- where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;
- as required by any law (including the Privacy Act and GDPR); and/or
- in order to sell our business (in that we may need to transfer Personal Information to a new owner).
7. DIRECT MARKETING
7.1. We may use your Personal Information to inform you of goods and services that may be of interest to you, and for other promotional purposes. If you do not wish to receive marketing or promotional communications from us, you should ‘unsubscribe’ online where a link is provided. In other circumstances, you should contact us using the contact details below indicating that you opt out of marketing communications and we will cease the relevant communication.
7.2. An individual may also opt to not have us collect and handle their Personal Information at all (for example, by telling us before they sign up to our Services or use our Online Platforms that they do not consent to our collection and handling of their Personal Information). This may prevent us from offering them some or all of our Services and access to our Online Platforms, and otherwise limit our ability to engage with them including to respond to any queries they may have.
8. COOKIES
We may use temporary (session) cookies or permanent cookies when you access our Online Platforms and/or Services. This allows us to recognise your browser and track the web pages you have visited. You can switch off cookies by adjusting the settings on your web browser.
We may use web beacons on our Platform from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.
9. THE SAFETY & SECURITY OF PERSONAL INFORMATION
9.1. We may hold your Personal Information in either electronic or hard copy form.
9.2. If you provide information to us electronically we retain this information in our computer systems and databases. If you provide information to us in hard copy (paper) this information is normally retained in our files and a copy is made to our electronic files.
9.3. We use certain security measures to safeguard and protect your information including password protection, authentication required to acess/update user data, 3rd party (on b2b servers) andt obfuscating identity
9.4. We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s Personal Information to in accordance with this policy or any applicable laws). The collection and use of an individual’s information by such third parties are subject to separate privacy and security policies.
9.5. If an individual suspects any misuse or loss of, or unauthorised access to, their Personal Information, they should let us know immediately.
9.6. Where we become aware of any breach to our security systems that breaches or is likely to result in a breach of your rights or freedoms with respect to your Personal Information, we will notify you and any regulatory authority as required by law.
10. OVERSEAS DISCLOSURES
10.1. We may disclose your Personal Information to third parties and service providers located overseas in connection with any purpose described in this Policy or authorised by law, including to overseas cloud computing hosts.
10.2. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations under the Privacy Act relating to your Personal Information.
10.3. The countries where these third parties and service providers are located include America and Europe
10.4. If you object to the disclosure of your Personal Information to recipients outside Australia, you should contact us using the below contact details.
11. HOW TO ACCESS AND/OR UPDATE INFORMATION
11.1. You are entitled to request access to the Personal Information held by us about you. This is generally provided upon your request unless we are permitted or required by law to refuse access.
11.2. Where you inform us that Personal Information held by us about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will correct it where we agree with you. If, having received and considered an application from you to amend your information, we do not consider that the information should be amended, we will not amend it but we will include a note with the information that you believe that it should be amended, and advise you that we have done this.
11.3. If you would like us to access or amend the Personal Information we hold about you, please contact us via your in-app support chat platform on our Online Platform, or using the contact details set out below.
11.3. We may ask you to verify your identity to ensure that your Personal Information is not improperly accessed or amended.
12. RIGHT TO BE FORGOTTEN
In the event that you decide that you no longer want us to hold your Personal Information, you may notify us in writing on the contact details set out below of your desire for us to delete your Personal Information on record. We will use our best endeavours and comply with all legal requirements within a reasonable timeframe to delete your Personal Information, unless we are required by law to retain such information.
13. LINKS
Links from our Online Platforms or via our Services to third party services that we do not operate or control are provided for your convenience. We are not responsible for the privacy or security practices of services that are not covered by this Privacy Policy. Third party services should have their own privacy and security policies which we encourage you to read before supplying any personal information to them.
14. COMPLAINTS AND DISPUTES
14.1. If an individual needs to contact us or has a complaint about our handling of their Personal Information, they should address their communication in writing to the details below:
Privacy Officer
Email: [email protected]
14.2. We will treat your enquiry or complaint confidentially.
14.3. You may contact the Office of the Australian Information Commissioner (www.oaic.gov.au), or by post to GPO Box 5218 Sydney NSW 2001, or by email to [email protected] wherever you believe that your rights to privacy have been breached by us and you are not happy with how we have responded to your complaint.
15. GDPR
15.1. If you are:
- A resident of the European Union accessing our Online Platforms or receiving our Services in Australia; or
- accessing our Online Platforms or receiving our Services from within the European Union,
then in addition to our obligations under the Privacy Act, equ is required to comply with the GDPR with respect to your Personal Information.
15.2. Any reference to Personal Information in this Privacy Policy is also a reference to Personal Data (as defined under the GDPR).
15.3. equ takes the security and privacy of your Personal Information seriously and has prepared this privacy policy and taken measures to collect, process and hold all Personal Information in compliance with both the Privacy Act and GDPR regardless of the user. Therefore, no additional terms for GDPR users are required.
16. ADDITIONS TO THIS POLICY
We may, at any time and at our discretion, vary this Privacy Policy. We will notify you if we amend this Privacy Policy, by contacting you through the contact details you have provided to us. Any amended Privacy Policy is effective once we notify you of the change.
Version Date: 16th May 2026
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