Privacy and Cookie Policy

Last updated: December 13, 2024

 

  1.    Background

  •    Best of the Bone Pty Ltd ABN 46 667 925 206 is committed to responsible privacy practices and to complying with the Australian Privacy Principles (APPs) contained in the Privacy Act.
  •    Best of the Bone recognises and acknowledges that protecting the privacy of individuals’ personal information is important and required under the Privacy Act.
  •    This Privacy Policy sets out Best of the Bone’s policies on the management of personal information including how Best of the Bone collects personal information, the purposes for which Best of the Bone may use and/or disclose this information, how Best of the Bone may use and/or disclose the information Best of the Bone collects, and to whom this information is disclosed. Additionally, this policy explains how individuals can request access to and correction of the information Best of the Bone holds about them, how individuals can file complaints with Best of the Bone in respect of how Best of the Bone handles personal information held about them, and to make any related inquiry.
  •    Best of the Bone reserves the right to (at its discretion) change or replace this Privacy Policy from time to time. Best of the Bone will post the modified, amended or new privacy policy to its website in place of the superseded policy. At any time, the latest version of our Privacy Policy is available from our website www.bestofthebone.com.
  •    Best of the Bone acknowledges that the Privacy Principles contained in the Privacy Act is from a strict legal position applicable within Australia. Best of the Bone however is committed to having this Privacy Policy to operate globally, except where this policy conflicts with the requirements of the local jurisdiction (in such case, Best of the Bone will comply with the requirements of the local jurisdiction).

Changes to This Privacy Policy

  • We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the "Last updated" date and take any other steps required by applicable law.
  • Best of the Bone recommends that you regularly check our website to ensure that you are aware of the current version of our Privacy Policy. 

 

  1.    Key Definitions

In this Privacy Policy:

  • "personal information" has the meaning set out in the Privacy Act, and (in summary) means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or otherwise;
  • For the purposes of this policy, “personal information” includes the information set out below under “What types of personal information does Best of the Bone collect”.
  • "APPs" means the Australia Privacy Principles set out in the Privacy Act;
  • "Privacy Act" means the Privacy Act 1988 (Cth);

 

  1.    Types of Personal Information Best of the Bone Collect
  • The types of personal information we collect from you depend on the circumstances in which the information is collected.
  • We may collect contact details including your name, occupation, address, email address, phone and fax numbers and your date of birth. We may collect answers you provide to questions we ask and other information in relation to your dealings with us. If you purchase products or services from us, we may also collect certain transactional information and financial details to process the transaction. 
  • If you are an Individual Contractor to Best of the Bone, we may also collect information relevant to your engagement with Best of the Bone including qualifications, resume, reference information from your nominated referees, tax file number, bank details, insurance details, feedback from supervisors and training records.
  • Best of the Bone may collect your personal information when you apply for a role with Best of the Bone. Such information may include your qualifications, resume, reference information from your nominated referees, tax file number, bank details. Where you are unsuccessful in an application for a role with Best of the Bone, we may request that it retains your personal information to enable us to consider you for future roles that may become available.
  • Best of the Bone may also collect information about you when you access Best of the Bone’s website. When you use our website, we may collect website usage information such as the IP address you are using, your browser version, the website that referred you to us and the next website you go to, the pages you request while visiting our websites, the date and time of those requests and the country you are in.
  • In certain circumstances we are required to collect government identifiers such as tax file numbers, Medicare numbers, health service provider numbers, pension numbers and Veteran's Affairs numbers. Best of the Bone only collects, uses and discloses such information as permitted or required by law.
  • Best of the Bone does not collect, store or retain any credit card and other payment information in connection with products purchased from Best of the Bone via this website. All payments for products purchased from Best of the Bone via this website are processed through third party payment gateway providers. Best of the Bone uses its reasonable endeavours to ensure that all purchases made through Best of the Bone’s website are made using secure HTTP connections (you can check that the connection is secure when the URL for the “check-out” web-page commences with “https://”).
  • If you call us via telephone, we may monitor and, in some cases, record such telephone conversations for staff training, quality assurance and record-keeping purposes.
  • If we communicate with you by email, we may use technology to identify you so that we will be in position to know when you have opened the email or clicked on a link in the email.
  • If you access our Website, we may utilise cookies to collect additional information about your use of our Website and apps. Please see section 11 below for further details. 

In addition to the types of personal information identified above, we may collect personal information as otherwise permitted or required by law.
Where you do not wish to provide us with your personal information, we may not be able to provide you with requested goods or services and/or certain functionality of our Websites and apps.

  1.    How we collect your personal information

Best of the Bone only collects personal information using lawful and fair means. Best of the Bone will not collect personal information unless the information is reasonably necessary for one or more of Best of the Bone functions or activities.

Best of the Bone collects personal information in a number of ways. The most common ways Best of the Bone collects your personal information are:

  • from forms which you complete and submit to us, including online forms;
  • through mail correspondence, emails and other electronic means;
  • If you signed up to receive special offers and marketing materials from Best of the Bone
  • from job applicants and staff members;
  • from direct contact in the course of Best of the Bone providing goods and/or services to you;
  • in the course of Best of the Bone conducting market research, including customer satisfaction surveys;
  • in the course of answering a general inquiry regarding Best of the Bone, the products and/or services Best of the Bone provides;
  • directly from you when you provide it to us or our agents or contractors;
  • via our website or when you deal with us online (including through our social media pages, creating an account or making an enquiry);
  • if you are an individual contractor to Best of the Bone, from your employer or recruitment agency;
  • from our related companies;
  • from credit reporting agencies;
  • Work program; from referees if you apply for a position as an Employee or Contractor with us); and
  • from consumer feedback where it is possible we would likely get name and contact details. Some consumers provide fuller information such as the condition and treatment so that Best of the Bone can help them with product advice.
  • from public sources and third parties, such as recruitment agencies and referees (e.g. if you apply for a role with us); and as otherwise required to manage our business.

Best of the Bone will only collect personal information where Best of the Bone specifically requests that information, except in circumstances where personal information is volunteered to Best of the Bone or is otherwise supplied to Best of the Bone or disclosed to Best of the Bone without Best of the Bone asking for such information. 

If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.

 

  1.    Dealing with Best of the Bone anonymously or pseudonymously

In accordance with the requirements of the APPs, you have the option of not identifying yourself or of using a pseudonym when dealing with Best of the Bone in relation to a particular matter. However, in accordance with the APPs, the foregoing would not apply in relation to that matter if Best of the Bone is required or authorised by or under an Australian law, or a court or a tribunal order, to deal with individuals who have identified themselves concerning that matter.

Additionally, if it is impracticable for Best of the Bone to deal with individuals who have not identified themselves or who have used a pseudonym on a particular matter, then Best of the Bone would not be required to provide you with the option to engage with Best of the Bone on an anonymous or pseudonymous basis concerning that matter. For example, if you choose to interact and deal with Best of the Bone on an anonymous or pseudonymous basis, or if you do not provide Best of the Bone with personal information when requested, Best of the Bone may be unable to provide you with all of the products and/or services that you seek from Best of the Bone.

Further, Best of the Bone reserves the right to verify your identity as part of Best of the Bone’s response to a request to access and/or correct personal information Best of the Bone holds about you, or as part of Best of the Bone’s complaints-handling process. If Best of the Bone is unable to verify your identity, or if you continue to engage with Best of the Bone in an anonymous or pseudonymous basis, then Best of the Bone may be unable to satisfy your request or to complete its complaints-handling process.

 

  1.    Our purposes for handling your personal information

The purposes for which we use and disclose your personal information will depend on the circumstances in which we collect it. Whenever practical Best of the Bone will take reasonable steps to inform you why Best of the Bone is collecting your personal information, how we intend to use that information and to whom Best of the Bone intends to disclose it at the time we collect your personal information.

We may use or disclose your personal information:

  • for the purposes for which we collected it (and related purposes which would be reasonably expected by you);
  • for other purposes to which you have consented; and
  • as otherwise authorised or required by law.

In general Best of the Bone collects, uses and discloses your personal information so that we can do business together and for purposes connected with our business operations such as Best of the Bone providing you with information useful to your needs. Some of the specific purposes for which we collect, hold, use and disclose personal information are as follows:

  • to respond to you if you have requested information (including via our websites or via an email or other correspondence you send to us);
  • to provide goods or services to you or to receive goods or services from you;
  • to process transactions and to administer customer accounts;
  • to administer and manage services, including charging, billing and collecting debts;
  • to enable you to participate in any research or marketing or competitions or similar programs that Best of the Bone conducts from time to time;
  • to optimise and customise the user experience (including content and advertising) for users of our websites;
  • to improve products and services and keep you up to date on such improvements;
  • to understand Best of the Bone customers better and help improve Best of the Bone’s products and services;
  • to optimise and customise the user experience (including content and advertising) for users of the Websites;
  • to protect the security and integrity of the Website;
  •  to facilitate communications via our Website, social media platforms or third party websites/platforms, including communications with us or with other users of those platforms via direct messaging and posting to forums
  • to facilitate your entry and participation in a competition or trade promotion;
  • to allow performance reporting and benchmarking of our business, if applicable;
  • to contact you (directly or through Best of the Bone’s service providers) to obtain your feedback, to find out your level of satisfaction with our products and services and for other market research activities;
  • to consider you for a job (whether as an employee or contractor) or other relationships with us;
  • to verify your identity;
  • to enable and manage all Best of the Bone contracts, including supplier, contractor or consultant relationships;
  • to address any issues or complaints that we or you have regarding our relationship;
  • to directly market Best of the Bone’s products and services to current and prospective customers (including through direct mail and direct email to current and to prospective customers), provided that such recipients have not opted out of receiving such communications;
  • to protect the security, health and safety of our premises, facilities, personnel and visitors;
  • to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone, by fax or in any other lawful manner.
    Best of the Bone may also use and/or disclose personal information it collects about an individual for one or more of the following purposes:
  • assessing an opportunity to provide Best of the Bone’s products and services to a current or prospective customer;
  • to comply with Best of the Bone’s obligations with any law or statute that binds Best of the Bone;
  • to comply with Best of the Bone’s obligations under a contract into which Best of the Bone has entered;
  • to assess the suitability of an individual applying for a job with Best of the Bone; and
  • to assess and to manage the supply of goods and/or services to Best of the Bone by a contractor or service provider.

 

     7.  What happens if you don't provide personal information

  •    Generally, you have no obligation to provide any personal information requested by us. However, if you choose to withhold requested personal information, we may not be able to provide you with products and services that depend on the collection of that information.
  •    Individuals while seeking employment with Best of the Bone, who fail to provide any lawfully requested personal information, may experience delays in the consideration of their application for employment or it may result in their application for employment being unsuccessful.

 

  1.    Who do we disclose your personal information to

We may disclose your personal information to third parties in connection with the purposes described in section 6 of this Privacy Policy.  This may include disclosing your personal information to the following types of third parties:

  • Best of the Bone’s related companies, such as Orchard Pty Ltd; Melrose Laboratories Pty Ltd;
  • Our agents, suppliers, contractors and other third parties that provide goods and services to us (including suppliers, marketing agencies, data analysis specialists, data processing organisations, billing and debt recovery providers, website and data hosting providers and other IT suppliers) in order to enable them to provide products and/or services to Best of the Bone which may directly or indirectly benefit the individual from whom Best of the Bone collected the information;
  • Best of the Bone’s customers, where we are required to disclose personal information under contracts entered into with any of our customers;
  • Best of the Bone’s accountants, insurers, lawyers, auditors and other professional advisers;
  • government and regulatory authorities, courts, tribunals and other bodies as required or authorised by law;
  • any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees);
  • in the event that Best of the Bone or its business and assets may be acquired or considered for acquisition by a third party, that third party and its advisors;
    carefully selected third parties with whom Best of the Bone has data sharing arrangements;
  • third parties that require the information for law enforcement or to prevent a serious threat to public safety; and - otherwise as permitted or required by law.

Where we disclose your personal information to third parties, we will use take reasonable steps to ensure that such third parties only use your personal information as reasonably required for the purpose we disclosed it to them and in a manner consistent with the APPs.

If you post information to public parts of Best of the Bone websites or to its social media pages, you acknowledge that such information (including if it includes your personal information) may be available to be viewed by the public. You should use discretion in deciding what information you upload to such sites. Without limiting the foregoing, we Best of the Bone may disclose personal information about an individual when required by law or court order, or other governmental order or process to disclose, where Best of the Bone believes in good faith that the law compels Best of the Bone to disclose the information.

Best of the Bone may disclose personal information of an individual where Best of the Bone considers (in good faith) that it is reasonably necessary for Best of the Bone e to do so in order to identify, contact or bring legal action against an individual whom Best of the Bone suspects or knows is causing harm to Best of the Bone, its business or operations.

 

  1.    Overseas transfers of personal information

Some of the third parties to whom we disclose personal information may be located outside Australia.  The countries in which such third-party recipients are located depend on the circumstances. Whenever we transfer your personal information outside of Australia, we will do so in accordance with the requirements of applicable privacy and data protection laws.

From time to time, we may also engage an overseas recipient to provide services to us, such as cloud-based storage solutions.  Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider.

By providing your personal information to us, you consent to us disclosing your personal information to any such overseas recipients for purposes necessary or useful in the course of operating our business, and agree that APP 8.1 will not apply to such disclosures.  For the avoidance of doubt, in the event that an overseas recipient breaches the Australian Privacy Principles, that entity will not be bound by, and you will not be able to seek redress under, the Privacy Act.

 

  1.    Use or disclosure of personal information for the purpose of direct marketing

Like most businesses, marketing and advertising is important to our continued success.  We therefore like to stay in touch with customers and let them know about new offers and opportunities.

Best of the Bone reserves the right to use and disclose your personal information for the purpose of direct marketing to you where:

  • you have consented to us doing so;
  • where we collected your personal information directly from you, in circumstances where you would reasonably expect us to use and/or disclose your personal information for the purpose of direct marketing or
  • it is otherwise permitted by law.

 

Direct Marketing

Direct marketing involves communicating directly with you for the purpose of promoting goods or services to you and to provide you with special offers. Direct marketing can be delivered by a range of methods including mail, fax, telephone, email or SMS. You can unsubscribe from our direct marketing, or change your contact preferences, by exercising the opt-out mechanism included with each direct marketing communication or through contacting us (see section 15).

In directly marketing Best of the Bone’s products and services to you, Best of the Bone will comply with other laws relevant to marketing, including the Spam Act 2003 (Cth), the Do Not Call Register Act 2006 (Cth) and the Competition and Consumer Act 2010 (Cth) (including the Australian Consumer Law). All direct marketing communications which Best of the Bone may send will include an easy opt-out mechanism if at any time you wish to stop receiving direct marketing communications from us.

 

Email analytics

Like many organisations, Best of the Bone use e-mail analytics to track and measure the success of our e-mail newsletters and other e-mail campaigns.

We use various technologies (such as tracking pixels) to collect information such as: which of our emails you have opened, which links you have clicked, which email client you are using, whether you opened our e-mail on a computer or mobile device, and the geolocation of your IP address.  We use this data to analyse and improve the performance of our e-mail campaigns.

 

Internet / Digital advertising

Best of the Bone may also collect and use information about you for the purposes of online targeted advertising services that help our ads to reach you (and other people who may be interested in our products and services) on websites, apps and social media platforms across the Internet.  These online targeted advertising services are operated by third party vendors such as Meta (which operates Facebook and Instagram) and Google Ads.

Some of these services work by using non-identifying data about your behaviour and demographics that has been collected through cookies and other tracking technologies (such as pixels and device identifiers) when you use the Internet, including when you move between different websites and apps and use different devices.  For example, third-party vendors may use cookies and/or device identifiers to serve ads based on your past visits to our websites.  Your browser or device may provide you with the option to disable or opt-out of some of these cookies and other tracking technologies (such as device identifiers).

Other services require us to use limited amounts of your personal information.  For example, we may include your information in a customer list that we provide to selected online advertising service providers so that we can conduct audience-based advertising.  This allows us to show our ads to you (if you also use those platforms) and to other users of those platforms who share similar characteristics with you.  The customer list is usually hashed (to improve security and confidentiality) before it’s processed by the service provider to target and serve our ads.

The data that is collected through these cookies and other tracking technologies, or provided by us, may be combined with other data (supplied by our advertising service provider, or third parties) to improve the targeting and serving of ads.
Our online advertising service providers also help us by measuring the effectiveness of our ad campaigns (e.g. conversion tracking) and providing us with analytics data that we use to inform and optimise our ad campaigns.  These analytics are based on data that may be collected through cookies and other tracking technologies.  The analytics data we receive is generally aggregated and non-identifying.

When we use any advertising service that requires us to use or disclose your personal information, we will only do so if we are permitted to do so by applicable privacy laws.  You can notify us at any time if you would like us to stop using your personal information for these targeted advertising purposes.

Our contact details are set out in section 17 of this Privacy Policy.
You can also:

Opt-out of certain online targeted advertising networks directly by visiting:

  • the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/; and
  • the Network Advertising Initiative’s opt-out page: http://www.networkadvertising.org/managing/opt_out.asp
  •  view the relevant social media platform's website to learn more about how they collect and use your information and adjust your preferences regarding the types of advertising you are shown.


11.  Security and protection of personal information

Best of the Bone will take reasonable steps to keep any personal information we hold about you secure from misuse, interference and loss, and from unauthorised access, modification and disclosure. Please notify us immediately if you become aware of any breach of security. Best of the Bone regularly reviews and updates its physical and data security measures in light of current technologies and threats. Unfortunately, no data transmission over the Internet or over mobile data and communications services can be guaranteed to be totally secure.

In addition, Best of the Bone’s employees and contractors who provide services to us or who have access to personal information Best of the Bone collects and holds are obliged to respect the privacy of any personal information we hold.
Best of the Bone does everything reasonably within its power and control to prevent unauthorised use or disclosure of personal information Best of the Bone collects and holds.

However, to the maximum extent permitted by law, Best of the Bone is not responsible for events arising from unauthorised use of or access to personal information except to the extent that such unauthorised use or access is as a result of Best of the Bone’s failure to comply with its legal obligations concerning the steps taken to secure the personal information Best of the Bone collects and holds.

Additionally, in accordance with Best of the Bone’s statutory obligations, it will take reasonable steps to destroy or to de-identify personal information when the information is no longer required for the purpose(s) for which the information as collected. Where Best of the Bone destroys or de-identifies personal information, we will endeavour to do so via a secure means.

 

  1.    Accuracy of the personal information we hold
  • Best of the Bone will take reasonable steps to maintain your personal information as accurately as reasonably possible. However, Best of the Bone relies on the accuracy of personal information as provided to us both directly (from you) and indirectly.
  • You may contact us if the personal information we hold about you is incorrect or to notify us of a change in your personal information. Our contact details are set out below.
  • Corrections will be made to any incorrect information or, in the event of a correction being refused, a reason will be provided.
  • Where information about an individual is corrected, and the information has previously been disclosed to third parties, Best of the Bone will take reasonable steps to notify third parties of the correction.

 

  1.    User Generated Content
  •    Our Services enable you to post product reviews and other user-generated content. If you choose to submit user generated content to any public area of our Services, this content will be public and accessible by anyone.
  •    We do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available, or for the accuracy, use or misuse of any information that you disclose or receive from third parties.

 

  1.    Links, cookies and use of websites and applications

Links

Best of the Bone websites may contain links to other sites. This Privacy Policy applies to our websites and not any linked sites which are not operated or controlled by Best of the Bone. We encourage you to read the privacy policy of each website that collects your personal information.

Cookies

Best of the Bone uses "cookies" and similar technology on its websites and in other technology applications. The use of such technologies is an industry standard, and helps us monitor the effectiveness of our advertising and how visitors use our websites/applications. We use such technologies to generate statistics, measure your activity, improve the usefulness of our websites/applications and to enhance the customer experience.

If you prefer not to receive cookies you can adjust your Internet browser to refuse cookies or to warn you when cookies are being used. However, our websites may not function properly or optimally if cookies have been turned off.

 

  1.    Assessing and correcting your personal information

You may seek access to personal information which Best of the Bone holds about you by contacting us as described below. Best of the Bone will provide access to that information in accordance with the APPs, subject to certain exemptions which may apply.

  • Best of the Bone reserves the right to require that the person requesting access provide suitable identification (to ensure that Best of the Bone does not inadvertently release or disclose personal information to an individual not entitled to access such information) and where permitted by law Best of the Bone may charge a reasonable fee to cover Best of the Bone’s costs incurred in providing access to your personal information.
  • Further, Best of the Bone reserves the right to redact information it makes available in response to an access request, to protect the privacy of other individuals.
  • From to time, Best of the Bone may refuse to provide access to the information held about an individual, in accordance with the APPs. Where Best of the Bone refuses access, Best of the Bone will explain the reasons for refusal in writing and provide details in relation to the relevant complaint process.
  • We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so.  If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.
  • We will respond to all requests for access to or correction of personal information within a reasonable time.

As noted above, Best of the Bone takes reasonable steps to ensure that the information Best of the Bone collects, holds, uses and discloses about an individual is complete, up-to-date and accurate. However, if at any time you believe or become aware that any personal information, we hold about you is incorrect or if you wish to update your information, you have the right to request that Best of the Bone amends or updates such information. If Best of the Bone refuses the correction request, Best of the Bone will provide written reasons and information about the complaints process should you not be satisfied with Best of the Bone’s reasons.

 

  1.    Privacy Complaints Process

If you have any questions, comments or complaints about our collection, use or disclosure of personal information, or if you believe that we have not complied with this Privacy Policy, the Privacy Act, please contact us using the details below.

  • When contacting us please provide as much detail as possible in relation to your question, concern or complaint. 
  • We take all complaints seriously, and will respond to your complaint in accordance with any applicable timeframes imposed by law and otherwise within a reasonable period. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
  • Best of the Bone reserves the right to verify your identity and to seek (where appropriate) further information from you in connection with your complaint.
  • Where required by law, Best of the Bone will provide its determination on your complaint to you in writing.
  • Please note that, in accordance with the APPs, Best of the Bone reserves the right to refuse to investigate or to otherwise deal with a complaint if Best of the Bone considers your complaint to be vexatious or frivolous, or as otherwise permitted by law.

If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:

  • Office of the Australian Information Commissioner 
  • GPO Box 5218, Sydney, NSW  2001 
  • Telephone: 1300 363 992 
  • Email: enquiries@oaic.gov.au  

 

  1.    How can you contact us?

Please address all privacy complaints, unsubscribes and requests to update or access information to:

  • Attention: Best of the Bone Customer Service
  • Address: 16-18 Lionel Road, Mount Waverley, VIC Australia 3149
  • Email: info@bestofthebone.com.au

 

Any requests to access, update or correct your health information should be made in writing.