well-r

Privacy Policy

This Privacy Policy applies specifically to well-r, a searchable online directory that allows current IICT members to publish their business details and be found and contacted by members of the public seeking treatment in a particular modality.

This Policy applies specifically to well-r. It does not affect any separate privacy terms that apply to your IICT membership. Use of well-r is also subject to the separate well-r Terms & Conditions.

1. Overview

This Privacy Policy explains how we collect, use, and disclose personal information in connection with well-r.

2. Information We Collect

From Practitioners, for the purpose of a public Listing

To create and display a Listing, we collect information such as: business/trading name, business contact number and email, website and social media links, business address or service area, modality/modalities practised, qualifications and accreditation status, a professional photo, a bio or description of services, availability, and treatment or pricing information (where provided).

This information is published on well-r and is intended to be publicly visible and searchable by Customers. Practitioners should not include any personal information in their Listing that they do not wish to be made public.

From Customers, when searching or making contact

When a Customer searches well-r or contacts a Practitioner, we may collect the Customer's name, email address, phone number, the content of their enquiry, and standard technical and usage information (such as IP address, browser type, and pages viewed) collected via analytics tools described in Section 6.

3. How We Use This Information

• Practitioner Listing information is displayed publicly to enable Customers to search for and identify suitable practitioners, and is used by us to confirm current IICT membership and accreditation status for eligibility to list on well-r.

• Customer enquiry information is used to connect the Customer with the relevant Practitioner and, where necessary, to enable us to respond to platform support requests, resolve disputes, and detect misuse of well-r (such as spam).

• Aggregated or de-identified usage data may be used to improve well-r's functionality and to understand demand across modalities and locations.

4. How We Disclose This Information

4.1 Practitioner Listing information is disclosed to the public generally --- this is the core purpose of well-r.

4.2 Customer enquiry information is disclosed only to the specific Practitioner the Customer chooses to contact. Once a Practitioner receives a Customer's enquiry, the Practitioner is separately responsible, as an independent business, for handling that information in accordance with their own obligations under applicable privacy law (including, where applicable, the Australian Privacy Principles under the Privacy Act 1988 (Cth)). We are not responsible for a Practitioner's subsequent use, storage, or disclosure of information received via a well-r enquiry.

4.3 We do not sell Practitioner or Customer personal information to third parties, and will not use Customer contact details to promote unrelated third-party products or services.

4.4 Overseas Disclosure of Personal Information. Some of the third-party services used by well-r, including the analytics and remarketing providers described in Section 6 (such as Google Analytics, Google Ads, and Facebook), operate servers located outside Australia, including in the United States. Where personal information (such as IP address or device and browsing data) is collected or processed by these providers, it may be transferred to and stored in those overseas locations as part of their standard operations. Other than through these analytics and remarketing providers, we do not otherwise disclose personal information to recipients located outside Australia. We take reasonable steps to ensure that overseas recipients handle personal information consistently with the Australian Privacy Principles, to the extent practicable. If you are located in the European Economic Area, the United Kingdom, or Switzerland, see also Section 9.3 for additional information about how we safeguard transfers of your personal information.

5. Data Security and Retention

We take reasonable technical and organisational steps to protect personal information collected through well-r from misuse, loss, and unauthorised access. Information is retained only for as long as reasonably necessary for the purposes described in this Policy, or as required by law.

6. Analytics, Cookies, and Remarketing

well-r may use third-party analytics and remarketing services, including Google Analytics, Hotjar, Google Ads, and Facebook, to understand usage of well-r and to serve relevant advertising. These providers may use cookies and similar technologies to collect information about your device and browsing activity on well-r.

You can opt out of Google Analytics by installing the Google Analytics opt-out browser add-on, manage Google Ads personalisation via Google's Ads Settings page, and manage Facebook's interest-based ads via Facebook's ad preferences. Please refer to each provider's own privacy policy for further detail.

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we will ask for your consent via a cookie banner on well-r before setting non-essential analytics or remarketing cookies, and you may withdraw that consent at any time. If you are a California resident, see Section 10 for information about opting out of the sharing of your personal information for advertising purposes.

7. Access and Correction

Practitioners can review and correct their Listing information at any time via their profile on well-r. Customers who wish to access, correct, or request deletion of information submitted through an enquiry may contact us using the details below.

8. How to Complain

If you believe your personal information has been handled in a way that breaches this Privacy Policy or the Australian Privacy Principles, you can lodge a complaint with us using the contact details in Section 12. Please include as much detail as possible so we can look into your concern.

We will acknowledge your complaint within 5 business days and aim to investigate and respond within 30 days of receipt. If you are not satisfied with our response, or do not receive a response within a reasonable time, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au or by calling 1300 363 992.

9. Your Rights if You Are Located in the EU, UK, or Switzerland

If you are located in the European Economic Area, the United Kingdom, or Switzerland, the following additional information applies to the personal information we process about you.

9.1 Legal basis for processing. We rely on the following legal bases to collect and use personal information: performance of a contract (to create and display a Practitioner's Listing, or to connect a Customer with a Practitioner they choose to contact); our legitimate interests (for example, to operate, secure, and improve well-r, or to detect misuse); consent (for example, for non-essential cookies, or where a Customer's enquiry discloses health information); and compliance with a legal obligation.

9.2 Your rights. Subject to applicable law, you may have the right to request access to, correction of, or erasure of your personal information; to restrict or object to our processing of it; to receive a copy of it in a portable format; and to withdraw consent at any time where processing is based on consent. You may exercise these rights using the contact details in Section 12.

9.3 International transfers. well-r operates from Australia, which does not currently have an EU or UK adequacy decision. Where personal information is transferred from the EEA, UK, or Switzerland to Australia or another country outside those regions, we take reasonable steps to ensure appropriate safeguards are in place, such as the EU Standard Contractual Clauses (or the UK equivalent), a copy of which can be requested using the contact details in Section 12.

9.4 Supervisory authority. In addition to contacting us under Section 8, you have the right to lodge a complaint with your local data protection supervisory authority (for example, the UK Information Commissioner's Office).

10. Your Rights if You Are a California Resident

If you are a California resident, and to the extent the California Consumer Privacy Act (as amended by the California Privacy Rights Act) applies to well-r, you may have the right to: know what personal information we have collected about you and how it has been used and disclosed; delete personal information we hold about you, subject to certain exceptions; correct inaccurate personal information; opt out of the sale or sharing of your personal information; limit the use of sensitive personal information; and not be discriminated against for exercising any of these rights.

Some of the analytics and remarketing tools described in Section 6 (such as Google Ads and Facebook) may be considered a "sale" or "share" of personal information under California law, even though we do not sell information for money. If you are a California resident and wish to opt out of this sharing, or to exercise any other right described above, please contact us using the details in Section 12.

Whether these rights formally apply depends on whether well-r meets the relevant business thresholds under California law. We provide these rights as a matter of good practice regardless of whether that threshold is met.

11. Practitioner Responsibilities for Customer Information

Practitioners who receive a Customer's contact details or enquiry through well-r must handle that information confidentially, in accordance with therapist/client confidentiality obligations and any applicable privacy or health-record laws, and must not use it for marketing purposes unrelated to the Customer's original enquiry without the Customer's separate consent.

12. Contact Us

If you have any questions about this Privacy Policy, please contact us using the contact details on well-r.

This Policy applies specifically to well-r. Your IICT membership information remains subject to IICT's own membership Privacy Policy.