Privacy Policy

Please fine below two privacy policies. 

1. Company Privacy Policy

2. E4L AI Voice Assistant Privacy Policy

_______________________

1. Company Privacy Statement

Individually, as a brand and as a company, we would never request or demand another human, member, or staff member to provide or present to us private medical information or personal private information. In respect to the integrity of personal privacy, The Privacy Act 1988, Discrimination Act 1991, Bio-Security Act 2015, Common Law, and Common Courtesy, this company privacy directive and company privacy mandate will always be in force.

Our focus as a leader in the space is to encourage a holistic approach to health and fitness with an inclusive and tolerant community. Cellular health protocols and education, effective fitness regimes, and better toxin-free lifestyle choices are at the core of our philosophy, and we look forward to becoming an expanding influence in this area in our community.

PLEASE NOTE: By visiting or logging into our website, cookies and related technologies may be employed by our data partners or vendors to connect your actions with personal information they or others may possess, including your email address. This information may be used by us or our service providers to deliver marketing messages or other communications to your email.

2. Know Your Rights

• Source – https://humanrights.gov.au/quick-guide/12030
• Source – https://humanrights.gov.au/our-work/employers/quick-guide-australian-discrimination-laws
• Source – https://humanrights.gov.au/sites/default/files/GPGB_quick_guide_to_discrimination_laws_0.pdf

3. Detailed Privacy Policy

This Privacy Policy applies to Elements4Life (E4L), which is a subsidiary of 432 Lifestyles PTY LTD ABN 40 644 961 295, as well as to all related companies and E4L Licensed Clubs & Facilities (collectively, Elements4Life). This Privacy Policy covers how E4L collects, uses, discloses, and stores your personal information and explains your rights under the Australian Privacy Principles (APP) contained in the Privacy Act 1988 (Cth) (the Act).

This Policy governs your dealings with E4L whether at an E4L club, E4L head office, or via the E4L website (www.elements4life.com.au).

Specifically, this Privacy Policy explains:

1. The types of personal information E4L collects and holds;
2. How E4L collects and holds your personal information;
3. Why E4L collects, holds, uses, and discloses your personal information;
4. How you may access and seek the correction of your personal information held by E4L;
5. How you may complain about a breach of the APPs or a registered APP code (if any) binding E4L, and how E4L will deal with such a complaint;
6. Whether E4L is likely to disclose your personal information to overseas recipients, and if so, the likely countries involved.

By using E4L’s website (www.elements4life.com.au) or completing any membership application forms, personal trainer forms, competition entry forms, or franchisee recruitment forms, you accept this Privacy Policy and expressly consent to E4L’s collection, use, and disclosure of your personal information in the manner described below.

3.1. Your Personal Information

E4L only collects personal information (information that identifies or could reasonably identify an individual) where it is reasonably necessary for E4L’s functions and activities. Such collection can include:

• Processing and managing membership and franchisee applications;
• Facilitating members’ and casual members’ gym access;
• Conducting marketing activities, research, and special offers;
• Accurately identifying those who use E4L’s services;
• Communicating with members, franchisees, and website visitors;
• Profiling our members and their interests;
• Operating the E4L business; and/or
• Transferring memberships between clubs under E4L’s transfer policy.

Typical types of personal information collected include:

• Name, age, gender, date of birth, and next of kin
• Health information (height, weight, medical conditions)
• Health and fitness goals
• License and banking details
• Contact details (phone, fax, email)
• Views and opinions
• Responses to forms and surveys (if any)

3.2. Your Sensitive Information

Sensitive information is personal information regarding racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, professional or trade association memberships, trade union membership, health or disability details, sexual orientation, or criminal record.

E4L only collects sensitive information where it is reasonably necessary for E4L’s functions or activities, and either you have consented or E4L is required or authorized under law to do so.

3.3. How E4L Collects Your Personal Information

E4L will collect your personal information through lawful and fair means directly from you unless it is unreasonable or impracticable to do so. Direct collection can occur via:

• Email
• Telephone (including calls and SMS)
• Social media and intranet (including surveys)
• Written correspondence (letters, faxes)
• Hard copy forms (registration, competition entry, surveys)
• In person
• E4L website (online purchases, form submissions, live chats)
• Electronic systems such as applications and use of a club access card
• E4L’s security surveillance cameras

E4L may also collect information from third parties, such as:

• Your personal trainer
• Market researchers & direct marketing providers
• Parents or guardians of underage members
• Current members (refer a friend)
• The Australian Tax Office (ATO) and the Australian Securities and Investment Commission (ASIC)
• Public sources (directories, membership lists, professional and trade associations, ASIC, bankruptcy, or court registry searches)

3.4. Unsolicited Personal Information

Unsolicited personal information is information that E4L receives without having taken active steps to collect it (e.g., an unrequested job application). If such unsolicited information is reasonably necessary for one or more of E4L’s functions or activities, E4L may keep records of it. Otherwise, E4L will destroy or de-identify the unsolicited information when lawful and reasonable to do so.

3.5. Using Your Personal Information

The main purposes for which E4L collects, holds, uses, and discloses personal information are to provide services and benefits to members and to grow E4L’s membership. This includes:

• Processing applications for memberships, franchisees, and prospective franchisees
• Understanding members’ needs and requirements
• Managing and running E4L’s website and social media platforms
• Providing information about E4L’s services
• Delivering or enhancing E4L’s products and services
• Helping E4L maximize the benefits provided to members
• Any other purpose directly related to E4L’s business for which you have provided consent (as required by law)

When you use E4L’s website, certain services or functions may require subscription or registration. You will know what information is being collected when you complete the relevant forms. E4L may also use your data to monitor for any unauthorized use of the website or E4L content.

3.6. Purpose of Collection (Primary vs. Secondary)

E4L will not use or disclose personal information for any purpose (secondary) other than the primary purpose of collection, unless one of the following applies:

1. You have consented to such use or disclosure.
2. You would reasonably expect E4L to use or disclose your information in that way, and it is directly related (for sensitive information) or related (for non-sensitive information) to the primary purpose.
3. Use or disclosure is required or authorized by Australian law or a court/tribunal order.
4. A permitted situation exists in relation to E4L’s use or disclosure of the information (such as public interest grounds).
5. E4L reasonably believes that the use or disclosure is necessary for enforcement-related activities by or on behalf of an enforcement body.

3.7. Do You Have to Provide Personal Information?

You are free to refuse providing personal information. However, refusal may result in the requested service not being provided or membership being refused or forfeited.

3.8. Sharing Your Personal Information

E4L may use and disclose personal information to third parties for related purposes, for example:

• Government bodies (ATO, ASIC, Australian Prudential Regulatory Authority, police, courts) as required by law
• Law enforcement agencies and governments for security, customs, or immigration purposes
• Banking service providers
• Rewards partner program providers
• Professional or government organizations
• Contracted service providers, such as:
  • IT service providers
  • Research and development providers
  • Conference organizers
  • Marketing and communications agencies
  • Mailing houses, freight, and courier services
  • Printers and distributors of marketing material
  • Debt collectors and banks
  • Personal trainers
  • External advisors (recruiters, auditors, lawyers)

E4L does not rent, sell, or exchange your personal information to third parties without your prior approval.

3.9. Government Identifiers

E4L does not adopt, use, or disclose government-related identifiers (e.g., Medicare numbers, driver’s license numbers) as its own identifier for you unless:

• Required/authorized by law or court/tribunal order
• Reasonably necessary to verify your identity
• Reasonably necessary to fulfill E4L’s obligations
• E4L reasonably believes it is necessary for enforcement-related activities

3.10. Cookies

To improve services, E4L may collect de-identified information from website users. Such data includes:

• IP address and/or domain name
• Operating system (browser type and platform)
• Date, time, and length of visit
• Resources accessed or downloaded

This information is used for customization, analysis, quality control, and administration. It is not used to identify individuals. You can stop your browser from accepting cookies by changing your browser preferences.

3.11. Links to Other Websites

Links on E4L’s website to third-party websites are for convenience only. E4L is not responsible for the privacy or security practices of those sites. You should review the third party’s privacy policies before providing any personal information.

3.12. Direct Marketing

If E4L holds your personal information, it may use or disclose that information (other than sensitive information) for direct marketing if:

1. E4L collected the information from you,
2. You would reasonably expect such use or disclosure for direct marketing,
3. E4L provided a simple way to opt out of direct marketing, and
4. You have not opted out.

E4L may also use or disclose your information for direct marketing in other circumstances if you have consented or it is impracticable to obtain consent, and E4L always provides a simple opt-out method in each direct marketing communication.

Sensitive information will only be used for direct marketing with your explicit consent.

3.13. How to Opt Out of Direct Marketing

You can always request not to receive direct marketing communications from E4L. If E4L facilitates direct marketing by other organizations, you may also request that E4L not use or disclose your information for that purpose. E4L will honor your request free of charge within a reasonable timeframe.

3.14. Collection Notices

At or before the time E4L collects personal information, or as soon as practical, E4L will usually notify you (for example, in a paper or website form) about:

• The identity of E4L and contact details of the collecting entity
• The purpose of collection
• The consequences if the information is not provided
• Any third parties to whom E4L may disclose the information
• Whether E4L is likely to disclose information to overseas recipients
• The main consequences if E4L does not collect all or some of the personal information

The terms of this Privacy Policy are subject to any more specific provisions in those collection notices or particular service terms.

3.15. Protecting Your Personal Information

E4L stores your information in paper and electronic forms. Reasonable steps are taken to protect it from misuse, interference, loss, unauthorized access, modification, or disclosure, including:

• Secure, password-protected databases
• Staff confidentiality requirements
• Security firewalls for system access
• Secure servers with limited access
• Document storage security
• Granting access only to verified individuals
• Building access controls
• Restricting provision of personal information to third parties with necessary guarantees
• Training staff on proper handling of personal information

Despite these measures, E4L cannot guarantee that personal information will be completely protected against unauthorized access or misuse; E4L does not accept liability for the improper (“buy nexium thailand”) actions of unauthorized third parties.

E4L will retain your personal information only as long as necessary to fulfill obligations to you, protect its legal interests, or as required by law. Once no longer needed, E4L will take reasonable steps to destroy or de-identify your information.

3.16. Disclosing Your Personal Information Overseas

E4L (and E4L group entities) may disclose your personal information to third party service providers operating outside Australia. E4L may also store your personal information on servers based overseas or in “cloud” storage.

Before disclosing personal information overseas, E4L will take reasonable steps to ensure that the recipient:

• Does not breach the Australian Privacy Principles in relation to your information, or
• Is subject to a law or binding scheme that is substantially similar to the Australian Privacy Principles.

E4L may disclose personal information to E4L entities or third parties in jurisdictions including Australia, New Zealand, the United States of America, and the Netherlands—each recognized by the European Commission as providing adequate data protection.

When you provide personal information under documents referencing this Privacy Policy, you acknowledge and consent to potential overseas disclosure. You also understand that:

• E4L will not be required to take steps to ensure the overseas recipient complies with the APPs.
• If the overseas recipient breaches the APPs, E4L will not be held liable and you may not be able to seek redress.
• The overseas recipient may not be subject to any privacy law or principles similar to the APPs.
• You may be unable to seek redress overseas.
• The overseas recipient may be subject to foreign laws that compel disclosure of personal information.

You can withdraw this consent at any time, and E4L will not rely on it for future dealings with your personal information.

3.17. Anonymity

Where lawful and practicable, you can deal with E4L anonymously or by using a pseudonym. However, for many of E4L’s services—such as membership or franchise applications—it will be impracticable or unlawful (identification required) to proceed without providing personal information.

3.18. Accessing Your Personal Information

You have the right to request access to records containing your personal information. To do so, please contact the Privacy Officer (details below). E4L will typically respond within a reasonable period.

If E4L refuses your request, you will receive written notice stating the reasons and how to complain. Reasons for refusal may include:

• Serious threat to life, health, or safety
• Unreasonable impact on others’ privacy
• Frivolous or vexatious requests
• Legal proceedings or prejudice to negotiations
• Unlawfulness or court/tribunal order
• Prejudice to enforcement-related activities
• Commercially sensitive decision processes

You may be required to provide proof of identity (e.g., driver’s license, passport) before E4L grants access.

3.19. Keeping Your Personal Information Accurate

E4L relies on the accuracy of the information you provide. If any details are inaccurate or incomplete, the services or information provided could be affected. Please notify the Privacy Officer if there are errors or if your information changes. E4L will correct or update your information free of charge within a reasonable period.

If E4L refuses to correct your personal information, you can request that E4L associates your personal information with a statement that the information is inaccurate, out of date, incomplete, irrelevant, or misleading. E4L will take reasonable steps to make this statement visible to those who use your information.

Upon correction, if E4L has disclosed your personal information to a third party and you request notification, E4L will inform that third party unless it is impracticable or unlawful to do so.

3.20. Dealing with SPAM and Do Not Call Registers

E4L will not send you commercial electronic messages unless permitted by the Spam Act (e.g., you have given inferred or express consent). Every commercial electronic message will identify E4L as the sender, include E4L’s contact details, and provide an unsubscribe facility.

E4L will not call any number listed on the Do Not Call Register unless permitted by the Do Not Call Register Act. If you do not want E4L to call you, please contact the Privacy Officer.

3.21. Resolving Your Privacy Concerns

If you have any issues or concerns regarding E4L’s collection or management of your personal information, please contact E4L’s Privacy Officer (see contact details below).

If your concerns are not resolved, you may contact the Office of the Australian Information Commissioner:

• Website: www.oaic.gov.au
• Phone: 1300 363 992

3.22. Changes to This Privacy Policy

E4L may review and update this Privacy Policy from time to time in accordance with new laws or changes to its operations. Changes will not affect prior uses of previously provided information. The most current version is available at www.elements4life.com.au. A printed copy is available free of charge upon request to the Privacy Officer.

3.23. E4L Privacy Officer

For any privacy-related queries or requests:

Email: erin@elements4life.com.au
Post: PO Box 3114, Belconnen BC ACT 2617

4. Privacy Collection Notice

Elements4Life (E4L) ABN 68 1195 2794 7, its related entities, and E4L-franchised Clubs (collectively, Elements4Life) issue this Collection Notice in accordance with the Australian Privacy Principles (APP) contained in the Privacy Act 1988 (Cth).

4.1. E4L Privacy Policy

A complete summary of E4L’s policies relating to the privacy of your personal information is available online at www.elements4life.com.au (see Privacy Policy). The Privacy Policy details:

• How to access and correct your information
• How to complain about privacy breaches and how E4L will address such complaints

A printed copy of the Privacy Policy can be requested free of charge via E4L’s Privacy Officer (contact details in Section 3.23 above).

4.2. E4L Contact Details

For any questions or concerns about E4L’s privacy practices, please contact our Privacy Officer:

• Email: erin@elements4life.com.au
• Post: PO Box 3114, Belconnen BC 2617

4.3. Collection from Third Parties

E4L may collect personal information from sources other than you, including:

• Personal trainers
• Market researchers & direct marketing providers
• Parents or guardians of underage members
• Current members (refer a friend)
• ATO & ASIC
• Public sources (directories, membership lists, professional and trade associations, ASIC, bankruptcy or court registry searches)

4.4. Collection Required/Authorized by Law or Court/Tribunal Order?

No. E4L’s collection of your personal information is not specifically required or authorized by law or by court/tribunal order.

4.5. Purpose of Collection

E4L’s primary purpose in collecting personal information is to provide services and benefits to members and to maintain and grow E4L’s membership. E4L may use your personal information for:

• Processing and managing membership & franchisee applications
• Facilitating gym access for members & casual members
• Marketing activities, research & special offers
• Identifying users of E4L’s services
• Communicating with members, franchisees & website visitors
• Profiling members & their interests
• Operating E4L’s business
• Transferring memberships between clubs

4.6. Consequences of Not Providing Personal Information

Refusing to provide requested personal information may lead to inability to receive certain services, or it may result in membership refusal or forfeiture.

4.7. Sharing Your Personal Information

E4L may disclose personal information to third parties for related purposes, including:

• Government bodies (ATO, ASIC, APRA, police, courts)
• Law enforcement agencies for security, customs, or immigration
• Banking service providers
• Rewards partner program providers
• Professional or government organizations
• Contracted service providers such as:
  • IT service providers
  • Research & development providers
  • Conference organizers
  • Marketing & communication agencies
  • Mailing houses, freight, courier services
  • Printers & distributors of marketing materials
  • Debt collectors & banks
  • Personal trainers
  • External advisers (recruiters, auditors, lawyers)

E4L does not rent, sell, or exchange your personal information to third parties without your prior approval.

4.8. Overseas Disclosures

E4L or E4L group entities may disclose your personal information to third-party service providers outside Australia, or store it on servers based overseas (including “cloud” storage). E4L will take reasonable steps to ensure that the overseas recipient:

• Does not breach the Australian Privacy Principles, or
• Is subject to a law or binding scheme ensuring similar protection to the APPs.

E4L may disclose personal information to other E4L entities in jurisdictions such as Australia, New Zealand, the United States of America, and the Netherlands—recognized by the European Commission as providing adequate data protection.

When you provide personal information under a document referencing this Collection Notice, you consent to possible disclosure outside Australia. You acknowledge:

• E4L need not ensure the overseas recipient complies with the APPs.
• If the overseas recipient breaches the APPs, you may not have redress under the Act.
• The overseas recipient may not be subject to privacy laws similar to Australia’s.
• You may have no redress overseas.
• Foreign laws may compel the overseas recipient to disclose your personal information.

If you withdraw consent, E4L will not rely on it for future dealings with your personal information.

END OF PRIVACY POLICY AND COLLECTION NOTICE

E4L AI Voice Assistant Privacy Policy

Last updated: 27 April 2025

Important: This Privacy Policy is dedicated to the personal information we collect through our in‑person service desks and our AI Voice Assistant channels (phone, SMS, email, and web‑chat) only. For broader website and membership privacy matters, please refer to the Elements4Life Master Privacy Policy.

1  Purpose

432 Lifestyles Pty Ltd (trading as Elements4Life, E4L, we, our, us) operates an AI Voice Assistant (the E4L Assistant) that provides 24/7 sales, support, lead nurturing, and secure payment facilitation. Protecting your privacy when you interact in person or with the E4L Assistant by phone, SMS, email, or web‑chat is critical to us.
This policy explains what personal information we collect, how we use it, how we protect it, and your rights—consistent with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), the Spam Act 2003, the Do Not Call Register Act 2006, and relevant payment‑card and consumer laws.

2  Scope

This policy covers personal information gathered when:

• you speak with our staff in person at an Elements4Life facility; or
• you call, receive a call from, text, email, or chat with the E4L Assistant.

It applies to members, prospects, website visitors, suppliers, contractors, and anyone whose data is captured or processed by the E4L Assistant.

3  Key Definitions

4  What We Collect

Depending on your interaction we may collect:

1. Identity & Contact – your full name, preferred name, date of birth, postal/email addresses, phone numbers.
2. Voice & Interaction Data – audio recordings, STT transcripts, call summaries, voicemail, chat logs, SMS/email threads.
3. Membership & Sales – membership IDs, purchase history, booking details, preferences, lead‑source tags.
4. Payment & Transaction – tokenised card data, Stripe customer IDs, billing address, transaction timestamps.
5. Health & Fitness (Sensitive) – voluntarily disclosed injuries, medical conditions, training goals.
6. Technical Metadata – IP address, device type, browser user agent, cookie/session identifiers.

We deliberately minimise collection of sensitive information; health data is only requested when necessary to deliver safe training services.

5  How We Collect Information

6  Legal Bases for Processing

We rely on one or more of:

• Consent – verbal or explicit when you proceed after the call‑recording notice, click opt‑in boxes, or dictate card details.
• Contractual necessity – delivering requested services, processing memberships, or completing sales.
• Legitimate interests – fraud prevention, service analytics, staff/AI training, improving member experience.
• Legal obligations – tax, consumer, and notifiable data‑breach compliance.

You may withdraw consent for marketing or call recording at any time, though some functions (e.g. payments) require minimum data.

7  Purposes of Use

We use your information to:

1. Provide & improve services – answer questions, book tours, tailor program recommendations.
2. Lead nurturing – send follow‑up SMS/email, schedule calls, remind you of offers.
3. Sales & payments – generate secure payment links, take card details via encrypted phone line, issue receipts.
4. Security & fraud prevention – authenticate callers, detect anomalies.
5. Training the Assistant – refine speech‑recognition and natural‑language models (using de‑identified data when practicable).
6. Regulatory compliance – maintain transaction records, log marketing consent, and meet OAIC guidance.

We never sell your personal information.

8  Automated Decision‑Making & Human Oversight

• The Assistant triages enquiries and may make automated recommendations (e.g. suggesting a 6‑week beginner program based on your stated goals).
• High‑impact decisions (e.g. denying service due to health risk, large payment reversals) are escalated to trained human staff.
• You can request manual review of any decision at any time (Section 14).

9  Disclosures & Third‑Party Access

We may disclose data to:

• internal authorised staff and franchisees;
• Stripe for payment processing;
• cloud speech‑to‑text vendors (ISO 27001 data centres) located in Australia, the US, or Singapore;
• CRM/email/SMS providers (Gymmaster, Twilio, Pipedrive);
• professional advisers (legal, accounting, insurance);
• law enforcement or regulators when legally compelled.

All suppliers sign agreements requiring compliance with the APPs and the PCIDSS where applicable.

10  Overseas Transfers

When overseas disclosure is necessary (e.g. cloud STT), we:

1. perform security due‑diligence;
2. ensure equivalent privacy safeguards via contractual clauses;
3. keep a public register of current overseas vendors on request.

11  Data Security

• Encryption – TLS 1.2+ for data in transit; AES‑256 or better at rest.
• PCI DSS Level 1 – all card data handled exclusively by Stripe.
• Access controls – role‑based permissions, MFA, audit logging.
• Call‑record redaction – card numbers are masked and excluded from long‑term storage; audio paused or bleeped during entry when technically feasible.
• Regular testing – intrusion detection, quarterly vulnerability scans.
• Staff & AI training – mandatory privacy and security modules.

12  Retention & Destruction

13  Marketing, Consent & Opt‑Out

• The Assistant will ask for permission before sending promotional SMS or email.
• Every SMS includes STOP instructions; every email has an unsubscribe link.
• You can opt out any time via the member portal, Assistant request, or email privacy@elements4life.com.au.

14  Your Rights – Access, Correction & Review

• Request access to or correction of your personal information by writing to our Privacy Officer (Section 16).
• Ask for human review of any AI‑driven outcome.
• Expect a response within 30 days. Reasonable ID verification applies.

15  Notifiable Data Breaches

We maintain a Data‑Breach Response Plan. If a breach is likely to cause serious harm, we will:

1. rapidly contain it;
2. inform affected individuals and the OAIC; and
3. implement remedial actions.

16  Contact & Complaints

Privacy Officer
Elements4Life – 432 Lifestyles Pty Ltd

We will acknowledge complaints within 7 days and strive to resolve them within 30 days. If unresolved, you may contact the Office of the Australian Information Commissioner (www.oaic.gov.au).

17  Changes to This Policy

We may update this AI Voice Assistant Privacy Policy when our technology or legal obligations change. The current version is always linked at the start of each Assistant interaction and on our website.

18  Acceptance

By continuing a conversation with our staff or the E4L Assistant after being notified of this policy, you acknowledge that you have read and understood it and consent to the collection, use, and disclosure of your information as described.