Last updated: April 2025

RM Therapy Pty Ltd (ACN 663 951 808) (“we”, “our”, “us”) is committed to protecting your privacy and ensuring that your Personal Information is handled in compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

This Privacy Policy outlines how we collect, store, use, and disclose your Personal Information when you engage with us. It applies to all individuals who interact with us, including clients, prospective clients, referrers, and other individuals whose Personal Information we may collect in the course of our operations. Please read it carefully.

By providing Personal Information to us, whether by submitting information through our website, www.rmtherapy.org (Our Website), by phone, by email, in person or otherwise, you expressly consent to the collection, storage, use, and disclosure of your Personal Information in accordance with this Privacy Policy.

If you are a third party providing Personal Information about somebody else, you represent and warrant that you have such person’s consent to provide that information to us.

While providing your Personal Information to us is optional, choosing not to do so may affect our ability to engage with you and provide our services to you.   

If you are accessing and using Our Website, this Privacy Policy should be read together with the Terms and Conditions of use of our website, which can be found at www.rmtherapy.org/terms-and-conditions.

1. Definitions

• Personal Information: 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 is recorded in a material form or not. Personal Information includes Sensitive Information and Health Information.
• Sensitive Information: A subcategory of Personal Information that includes Health Information, genetic information, racial or ethnic origin, sexual orientation, membership in political or trade unions, and other sensitive data, as defined in the Privacy Act 1988 (Cth).
• Health Information: Personal Information that relates to the health, illness, injury, or disability of an individual, or an individual’s health services or history, as defined in the Privacy Act 1988 (Cth).
• Our Website: www.rmtherapy.org
• APPs: Australian Privacy Principles

2. What types of Personal Information we collect

The types of Personal Information we may collect will depend on how you engage with us, including but not limited to how you access and use Our Website.

Examples include but are not limited to:

• Identity information such as your name, age, photographic identification, marital status, pronouns, and gender.
• Contact information such as your telephone number, residential address, and email address.
• Technical and usage information such as your IP address, device and network information, and access and use of Our Website.
• Interaction information such as information provided when you participate in any interactive features on Our Website, such as surveys.
• Marketing and communication information such as your preferences for receiving marketing communications from us or third parties.
• Sensitive Information.
• Health Information.
• Any other Personal Information you choose to provide to us.

3. How we collect your Personal Information

We may collect your Personal Information in several ways, including but not limited to:

• Directly from you, when you:
• Make an enquiry or contact us;
• Complete an intake form, referral form, consent form, or any other online or paper-based form;
• Book, attend, or cancel an appointment;
• Provide information to us during a consultation, session, or any other interaction;
• Subscribe to newsletters, updates, or marketing communications;
• Respond to surveys, questionnaires, or feedback requests; and
• Access or use Our Website or other digital tools and services.
• From third parties, such as our third-party service providers, healthcare providers, support coordinators, family members, or legal guardians who provide information on your behalf (with your consent or as otherwise permitted by law).
• Through third-party systems and integrations, including payment processors, practice management platforms, and other service providers we use to facilitate our operations.
• Automatically, through cookies, log files, analytics, and tracking technologies when you interact with Our Website or digital services (for example, IP address, browser type, device information, and usage data).
• In the course of other engagements with us, including in a professional, administrative, or support capacity.

If we receive unsolicited information (i.e., information provided to us without our request), we will only retain, use, or disclose that information if we would have been able to do so under the Privacy Act 1988 (Cth). If we would not have been able to do so, we will take appropriate steps to destroy, permanently delete, or de-identify the information.

4. Cookies

We may use cookies on Our Website to store preferences and recognise you on return visits. Cookies do not collect personally identifiable information unless linked to data you provide. They also enable third-party ads through retargeting campaigns.

You can block cookies through your browser settings, but doing so may affect your ability to use certain features of Our Website.

5. Why we collect and use your Personal Information

In general, we will only use and disclose your Personal Information in ways that you would expect.

We may use and collect your Personal Information for the following purposes:

• Any purposes you have given consent for.
• The main purpose for which it was originally collected.
• Secondary purposes that are directly related to the primary purpose, where you would reasonably expect the information to be used or disclosed for such purposes.  
• To contact emergency services or reach out to your family, partner, or support person if we reasonably believe there is a serious risk to your life, health, or safety or that of another person, and it is not feasible to obtain your consent.
• As required or permitted by law.

In line with the above, this may include using and collecting your Personal Information to, for example:

•      To communicate with you, including responding to inquiries, requests, and concerns.

•      To provide our services to you.

•      To process payments and handle financial transactions.

•      To send marketing communications, newsletters, or promotional materials.

•      To improve and personalise your experience on Our Website.

•      To comply with our legal obligations.

6. How we store and secure your Personal Information

We have implemented reasonable measures to store and secure Personal Information from mishandling.

Personal Information you provide to us may be collected and stored in Splose, which is a specialised practice management software used to manage appointments, client records, clinical documentation, invoicing, case notes, and more. Personal Information collected and stored in Splose is handled in accordance with the privacy policy of Splose Pty Ltd (ACN 614 286 636), which is available at  www.splose.com/privacy-policy.

Where the Personal Information is no longer required, subject to the relevant laws and regulations, we will take reasonable steps to ensure that the Personal Information is de-identified or destroyed.

7. Disclosure of Personal Information

We may disclose your Personal Information to:

• Our employees, contractors, and affiliated entities.
• Our third-party service providers.
• Professional advisors.
• Any party to whom our business or assets (or any part of them) may be transferred, in good faith.
• Third-party disability provider partners that you authorise us to contact on your behalf.
• Courts, tribunals, regulatory bodies, and law enforcement officers, as required or authorised by law, in connection with legal proceedings or to establish, exercise, or defend our legal rights.
• Third parties involved in data collection and processing, such as analytics providers and cookies.
• Any other third parties, as required or permitted by law.

Additionally, we may disclose your Personal Information, excluding your Sensitive Information, to:

• Marketing and advertising service providers.
• Payment system operators or processors.
• Our current or potential agents or business partner.
• Courts, tribunals, and regulatory authorities, if you fail to pay for goods or services we have provided to you.

8. Third-party service providers

We may disclose your Personal Information to third-party service providers who assist us in delivering our services, supporting our operations, and improving our systems and processes. This may include disclosures to:

·         Facilitate the provision of our services to you.

·         Conduct quality assurance activities and service reviews.

·         Create and manage user profiles or client accounts.

·         Provide technical support, IT infrastructure, or cybersecurity services.

Examples of third-party service providers we may engage include those that:

·         Verify or validate identity and other information, such as identity checks, police checks, or other screening processes.

·         Monitor and moderate use of Our Website to help prevent misuse or breaches of our terms of use.

·         Process payments or assist with financial administration, including invoicing and reconciliation.

·         We may also share your Personal Information with our professional advisers and service providers who support us in areas such as legal, administrative, accounting, insurance, auditing, business consulting, data analytics, marketing, research, and technology services.

·         In some cases, we may also disclose Personal Information to:

o    External review platforms to facilitate the collection of feedback or reviews about our services; and

o    Government agencies or funding bodies, where necessary to verify funding arrangements, such as for clients accessing services through government-supported programs.

Third-party service providers handle your Personal Information in accordance with their own privacy policies, which may differ from ours.

The third-party services we may use include but are not limited to:

·      Splose (practice management software), provided by a third party to manage client records, appointments, and communications. Its privacy policy is available at www.splose.com/privacy-policy.

• Stripe (payment processing service), used to facilitate secure online transactions. Its privacy policy is available at www.stripe.com/au/privacy.
• Mailchimp (email marketing service), used to manage and distribute marketing communications. Its privacy policy is available at www.mailchimp.com/legal/privacy/.
• Google services, including Google Analytics and Invisible reCAPTCHA, used for analytics, advertising, and security purposes. Its privacy policy is available at www.google.com/intl/en/policies/privacy.

We encourage you to review the privacy policies above to understand how they may collect, use, store, and disclose your Personal Information.

9. Overseas disclosure

We may transfer or otherwise disclose your Personal Information to third parties which provide information technology and other services to us. Those third parties may be located outside Australia or may store, transfer or access your Personal Information outside Australia, for example, in the United States of America.

Overseas recipients of your Personal Information may not be bound by Australian privacy laws or equivalent protections. We will take reasonable steps to ensure that overseas recipients of your Personal Information do not breach the Australian Privacy Principles in relation to that information.

By providing your Personal Information to us, you expressly consent to the transfer of that information outside Australia.

10. Direct marketing

We may use Personal Information collected from or about you for the purpose of sending direct marketing materials to you.

By using Our Website, you consent to receiving direct marketing materials from us. You may opt-out at any time by following the unsubscribe link in our emails or contacting us at admin@rmtherapy.org.

11. Security of your Personal Information

The security of your Personal Information is important to us. However, no method of transmission over the internet or method of electronic storage is 100% secure. While we endeavour to use commercially reasonable measures to help protect your Personal Information from unauthorised access, use and disclosure, we cannot guarantee its absolute security. Take note that the transmission and exchange of Personal Information over the internet is done at your own risk.

12. Access and correction

You have the right to request access to and correction of the Personal Information we hold about you. To make a request, please contact us at admin@rmtherapy.org.

In certain circumstances, we may be legally permitted to deny access or decline a correction request. If we are unable to provide access or make a correction, we will inform you as soon as reasonably possible, explain the reasons for our decision, and outline any available avenues for lodging a complaint.

We may charge an administrative fee to process your request for access to your Personal Information, for example, to cover the cost of retrieving the Personal Information.

13. Complaints

If you think your Personal Information has been mishandled, please contact us at admin@rmtherapy.org and provide details of your complaint, along with any supporting evidence and information.

We will investigate and respond to all complaints within a reasonable time. We may seek further information from you in order to provide you with a full response.

If you are not satisfied with the outcome of our investigation, you may raise your concerns with us, or you may lodge a complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au).

14. Changes to this Privacy Policy

We may update or modify this Privacy Policy at our discretion and at any time by publishing the revised version on this Website. By continuing to use this Website after it has been updated, you accept the revised Privacy Policy.

We encourage you to check this Website regularly to stay informed of any changes.

15. Contact Information

If you have any questions about this Privacy Policy or how we handle your Personal Information, please contact us at admin@rmtherapy.org.