Version 1
Last updated 21 Dec 2023

This document describes how and why we might collect, store, use, and/or share your information when you use our services.

'We', 'us' and 'our' refer to Rugged and its related entities and businesses. We operate mobile and web-based applications to facilitate improving the health and fitness of our users (Platform).

Our commitment

We understand how important it is to protect your personal information. This document sets out our Privacy Policy commitment in respect of personal information we hold about you and what we do with that information.

We recognise that any personal information we collect about you will only be used for the purposes we have collected it or as allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.

Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in Schedule 1 of the Privacy Act 1988 (Cth) and any other relevant law.

Information we collect

We ask for information so you can use our services, sign in to your account, receive customer support and safety information, and communicate with you about our services, promotions, and activities. We collect the following information when you engage with us.

• Personal information such as name, address, phone number, email, gender, occupation, personal interests and any other information you provide to us.
• Non-personal information including, but not limited to, data relating to your activities on the Platform (including IP addresses) via tracking technologies such as cookies, web beacons and measurement software or data relating to survey responses.
• 3rd party information If you access any of our services through a social network site or login to our Platform using your social network credentials, we will collect limited information provided to us by that social network site, such as user name, site ID, profile photo and email address.

You acknowledge that the personal information you provide us and which we collect from you, is your own information or information which you have been authorised to provide to us.

Why we collect your personal information

We collect personal information largely for the purposes of facilitating your use of the Platform, including verifying your details and providing you with products and services that you have requested. We may also collect your personal information for the purposes of direct marketing and managing our relationship with you. From time to time we may offer you other products and services. Furthermore, we may collect your personal information to improve our level of service, develop our expertise and know-how and for training and quality assurance purposes.

To enable us to maintain a successful business relationship with you, we may disclose your personal information to other organisations that provide products or services used or marketed by us. We may also disclose personal information to any other organisation that may have an interest in you, or in our business.

How do we collect your personal information?

Where reasonable and practical we will collect your personal information directly from you, including when you interact with us over the phone and via email or when you register to use and access the Platform.

We may also collect personal information about you when you log in to use our Platform via your social networking site account, when you contact us or our service providers for any reason or through our related bodies corporate, service providers and third parties so that we may provide a better or more relevant service or product to you.

Sharing personal information

We may share your personal information for the purposes as follows:

• to our service providers, so that they can provide you with products or services on our behalf or products or services that you have requested directly from them, or to help us to provide you with our products or services;
• to anyone who represents you, such as financial consultants, accountants, lawyers and advisers;
• to third parties, where reasonably necessary to allow to use the Platform or where you have requested information, services or products from them;
• to associated businesses that may want to market products to you;
• to companies that provide information and infrastructure systems to us, including third party verification providers;
• organisations that provide products or services used or marketed by us;
• to relevant public, government or regulatory authorities where we believe is necessary to help identify you;
• where necessary for us to bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users or anyone else who could be harmed by such activities;
• to your employer, referees, listed contacts or identity verification services to verify information you have provided;
• where we are otherwise authorised by law to do so.

We may use cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located outside Australia.

We may disclose your personal information to overseas entities that provide support functions to us. You may obtain more information about these entities by contacting us.

We may also disclose your information to overseas recipients for analytical and business purposes. You may obtain more information about these recipients by contacting us.

Data retention

We retain personal data for as long as is necessary for the processing purpose(s) for which the data was collected, and any other permissible, related purpose. When we no longer need the personal information we collect, we either anonymize the information upon your request or securely destroy the information, unless we are legally required to retain it.

Direct marketing

From time to time we may use your personal information to provide you with current information about the Platform, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with whom we are associated.

If you do not wish to receive marketing information, you may at any time decline to receive such information by emailing us on admin@rugged.dev

If the direct marketing is by email you may also use the unsubscribe function. If the direct marketing is by text you may also use the unsubscribe function. We will not charge you for giving effect to your request and will take reasonable steps to meet your request at the earliest possible opportunity.

By using the unsubscribe function in a direct marketing communication you will only unsubscribe from direct marketing from that entity/brand who sent you the communication and method of delivery. Please let us know if you would like to unsubscribe from all direct marketing from us and related entities. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.

Updating your personal information

It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.

If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.

Access and correction to your personal information

We will provide you with access to the personal information we hold about you. You may request access to any of the personal information we hold about you at any time. We may charge a fee for our costs of retrieving and supplying the information to you.

Depending on the type of request that you make we may respond to your request immediately, otherwise we usually respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.

There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious.

An explanation will be provided to you if we deny you access to the personal information we hold about you.

If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the personal information at the time of the request otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days.

We may need to consult with other service providers as part of our investigation.

If we refuse to correct personal information we will provide you with our reasons for not correcting the information.

Business without identifying you

In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information, for example, if you make general inquiries about current promotional offers.

Sensitive information

We will only collect sensitive information about you with your consent. Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health.

How safe and secure is your personal information that we hold?

We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.

Complaints

If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act 1988 (Cth), you may contact our complaints officer by email at admin@rugged.dev.

We will acknowledge your complaint within seven days. We will provide you with a decision on your complaint within 30 days.

If we do not reach agreement on your complaint, you may refer the complaint to the Privacy Commissioner which can be contacted at www.oaic.gov.au by phone on 1300 363 992, by email at enquiries@oaic.gov.au or by post at GPO Box 5218, SYDNEY NSW 2001.

Further information

You may request further information about the way we manage your personal information by contacting us.

Change in our privacy policy

We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and marketplace practices.

As a consequence, we may change this Privacy Policy from time to time or as the need arises and we will publish the updated Privacy Policy here.

You may request this Privacy Policy in an alternative form.