Privacy Policy

Date: 01 August 2025

1. About I Choose Well and the I Choose Well Platform

I Choose Well 73 683 484 228 (I Choose Well, us, we or our) operates a digital platform (I Choose Well platform).

2. About this Privacy Policy

2.1 Introduction

I Choose Well is committed to complying with the Privacy Act and respecting the privacy of the personal information (as defined in the Privacy Act 1988 (Cth)) of persons with whom we interact.

This Privacy Policy sets how I Choose Well collects, stores, uses, discloses and otherwise handles personal information and the rights a person (you or your) has in respect of personal information we hold about you that we collect via our website or when we otherwise engage with you (other than when we engage with you via the I Choose Well platform in which case the I Choose Well Platform Privacy Policy applies).

2.2 To Whom and When this Policy Applies

This Privacy Policy applies to:

• persons who engage with I Choose Well via the I Choose Well Website or by other means of communication such as email, mail and telephone;

• our suppliers, organisations I Choose Well supports via donations and sponsorship and other business partners (supplier); and

• our potential employees.

This Privacy Policy does not apply to the I Choose Well Platform or to I Choose Well’s employees when they are engaging with us in their capacity as an employee.

2.3 Changes to Privacy Policy and Continued Engagement With Us

This Privacy Policy came into effect on the date specified above. We may need to update it from time to time. Updates of our Privacy Policy will be posted on the I Choose Well Website.

By continuing to use I Choose Well’s website, the I Choose Well platform or otherwise continuing to deal with I Choose Well, you accept this Privacy Policy as it applies from time to time.

2.4 Non-Acceptance of Privacy Policy

If you do not wish to submit personal information, you may not be able to access or use sections of the I Choose Well Website or receive services or information that require your personal information.

3 The Personal Information We Collect

3.1 Introduction

I Choose Well needs to collect personal information to conduct our business including providing services to our customers and acquiring services from our suppliers and to engage with visitors to the I Choose Well Website and others who communicate with us.

I Choose Well does not expect to collect any sensitive information about any persons via the engagements described in this Privacy Policy.

3.2 I Choose Well Website User or Other Engagement with I Choose Well

If you fall within this category, the personal information we collect will be collected from you directly. The types of personal information we may collect will depend upon the reason for which you contacted or engaged with us but will include:

• your name;

• your employer or organisation you represent;

• your position within your organisation;

• your email address;

• your preferred physical contact address such as home address or business address;

• your telephone number;

• the nature of your request or contact; and

• if you contact us by completing a web form, any information included by you in that web form.

3.3 Suppliers

If you fall in this category, the majority of the information we collect about you (and each person in a company, partnership, other business organisations) with whom we deal) will be collected directly from you. The information we collect includes:

• your name;

• the name of the organisation you represent;

• your position within your organisation

• your business email address;

• your business address other address;

• your business telephone number;

• bank account details of your business;

• information about your qualifications relevant to the services or goods your organisation supplies to I Choose Well; and

• references relating to you and your organisation.

We may also collect information about you indirectly including from a credit checking agency, organisations that provide information about businesses, government agencies such as Australian Securities and Investment Commission and exiting or previous customers and business partners.

3.4 Potential Employees

The majority of the information we collect about potential employees will be collected directly from the potential employee or from a recruitment agency or labour hirer provider with whom you are registered. The types of personal information we might collect about you will ultimately differ based on the circumstances, but might include:

• your name;

• your email address;

• your preferred physical contact address such as home address or business address;

• your telephone number;

• your professional qualifications or skills;

• details of your employment history (including details of any personal or professional references provided to us by third parties); and

• references.

3.5 Social Media

I Choose Well uses social networking services such as Facebook, LinkedIn, and X (formerly Twitter) to communicate with the public about its activities. I Choose Well may collect your personal information when you communicate with us by using these social networking services, and the social networking services will also handle your personal information for their own activities. These social networking sites have their own privacy policies.

3.6 Cookies, Tracking and Measurement Software

I Choose Well uses cookies and similar technologies (such as Google Analytics, web beacons and proprietary measurement software) on the I Choose Well Website to analyse trends, administer our services, diagnose problems, improve the quality of our products and services, track users' movements around the I Choose Well Website and to gather demographic information about our user base as a whole.

A cookie is a small text file that the I Choose Well Website may place on your device to store information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of the I Choose Well Website for any of your future visits to the I Choose Well Website. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the I Choose Well Website.

You may refuse to use cookies, web beacons or some of the proprietary measurement software features by selecting the appropriate settings on your browser or the settings section of your mobile or tablet device. However, please note that if you do this, you may not be able to use the full functionality of the I Choose Well Website.

4. How Personal Information Is Used and Disclosed

4.1 Primary Purposes of Use of Confidential Information

In general terms, the primary purposes for which we collect personal information are to:

• enable and improve the functionality of the I Choose Well Website;

• communicate with persons who contact us via the I Choose Well Website or other means;

• engage with our suppliers to undertake our business; and

• engage with potential employees.

The primary purpose will generally be determined by reference to the circumstances in which the personal information was collected or submitted.

We will only use and disclose your personal information for the purposes for which it was collected or for any secondary purposes which you might reasonably expect and which are related to the primary purpose.

I Choose Well may disclose personal information to its related bodies corporate located in Australia and will require each related body corporate to comply with this Privacy Policy in respect of the personal information disclosed to it.

4.2 I Choose Well Website Users and Other Forms of Contact from Individuals Who Do Not Represent Suppliers, Suppliers and Potential Employees

If you fall into this category, the primary purposes for which I Choose Well uses the personal information we hold about you include:

• to manage our relationship with you;

• to deal with a specific request you have made or to resolve an issue you have raised;

• if you have signed up to receive a newsletter, regular information or marketing material about I Choose Well and its products and services or the I Choose Well Website, to send newsletters, information or marketing materials;

• if you have agreed to provide feedback about I Choose Well, its products and services or the I Choose Well Website, to request your opinion and feedback;

• to improve the I Choose Well Website, including customising and improving your online experience with us;

• to ensure the proper functioning of our businesses including administrative, operational and financial purposes;

• any purposes permitted or required under applicable laws;

• any other use to which you have expressly or impliedly consented; and

• purposes necessary or incidental to the provision of the preceding purposes.

4.3 Representatives of Suppliers

If you fall into this category, the primary purposes for which I Choose Well uses the personal information we hold about you include:

• to manage all aspects of our relationship with the organisation you represent including administrative, operational and financial matters;

• to deal with a specific request you have made or to resolve an issue you have raised;

• if you have signed up to receive a newsletter or regular information about I Choose Well or the I Choose Well Website, to send that newsletter or information;

• to send you marketing and promotional material that we believe you may be interested in and otherwise communicating with you about our products and services that may be of interest or relevant to the organisation you represent;

• if you have agreed to provide feedback about I Choose Well, its products and services or the I Choose Well Website, to request your opinion and feedback including to assist us with our marketing, planning, product development and research requirements;

• to improve the I Choose Well Website, including customising and improving your online experience with us;

• to ensure the proper functioning of our business including administrative, operational and financial purposes;

• any purposes permitted or required under applicable laws;

• any other use to which you have expressly or impliedly consented; and

• purposes necessary or incidental to the provision of the preceding purposes.

4.4 Potential Employees

If you fall into this category, the primary purposes for which I Choose Well uses the personal information we hold about you are to assess whether you are a suitable candidate for a position with I Choose Well and to make any resultant offer following our assessment.

4.5 Social Media

I Choose Well may repost your posts including any personal information included in or attached to your post if it considers it appropriate to do so.

4.6 Disclosure Generally

In addition to any specific any rights of disclosure specified above, I Choose Well may also disclose the personal information we hold about you as follows:

• Related entities and networks – We may disclose personal information to our related bodies corporate and between our multiple online networks to ensure that the networks function as we require or intend. Our related bodies corporate and online networks will comply with this Privacy Policy.

• Service providers – We may make your information available to certain third party service providers who assist us, or act on our behalf, to provide, develop, deliver, administer, manage, improve, promote, market and protect the I Choose Well Website, our IT systems and other business functions subject to confidentiality obligations and restrictions on use we consider appropriate (such as requiring service providers to comply with this Policy). This might include (without limitation) providers of cloud services, data storage providers, website hosting services, channels, direct marketing services, market or consumer research services, data connectivity platforms, customer support contractors, human resources, IT consultants and independent contractors who provide us with services or who assist us with our corporate or business functions.

• Third party data analytics and data marching companies (such as Google) – We use third party analytics companies to collect data from the I Choose Well Website about traffic on the I Choose Well Website via cookies and identifiers subject to confidentiality obligations and restrictions on use we consider appropriate (such as requiring service providers to comply with this Policy). These companies analyse and report about the data they have collected, eg, a report may summarise how many people have viewed a certain webpage. These companies may combine the data they collect from the I Choose Well Website with data obtained from other companies to produce reports relevant to our businesses. These companies may also share the data they collect with other data analytics companies.

• Legal requirements and proceedings – We may disclose information to law enforcement authorities, national security agencies, statutory dispute resolution bodies, other government and regulatory authorities and other organisations as required or authorised by law, or in accordance with any industry code or standards registered under an applicable law. We may also disclose information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraudulent or illegal activity.

• Business partners – We may share your information with our third party business partners. These may include (without limitation) our licensees; partners who collect money on our behalf; partners who jointly provide goods or services with us; or partners who provide a service or product that operates in conjunction with (or interacts with) the I Choose Well Website or our goods and services. The third party’s use of your information will be governed by their own privacy policy. You should consult each of their privacy policies to determine your rights with respect to their use and treatment of your information. Where you have consented, we may also share your information with our business partners so they can send you marketing communications.

• Professional advisers – We may also share your information for certain purposes with our professional advisors and representatives (eg, lawyers, accountants, auditors, corporate consultants or business analysts) to assist us with our corporate or business functions and to develop our business strategies.

• Protection of the I Choose Well Website and our goods and services – We may disclose information to protect and defend the rights, interests and safety of the I Choose Well Website and our goods and services, our employees, contractors and agents; to protect the security and safety of our users of the I Choose Well Website, including when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss.

• Business transfers – We may disclose information in the event of a proposed or completed sale or transfer of all or a portion of our business or assets (including in the event of a reorganisation, dissolution or liquidation). We will make reasonable efforts to notify you by posting a notice on the I Choose Well Website and sending you an email if we have your email address.

4.7 De-identified Information

I Choose Well may use de-identified personal information as we consider necessary or appropriate including for the following purposes:

• recording and assessment of internet usage across the I Choose Well Website;

• commercial and academic research;

• data analytics (including by monitoring aggregate metrics such as total number of visitors, traffic, and demographic patterns);

• statistical purposes;

• security (including preventing various types of data processing abuse attempts and block suspicious behaviour);

• creating, training, implementing machine learning model and artificial intelligence;

• quality assurance;

• policy generation; and

• creating new services or products.

I Choose Well may disclose de-identified personal information to third parties providers who provide services to I Choose Well in respect of or relating to the purposes specified above including online security monitoring and management and big data analytics and research.

5. Security of Personal Information

I Choose Well will take all reasonable precautions to protect your personal information from unauthorised access or disclosure, or misuse or loss. Some of these precautions include:

• appropriately securing our physical facilities, systems and electronic networks with at least standard industry protections;

• undergoing regular external security assessments and auditing such independent penetration testing;

• using standard industry encryption methods when storing and transferring personal information;

• implementing monitoring and access controls that regulate who can access particular information;

• requiring our team and service providers to comply with confidentiality obligations before they access personal information;

• conducting background checks on our staff before they commence work for us;

• ensuring all our staff use multi-factor authentication.

6. Location of Personal Information

All personal information held by I Choose Well will be stored in stored in Australia.

7. Retention of Personal Information

I Choose Well will only retain personal information for as long as necessary for the purposes specified in this Privacy Policy unless a longer retention period is required or permitted under applicable legislation.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we handle your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

I Choose Well may retain de-identified personal information for as long as it considers necessary or appropriate.

8. Opting Out

You may opt out of I Choose Well collecting your personal information. Your decision to opt out may mean that I Choose Well cannot:

• provide some or all of our services to you or the organisation you represent; or

• in the case of potential employees, assess whether I Choose Well may wish to employ you or make an employment offer.

9. Withdrawal of Consent

Where we have obtained your consent to handle your personal information, or consent to send you information, you may withdraw your consent at any time and we will cease to carry out the particular activity to which you previously consented unless we consider that there is an alternative reason to justify our continued handling of your personal information for this purpose. In this case, we will inform you if we have an alternate reason to continue to use your personal information.

Your decision to withdraw your consent may mean that I Choose Well cannot:

• provide some or all of our services to you or the organisation you represent; or

• in the case of potential employees, assess whether I Choose Well may wish to employ you or make an employment offer.

10. Accessing, Correcting and Updating Person Information

You have the right to access and request a copy of the personal information I Choose Well holds about you.

In some instances, we may be unable to give you access to the person information you have requested. If this is the case, we will provide you with a written explanation of the reasons for our rejection of your request.

You also have the right to ask that your personal information be corrected or updated.

11. De-identification

You may request that we de-identify the personal information we hold about you. Your decision to require I Choose Well to de-identify your personal information may mean that I Choose Well cannot provide some or all of our services to you.

In some instances, we may be unable to de-identify your person information. If this is the case, we will provide you with a written explanation of the reasons for our rejection of your request.

If you contact us directly to make the request, we will take reasonable steps to:

• correct any errors within 7 days of receipt of a written notice of those errors; or

• provide you with access within 28 days of receipt of a written request.

12. Deletion

You may request that we de-identify the personal information we hold about you or that we delete it. Your decision to require I Choose Well to delete your personal information may mean that I Choose Well cannot provide some or all our services to you.

In some instances, we may be unable to delete your person information. If this is the case, we will provide you with a written explanation of the reasons for our rejection of your request.

13. Making Requests and Processing Requests

If you wish to make a request under sections 8, 9 10, 11 or 12 or contact us about your receipt of unsolicited communications, you may contact us via the contact details specified in section 14.

We will generally comply with the following timelines:

• acknowledging your request – within 2 working days of receipt of a written request;

• accessing personal information – within 14 days of receipt of a written request;

• correcting errors in or updating personal information – within 14 days of receipt of a written request;

• providing a copy of the personal information we hold about you – within 14 days of receipt of a written request;

• providing you with access – within 14 days of receipt of a written request;

• de-identifying personal information – within 14 days of receipt of a written request;

• withdrawal of consent – within 14 days of receipt of a written request;

• deletion of personal information – within 14 days of receipt of a written request; and

• other matters – within 28 days of receipt of a written request.

I Choose Well will notify you if we cannot meet the timings specified above and provide new timing.

There is no fee for submitting a request and we do not intend to charge a fee for dealing with your requests. However, if after undertaking a preliminary review of the personal information we hold about you, we conclude that the volume is extensive, we reserve the right to charge a reasonable fee for undertaking the action you have requested. We will inform you of the proposed fee before undertaking any action other than the preliminary review and will not take any further action until you have paid the fee.

14. Contacting Us and Complaints

If:

• you would like to request access, correction, updating, de-identification or deletion to or of the personal information we hold about you or withdraw your consent to our use of the personal information;

• you have any questions, concerns or feedback about this Privacy Policy, the personal information we collect or how we handle the personal information we hold about you; or you wish to complain about our decision to reject a request you have made for access, correction, updating, de-identification or deletion to or of the personal information we hold about you, please contact the I Choose Well Digital Privacy Officer via the following channels:

Digital Privacy Officer

Website

www.ichoosewell.com; or

Email

dpo@ichoosewell.com; or

Post

Digital Privacy Officer

I Choose Well Pty Ltd
Unit 9, 497 Burke Road
Camberwell VIC 3124
AUSTRALIA

If you are not satisfied with our response to any complaint you have made, you may contact the Office of the Australian Information Commissioner to seek advice or make a complaint via the contact details available on the Commissioner’s website at www.oaic.gov.au.