Privacy Policy
Effective Date: 17 January 2025

1. Introduction
Sleaping Giant Pty Ltd T/A Chocolate Box Training ("we," "our," "us") is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information in compliance with the Privacy Act 1988 (Cth), the Privacy and Personal Information Protection Act 1998 (NSW), and applicable international privacy standards.

2. Personal Information We Collect
We collect personal information that is reasonably necessary for our business functions and activities. This may include:

• Contact Details: Name, address, email address, and telephone number.
• Demographic Information: Date of birth, gender, and emergency contact details.
• Health Information: Medical history or conditions relevant to your fitness program.
• Biometric Data: Facial recognition data for members utilizing 24/7 gym access.
  Financial Information: Payment details for membership and services.

3. How We Collect Personal Information
We collect personal information through various means, including:

• Direct Interactions: When you register for membership, complete forms, or communicate with us in person, by phone, or via email.
• Digital Platforms: Through our website, mobile applications, and social media channels.
• CCTV Surveillance: For security purposes within our facilities.
  Facial Recognition Technology: With your explicit consent, to facilitate 24/7 gym access.
• Call Recordings: Some inbound and outbound phone calls are recorded for quality and training purposes. These call recordings are listened to by the senior management team only, and not shared further. If you do not wish to have your call recorded and kept, let us know.

4. Purpose of Collecting Personal Information
We collect and use your personal information to:

• Provide Services: Deliver fitness programs, classes, and related services.
  Manage Memberships: Administer your membership, including billing and communication.
• Ensure Safety: Monitor health information to tailor programs safely and respond to emergencies.
  Enhance Security: Utilize facial recognition and CCTV for secure facility access and safety.
• Marketing: Inform you about promotions, events, and updates (with your consent).

5. Disclosure of Personal Information
We do not sell your personal information. We may disclose it to:

• Service Providers: Third-party vendors who assist in operations (e.g., payment processors) under strict confidentiality agreements.
• Legal Obligations: Comply with legal requirements or respond to lawful requests by public authorities.
• Emergency Situations: Protect your vital interests or those of another person.

6. Security of Personal Information
We implement appropriate technical and organizational measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. This includes:

• Encryption: Securing data in transit and at rest.
• Access Controls: Restricting access to authorized personnel only.
• Regular Audits: Conducting security assessments to identify and mitigate risks.

7. Biometric Data
For members opting for 24/7 access, we use facial recognition technology:

• Consent: We obtain your explicit consent before collecting biometric data.
• Usage: Solely for identity verification to grant facility access.
• Storage: Encrypted and stored securely, with access limited to authorized personnel.
• Retention: Retained for the duration of your membership and deleted within 30 days of termination, unless required by law.
  

8. Media Consent
We may capture photos and videos of members during classes, events, or while using our facilities. These materials may be used for promotional purposes, including on our website, social media channels, and marketing materials.

• Usage and Protection: Photos and videos are treated as personal information under the Privacy Act 1988 (Cth). We ensure these materials are stored securely and only used for the purposes described.
• Opt-Out Option: Members who do not wish to have their image used in promotional materials can opt out by providing written notification to hello@chocolateboxtraining.com. Once received, we will take reasonable steps to exclude the member from future media use.

9. Your Rights
You have the right to:

• Access: Request a copy of the personal information we hold about you.
• Correction: Seek correction of inaccurate or outdated information.
  Deletion: Request deletion of your personal information, subject to legal obligations.
• Withdraw Consent: Withdraw consent for processing your information, including biometric data.
  

To exercise these rights, contact us at hello@chocolateboxtraining.com.
Sleaping Giant Pty Ltd will not charge any fee for your access request but may change an administrative fee for providing a copy of your Personal Information.

10. International Data Transfers
We do not transfer your personal information outside of Australia. If this changes, we will ensure compliance with applicable data protection laws and obtain your consent where required.

11. Updates to This Privacy Policy
We may update this Privacy Policy to reflect changes in our practices or legal obligations. Significant changes will be communicated via our website or directly to you.

12. Contact Us
If you have questions or concerns about this Privacy Policy or our data practices, please contact:

Email: hello@chocolateboxtraining.com
Phone: +61 (2) 9971 5194
Address: Chocolate Box Cromer - 15/1 Thew Parade Cromer, NSW 2099; Chocolate Box Brookvale - 170 Harbord Road, NSW 2100;  Chocolate Box Narrabeen - 1525 Pittwater Road, North Narrabeen NSW 2101.

By engaging with our services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of your personal information as described.