Privacy Policy

Version Website PP v1.0 + Program PP v1.3 · 16 October 2026 · Wellness Technology Services Pty Ltd, ABN 43 682 264 606

Part A — General Privacy Policy

Wellness Technology Services Pty Ltd (ABN 43 682 264 606, Kensington NSW) (“WTS”, “we”, “us”)

Last updated: 16 October 2026

1. What this policy covers

This policy explains how WTS handles personal information collected through this website and in our general business dealings, such as enquiries, emails and meetings.

Some of our services have their own privacy policy, which applies instead of this one for that service:

Employee Biometric Health Program: see the Program Privacy Policy below.
Client engagements (for example WISER or Movement Health): personal information is handled under the agreement with the client organisation and any participant notice provided for that engagement.

We comply with the Australian Privacy Principles in the Privacy Act 1988 (Cth).

2. What we collect

When you contact us: your name, organisation, role, email address, the topic of your enquiry, and anything you choose to include in your message or later emails.
When you visit the website: our website platform, Wix, may collect technical information such as your IP address, browser type, pages visited and cookie identifiers.

Please don’t send us health information through the website or by email. We don’t need it to respond to an enquiry. If you send it anyway, we’ll only use it to respond, and we’ll delete it if we don’t need it.

3. Why we collect it

We use your information to:

respond to your enquiry and arrange any follow-up you ask for;
manage our business relationship with you or your organisation;
operate, secure and improve the website; and
meet our legal obligations.

We don’t sell your information. We’ll only send you news or marketing if you’ve asked us to, and you can opt out at any time.

4. Who we share it with

We share your information only with service providers who help us run our business, and only as needed:

Wix, which hosts this website and the enquiry form;
Google Workspace, which provides our email and document storage;
professional advisers (for example our lawyers and accountants); and
others where the law requires or authorises it.

5. Overseas disclosure

Some of these providers may store or process personal information outside Australia, including in the United States and other countries where Wix and Google operate. We take reasonable steps to make sure they handle it consistently with the Australian Privacy Principles.

6. How we protect it

We restrict access to enquiry records to WTS personnel who need them, and we use the access controls and security features of the systems that hold them. We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure.

7. How long we keep it

We keep enquiry records for 2 years after our last contact with you, unless the enquiry becomes a client relationship or we need the information for a legal reason. After that we delete or de-identify it.

8. Automated decisions

We don’t use personal information collected through this website to make automated decisions about you.

9. Access and correction

You can ask to see or correct the personal information we hold about you by emailing support@wellnesstechnologyservices.com. We’ll respond within 30 days.

10. Complaints

If you have a privacy concern, email us first at support@wellnesstechnologyservices.com. We’ll acknowledge it within 5 business days and aim to resolve it within 30 days. If you’re not satisfied, you can contact the Office of the Australian Information Commissioner at www.oaic.gov.au or 1300 363 992.

11. Changes

We may update this policy. The current version is always on this page, with the date it was last updated.

Part B — Employee Biometric Health Program Privacy Policy

1. Who we are

Wellness Technology Services Pty Ltd, ABN 43 682 264 606 (WTS, we, us) runs the WTS Employee Biometric Health Program — Foundations (the Program). This policy explains what personal information we handle for the Program, why, who we share it with and what choices you have.

We comply with the Australian Privacy Principles in the Privacy Act 1988 (Cth) for the Program. We are a service provider to you, not your employer.

Privacy contact: support@wellnesstechnologyservices.com (email only). Use this address for any privacy question, to see or correct your information, to leave employer reporting, or to make a complaint.

2. The short version

Through the Program, WTS does not collect, access or use your Oura data. Your ring data stays in your own Oura account, under Oura’s own privacy policy. If WTS ever invites you to take part in a separate WTS project that would use your Oura data, you’ll get a separate notice explaining exactly what would be used and why. Nothing is used unless you give your separate, express consent to that project, and saying no has no effect on the Program, your ring or your credential.
We collect what you give us to buy and take part in the Program — your contact and order details, and the answers and selections you make in the modules.
Your employer never sees your individual Oura or other biometric data, or your individual answers and selections. If your organisation has bought our Employer Reporting Service, it receives de-identified, aggregate reports only — never about a group of fewer than 20 people.
We do not use your details for marketing, and we do not sell your information.
You can ask us at any time to leave you out of employer reporting entirely (section 7). This does not affect your access to the Program, your ring or your credential.
Personal reflections are never entered into the platform. The modules tell you when something is just for you to jot down yourself.

3. What we collect

Order and contact details: Name, email, phone, delivery address, ring model, size and colour, your size-from-kit confirmation, the organisation your checkout link belongs to, your employing entity or work group (for example, a business unit), your order/payment reference. From You, at checkout (Stripe).

Payment details: Card details. Entered into Stripe; WTS does not see or store your full card number

Enrolment and activity records: Your start date and schedule, enrolment, whether you’ve ticked “I’ve set up my ring”, module completions (used to confirm you’ve completed all ten modules for your credential), credential issue. From You and the WTS-hosted learning platform

Program responses: Quiz answers; the action you choose at the end of some modules; support-level selections (for example, whether a self-managed step, a workplace conversation or formal support fits); 👍/👎 module ratings; an optional 0–10 rating of how likely you are to recommend the Program; follow-up answers on whether you tried your chosen action. From

You, in the WTS-hosted learning platform

Support requests: What you tell us when you contact support, and any request to leave employer reporting. From

You

What we do not collect through the Program: your Oura data (sleep, readiness, activity, heart rate, temperature, stress or any other ring measurement), your Oura account login, free-text personal reflections, or anything for marketing.

Some Program responses may reveal information about your physical or psychological health or the support you may consider seeking. WTS treats this information as sensitive information and collects it only where reasonably necessary for the Program and with your consent.

4. Why we collect it, and your consent

We use your information to:

Deliver the Program — process your order, arrange your ring through Oura, enrol you, run your program schedule, give support, and issue your credential.
Improve and check the Program — using de-identified, aggregated data only, to see which modules are useful and to improve them.
Report to your organisation — only if it has bought the Employer Reporting Service — using de-identified, aggregated data only (section 6).

Consent. When you tick the box at checkout, you agree to the Program Terms & Conditions (https://www.wellnesstechnologyservices.com/ebh-program-t-cs) and consent to WTS collecting and handling the information reasonably necessary to process your order, deliver the Program, support you and issue your credential, and to using de-identified, aggregated information as described in this section and section 6.

5. Your Oura data and Oura’s role

You set up your own Oura account and accept Oura’s own terms and privacy policy:

Oura Privacy Policy: https://ouraring.com/privacy-policy
Oura Terms of Use: https://ouraring.com/terms-and-conditions

Oura (Oura Health Oy, Finland, and its affiliates) controls the data in your Oura account, including your ring measurements, profile and account information. Oura stores it in its own cloud systems. Oura’s privacy policy says that Oura “is a global company with servers around the world, and your personal data may at times be processed on servers located outside of the country where you live”. Through the Program, WTS does not receive, access or use the data in your Oura account.

To get your ring to you, we give Oura your name, delivery address, email, phone and your ring model, size and colour.

6. Information provided to your organisation

Only if your organisation has bought WTS’s Employer Reporting Service.

If it has, your organisation receives de-identified, aggregate reports covering:

How many people enrolled, activated and completed modules and the credential (counted across participants who have not left employer reporting — section 7); and
Response-based measures — such as the share of people who found modules useful, who tried their chosen action, and who selected a conversation, professional or clinical support option — counted across participants who have responded and have not left employer reporting (section 7).

Every report follows two rules:

No group smaller than 20. Any group of participants with fewer than 20 people is not reported.
No slicing that gets smaller than 20. A report cannot combine filters (for example work group and site) if that would describe fewer than 20 people, even where the larger group is bigger.

Reports never include your name, any individual record, or any Oura or biometric data. Your organisation cannot ask us for individual information and we will not give it.

If your organisation has not bought the Employer Reporting Service, it receives no reporting from us.

The Program is hosted by WTS. Your organisation’s own systems never hold your completions, answers or selections.

7. Leaving employer reporting

You can ask us at any time, without giving a reason, to leave you out of employer reporting entirely — your Program responses and the simple counts of enrolment, activation and module and credential completion described in section 6.

How: email support@wellnesstechnologyservices.com with “Leave employer reporting”.
When it takes effect: before the next report we produce. We record your request.
What it doesn’t change: your access to the Program, your ring, your Oura account or your credential.
Reports already produced are not recalled; they are de-identified and aggregate.

8. Who we share information with

We do not sell your information. We share it only with the service providers we need to run the Program, and with your organisation only as described in section 6.

WTS takes reasonable steps to assess and manage the privacy and security arrangements of service providers that handle personal information for the Program. Those steps may include contractual privacy and security obligations, limits on permitted use, access controls, breach-notification requirements, retention and deletion requirements, and review of overseas handling arrangements.

Overseas disclosure. Some service providers we use to run the Program may store or process personal information outside Australia:

Oura (Finland and other countries where Oura operates): your ring order and delivery details.
Stripe (the United States and other countries where Stripe or its sub-processors operate): payment details you enter at checkout.
Compono (Australia and the United States): hosts the learning platform WTS uses to deliver the modules and record completions and responses.
Google Workspace (the United States and other global Google data center regions): WTS email and file storage.

WTS takes reasonable steps to make sure these providers handle your information in line with the Australian Privacy Principles.

We may also disclose information where the law requires or authorises it.

9. How we protect personal information

WTS restricts access to identifiable Program records to authorised personnel who require access for their role. WTS uses access controls and logging appropriate to the systems holding those records and restricts external link-sharing for Program records. Order export files are access-restricted and deleted in accordance with section 10. WTS also takes reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.

10. How long we keep it

We retain personal information only for as long as it is reasonably required for the purposes described in this policy, to deal with an open request, complaint or claim, or to meet a legal obligation. At the end of the applicable period, we take reasonable steps to delete or de-identify the information.

Order, payment and refund records: 10 years after the end of the financial year of the transaction

Order export files (used to place your ring order and set your start date): Deleted within 30 days after your batch’s dispatch is confirmed

Program records — enrolment, start date, completions, quiz answers, selections, ratings and follow-up answers: 2 years after your 12-month program anniversary (or after you leave the Program, if earlier), then deleted or de-identified

Credential record — your name, the credential and its issue date: 7 years after issue, so we can confirm it if you ask

Support and complaint correspondence, including requests to leave employer reporting: 2 years after the matter is closed (longer if a claim is still open)

Access logs for identifiable Program records: 2 years

De-identified, aggregated data and reports: Retained while reasonably required for Program evaluation, governance and lawful business purposes, provided WTS has taken reasonable steps to ensure that individuals are not reasonably identifiable

11. Automated decisions

WTS uses the learning platform to apply the Program’s fixed rules. The platform opens and closes your module windows on set dates counted from your start date. It records a module as complete when you have answered all required knowledge-check questions correctly and selected the required action. At your 12-month program anniversary, the platform uses your recorded completion status to determine whether the Program credential is issued. Program access also closes automatically at that anniversary.

These processes use your enrolment, start-date and module-completion information. They do not assess your health, work performance or suitability for employment. If you believe your completion record is incorrect or a credential has not been issued correctly, contact WTS and request a manual review.

12. Access and correction

You can ask to see the personal information we hold about you, or to correct it, by emailing support@wellnesstechnologyservices.com. We will respond within 30 days. For your Oura data, use Oura’s own tools and data-request process.

13. Data breaches

If a data breach involving your information is likely to cause you serious harm, we will notify you and the Office of the Australian Information Commissioner, as the Notifiable Data Breaches scheme requires. If we suspect a breach, we assess it quickly and within 30 days at most. If a breach affects Oura data, Oura handles it under its own obligations.

14. Complaints

Email our privacy contact first: support@wellnesstechnologyservices.com. We will acknowledge you within 5 business days and aim to resolve your complaint within 30 days. If you’re not satisfied, you can complain to the Office of the Australian Information Commissioner: www.oaic.gov.au, 1300 363 992.

15. Changes

We will tell you by email before any change that affects how we use your information. Any new use — including any future use of biometric data — needs a new, separate consent.

Last updated: 16 October 2026.