Privacy Policy

In this Privacy Policy, “us”, “we” or “our” means Rhubarb Group Pty Ltd (ABN 58 653 651 855), trading as Dee Zibara (the “Company”). We are committed to respecting your privacy and protecting your personal information.

This Privacy Policy sets out how we collect, use, store and disclose your personal information. We are bound by the Australian Privacy Principles (“APPs”) in the Privacy Act 1988 (Cth) (“Privacy Act”). By providing personal information to us, or by using our website, member account or services, you consent to us collecting, using and disclosing your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.

We may change this Privacy Policy from time to time by publishing the updated version on our website. Please check periodically so you are aware of the current version. Your continued use of our website or services after a change is taken to be acceptance of the updated Privacy Policy.

1. Who this policy covers and our platform

This Privacy Policy applies to personal information we collect through our website at www.deezibara.com, your member account, our programs, products and services, and our communications with you.

We deliver our programs and member accounts through a third-party platform (Kajabi). You can access your account on the web or through Kajabi’s own mobile app. Kajabi’s platform, and its mobile app, are operated by Kajabi under its own terms and privacy policy; we recommend you review them. This Privacy Policy does not cover the practices of third parties we do not own or control.

2. You must be at least 18

Our website, programs and services are intended for people aged 18 or over. We do not knowingly collect personal information from anyone under 18. If you believe a person under 18 has provided us with personal information, please contact us and we will take reasonable steps to delete it.

3. The personal information we collect

Personal information is information or an opinion about an identified, or reasonably identifiable, individual. Depending on how you interact with us, we may collect:

• name;
• mailing or street address;
• email address, telephone number and other contact details;
• age or date of birth, and gender;
• credit card and other payment information (usually collected and processed by our payment provider);
• account information and login credentials;
• messages, chat, email and survey responses, and related metrics;
• details of the products and services we have provided or that you have enquired about;
• device ID and type, geo-location information, IP address, browser and connection information, page views and other usage and analytics data; and
• any other information you provide to us directly, or that we collect through your use of our website, account or services.

4. Sensitive and health information

If you take part in one of our programs, challenges or assessments, we may collect health information from you so we can provide our services - for example, information about your health conditions, symptoms, medications, and measurements such as height and weight. Health information is “sensitive information” under the Privacy Act and attracts higher protection.

We only collect sensitive information with your consent and where it is reasonably necessary for our services. By providing health information to us (including through onboarding questionnaires and pre-screening), you consent to us collecting, holding and using it for the purposes described in this Privacy Policy. We will not disclose your health information to third parties without your consent, except where required or authorised by law. Health information is not used for direct marketing.

5. How we collect your information

We collect personal information:

• directly from you - for example when you create an account, purchase or enquire about a program, complete a questionnaire or survey, or contact us;
• automatically as you use our website and account, including through cookies and similar technologies; and
• from third parties, such as our platform and payment providers, and (if you apply for a role with us) recruiters and referees.

You can decline to provide information we request, but we may then be unable to provide some or all of our services to you.

6. Why we collect, use and disclose your information

We may collect, hold, use and disclose your personal information to:

• provide you with access to, and the benefit of, our website, account, programs, products and services;
• process transactions, fulfil orders, and manage billing and collections;
• register you as a user and manage your account;
• respond to your enquiries and provide customer support;
• send you service, support and administrative messages, reminders, updates and security alerts;
• operate, protect, improve and optimise our website, services and business, including analytics, research and quality improvement;
• send you marketing and promotional messages you have not opted out of (see below);
• manage risk, legal liabilities and claims, and obtain professional advice;
• comply with our legal obligations, resolve disputes, enforce our agreements, and prevent fraud, security incidents or unlawful activity; and
• any other purpose you would reasonably expect, that we tell you about when we collect the information, or that you consent to.

7. Direct marketing and your choices

We and our carefully selected partners may send you marketing about our programs, products and services, by email, SMS, mail or other channels, in accordance with the Spam Act 2003 (Cth) and the Privacy Act. You can opt out at any time by using the unsubscribe link in our emails or by contacting us. We will still send you necessary service and account messages. Health information is never used for direct marketing.

8. Who we may disclose your information to

We do not sell your personal information. We may disclose it, for the purposes described above, to:

• our employees, contractors and related bodies corporate;
• third-party suppliers and service providers, including our platform provider (Kajabi), hosting, email, analytics and marketing providers;
• payment systems operators and processors;
• our professional advisers (such as lawyers, accountants and consultants);
• a buyer or successor in the event of a sale, merger or restructure of our business;
• third parties you have authorised to receive your information; and
• government agencies, regulators or law enforcement, where required, authorised or permitted by law.

Except with your consent or where an APP exception applies, we will not disclose your health information to third parties.

9. Overseas disclosure

We use service providers located outside Australia, so your personal information may be stored and processed overseas. In particular, our program and account platform (Kajabi) and certain other providers are based in, or store data in, the United States, and other providers may be located in other countries. Where we disclose personal information overseas, we take reasonable steps to ensure the recipient handles it consistently with the APPs, except to the extent you consent to the disclosure or an APP exception applies.

10. Cookies and tracking

We use cookies and similar technologies to operate our website, remember your preferences, and understand and improve how our website is used. Cookies are small files stored on your device. You can disable cookies in your browser settings, but parts of our website may not work as intended. Where a cookie is linked to your account it may be personal information, and we handle it in line with this Privacy Policy.

Do Not Track: because there is no consistent industry standard for “Do Not Track” signals, our website does not currently respond to them.

11. Security

We take reasonable steps to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure, using physical, administrative and technical measures such as access controls, user IDs and passwords. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account password secure and for signing out after use. Any transmission of personal information is at your own risk.

12. Notifiable data breaches

We comply with the Notifiable Data Breaches scheme under the Privacy Act. All staff must refer any actual or suspected data breach to our Privacy Officer as soon as possible. Where we suspect an eligible data breach, we will assess it promptly (and generally within 30 days), take reasonable remedial steps, and - where the scheme requires - notify affected individuals and the Office of the Australian Information Commissioner (OAIC).

13. Accessing and correcting your information

You can ask to access the personal information we hold about you, and to have it corrected if it is inaccurate, out of date, incomplete, irrelevant or misleading. Please contact our Privacy Officer (details below). We may need to verify your identity. There is no charge to request access, though we may charge for reasonable costs of compiling information. If we decline a request, we will give you our reasons as required by the APPs.

14. Dealing with us anonymously

Where it is lawful and practicable, you may deal with us anonymously or using a pseudonym - for example, when making a general enquiry. Generally, we cannot provide our programs or services on an anonymous basis because we need your information to deliver them.

15. Complaints

If you believe we have breached the Privacy Act or mishandled your personal information, please contact our Privacy Officer with your name, contact details and a description of your complaint. We will acknowledge and respond within a reasonable time. If you are not satisfied with our response, you may complain to the OAIC by phone on 1300 363 992 or via the contact details on the OAIC website (oaic.gov.au).

16. Links and social media

Our website and communications may contain links to, or plug-ins for, third-party sites and platforms (for example Facebook, Instagram, YouTube, TikTok and LinkedIn). We are not responsible for the content or privacy practices of those third parties, and their privacy policies may differ from ours. Information you post on social media is governed by that platform’s terms and privacy policy.

17. Visitors from the EU, EEA and UK (GDPR)

We are based in Australia and do not specifically target customers in the EU, EEA or UK, but where the General Data Protection Regulation applies to personal information we hold about individuals there, we aim to comply with it. Subject to applicable law, you may have rights to: access the information we hold and how we process it; have it corrected or erased; restrict or object to our processing; data portability; withdraw consent where we rely on it; and lodge a complaint with your local supervisory authority. Withdrawing consent may mean we can no longer provide our services to you. To exercise these rights, contact us using the details below.

18. Contact us - Privacy Officer

For questions about this Privacy Policy or our privacy practices, or to access or correct your information or make a complaint, contact our Privacy Officer:

Privacy Officer
Rhubarb Group Pty Ltd
1/39 Leighton Place, Hornsby NSW 2077, Australia
Email: [email protected]