PRIVACY POLICY

On Top Pty Ltd (ACN 149 410 435), together with its registered business names including On Top Performance Academy, On Top Fitness, Team On Top, Focused Fitpreneur, PT Success Program, and coachGrazy and their related entities, affiliates and assigns (collectively referred to as ONTOPPA, “we”, “us” or “our”), is committed to protecting your privacy and the security of your personal information (as that term is defined in the Privacy Act 1988 (Cth) (Privacy Act).

This Privacy Policy sets out how ONTOPPA collects, uses, discloses, stores, secures and disposes of personal information in accordance with the Privacy Act, including through our website at www.ontoppa.com.au and any other online or digital platforms operated or managed by us (“Online Platforms” – see paragraph 17 for a more complete definition).  It also explains your rights to access and correct your personal information, and how you may make complaints.

ONTOPPA is bound by the Australian Privacy Principles (APPs) set out in Schedule 1 of the Privacy Act. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner (OAIC) at http://www.oaic.gov.au.

About Us

  1. ONTOPPA provides, or is reasonably contemplating providing, a range of services and content, including:
  • online coaching, training and mentoring programs;
  • self-paced educational courses and resources (including the Content Vault and Fast Track Formula);
  • digital tools, e-Books and other downloadable resources or templates (e.g. checklists, worksheets, marketing plans);
  • blog articles, newsletters and written educational content;
  • podcasts, webinars, video channels and other streaming media;
  • social media content and community forums (e.g. Instagram, Facebook);
  • interactive tools and online experiences (e.g. online quizzes, scorecards);
  • affiliate, referral and revenue-sharing programs;
  • access to industry mentors and experts, including any educational, coaching, or community content they share with ONTOPPA;
  • other multimedia, interactive or digital content hosted on our Online Platforms; and/or
  • any other current or future services or offerings that may reasonably fall within ONTOPPA’s online education, coaching, or fitness business.

Collectively, these offerings are referred to in this Privacy Policy as the “Services,” whether provided free or paid and whether online or offline.

  1. This Privacy Policy applies to all individuals who interact with ONTOPPA and whose personal information is collected by ONTOPPA, including clients and members, prospective clients and members, contractors, suppliers, and visitors to our Online Platforms. It does not apply to business entities (Pty Ltd) if no personal information about individuals is collected. ONTOPPA is based in Australia and information it collects from you will be processed and stored in Australia.
  2. We may update this Privacy Policy from time to time to reflect changes in law, our practices, or technology. The latest version will always be published on our Online Platforms including our website ontoppa.com.au.

Collection of Personal and Sensitive Information

  1. “Personal Information” is defined under the Privacy Act and is characterised as being information or an opinion about an individual whose identity is apparent or an individual who is reasonably identifiable, whether true or not, and whether recorded in material form or not. If we do not maintain information in a form that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual or household, such information is not considered Personal Information and this Privacy Policy will not apply to our processing of that information.
  2. The types of Personal Information we may collect include your name, gender, date of birth, contact details (such as email, phone number and address), credit card or bank account details, billing and payment information, occupation, employer, driver’s licence number, tax file number, emergency contact details, membership, products and services information and preferences, and records of your communication with us. We may also collect your location data through our Online Platforms if you choose to enable this service.  While gender is collected as Personal Information, we do not generally collect Sensitive Information unless reasonably necessary for our functions and with your consent.
  3. We may also collect behavioural and/or statistical information about individuals or businesses in connection with the Services.
  4. “Sensitive Information” is a subset of Personal Information and includes information about your health, genetic or biometric data, disability, racial or ethnic origin, political opinions, membership of a professional or trade association, religious beliefs or affiliations, sexual orientation or practices, or criminal record. We will only collect Sensitive Information where it is reasonably necessary for our Services, functions or activities, and with your consent or as otherwise permitted by law (for example, your height, weight, biometric information, training goals, injuries, medical clearances or any other relevant health details or records).
  5. Unless otherwise stated, any reference to “Personal Information” in this Privacy Policy should be read to include “Sensitive Information” where relevant and lawfully collected.

Why We Collect Personal and Sensitive Information

  1. ONTOPPA collects Personal Information, and where necessary and with consent, Sensitive Information, from customers, employees, contractors and other individuals that is reasonably necessary for one or more of our Services, business functions or activities, to meet any regulatory requirements which apply to our business, to market and sell our products and services and to conduct employee related activities. Collection of personal information from employees is covered under employment law, not the Privacy Act, but handled in line with privacy principles where practical.
  2. It is your choice whether or not to share your physical or mental health details or other sensitive information with ONTOPPA, and we will process any such data only if you have given your explicit consent, or it is deemed necessary, or if the sensitive personal information has been manifestly made public by you (for example, by you posting information about your health/fitness status on online platforms). We do not generally collect information about race, ethnicity, political opinions, religious beliefs, or criminal history, unless required by law or provided with consent.
  3. You have the option to deal with us anonymously or by using a pseudonym. However, you acknowledge that where this is impractical (for example when you contract with us) or where the law or a court order provides otherwise we are not required to provide these options to you.
  4. If you choose not to provide your Personal Information to ONTOPPA, or choose to deal with us anonymously, or by using a pseudonym, we may not be able to undertake certain activities for you including providing you with requested information, products or services, and/or you may not be able to use some functionalities across our platforms.

When and How We Collect Personal Information

  1. ONTOPPA collects Personal Information directly from you when you do any of the following: visit our Online Platforms, sign up for a membership, programs or services, buy products from us, request information about us or our products or services, provide feedback, participate in surveys, quizzes, or promotions, change your content or email preferences, enter into an agreement or contract with us, fill in a form on our online platforms (including an enquiry form or a registration form to register as a user on our website), subscribe to newsletters, marketing, or request downloads (such as eBooks), fill in a form or request that we forward your information to a third party service or course provider, or communicate with us by phone, chat services, email, social media, in writing or in person.
  2. We may also collect information indirectly from third parties where you have provided consent (e.g., payment processors, marketing partners, course or training providers, Registered Training Organisations (RTOs) or referral partners). When you have elected to sign up and log into our platforms using a third-party account you created (e.g., through Facebook, Apple, Google), we collect the information you have agreed to make available to us. This information is collected by those third-party account providers and disclosed to ONTOPPA under their privacy policies. You can control what data we receive by changing your privacy controls in your third-party account.
  3. In some cases, we may collect de-identified or aggregate information that cannot reasonably identify you. De-identified information means that all personal identifiers such as a person’s name, contact details, date of birth or other characteristics that enable identification of an individual have been removed. Aggregate information refers to information that has been combined with data from other individuals so that only broad patterns or trends can be observed, without identifying any particular person.
  4. In some circumstances we may receive Personal Information that we have not requested. If this occurs, we will comply with our obligations under the Privacy Act. You acknowledge that we may de-identify and/or destroy this information unless we are required to keep it by law.

Information Collected via Our Online Platforms

  1. ONTOPPA will not collect any Personal or Sensitive Information about users of our Online Platforms except when you knowingly provide it or as otherwise described in this Privacy Policy.  Our Online Platforms include, but are not limited to our:
  •  Website (ontoppa.com.au);
  • Landing pages and blogs;
  • Digital or mobile applications as developed from time to time;
  • Podcasts, video channels, webinars and streaming services;
  • Member portal, e-learning platform or online community forums;
  • Our social media accounts or profiles, such as (without limitation) Facebook, Instagram, YouTube and Twitter (but at all times being subject to the terms and conditions of use and privacy policies of the websites hosting those accounts or profiles); and/or
  • Any other current or future online or digital platforms or software from which ONTOPPA may provide the Services or you may communicate with ONTOPPA.
  1. ONTOPPA will handle Personal Information collected online with the utmost care and in order to provide you with the Services offered through the Online Platforms, and will not knowingly use it in ways not consented to by you.
  2. ONTOPPA may collect Personal Information online where you have selected particular services or features on the Online Platforms (e.g. sharing your fitness activities with friends through our platforms), which may include your photos, audio, contacts and calendar information, as well as your social network information (including credentials and any information from your public posts about ONTOPPA or your communications with us). Further, we may collect information you share in a social media post where you tag, use a hashtag, link, or otherwise direct the post to our attention.

Aggregate and Click Stream Data 

  1. When you visit and browse our Online Platforms, including our Website, our platform hosts may collect Personal Information and non-personal information or data in aggregate form for statistical, reporting and maintenance purposes. Subject to paragraph 42, the Personal Information collected by our platform hosts will not be used to identify you.  The information may include:
  • the number of users visiting our platforms and the number of pages viewed;
  • the date, time and duration of a visit;
  • the IP address of your computer; and/or
  • the path taken through our platforms.
  1. ONTOPPA’s Online Platform hosts may use this information to administer and improve the performance of our platforms, including to measure and analyse internet usage across our platforms and to assist us with the diagnosis of and to provide support for any issues with our platforms or services.
  2. The collection of Personal Information via any third-party integrated or affiliated applications and/or software will be subject to the privacy policies and practises of those third parties.

Cookies

  1. ONTOPPA does not knowingly use cookies or similar tracking technologies to collect Personal Information about you unless you voluntarily provide it (for example, by completing forms on our Online Platforms or communicating with us). However, we may collect certain data that does not, on its own, identify individuals (sometimes called “web log information”) when you visit certain pages, such as the type of browser and operating system you use, the date and time of your visit, pages viewed, and your IP address. In some cases, where this data is combined and can reasonably identify you, it may be considered Personal Information under the Privacy Act.  Where required by law, we will seek your consent before placing such technologies on your device.
  2. We may also use “cookies” to give users the best possible experience on our Online Platforms. Cookies are small text files placed on your device to help manage security, navigation, user preferences, and session information. You can adjust your internet browser to disable cookies, but this may limit the functionality of our Online Platforms and/or ONTOPPA may not be able to provide you with all the Services you require.

Web Beacons

  1. Web beacons are images that originate from a third-party site designed to track user activities such as visiting a page or clicking a link. ONTOPPA may use web beacons to collect aggregate data and provide this information to our Online Platform hosts to administer and improve the performance of our sites.

Advertising

  1. We use Google and/or other third-party service providers to serve ads on our behalf across the Internet and sometimes on our Online Platforms. They may collect anonymous, non-personal information about your visits to our Online Platforms, and your interaction with our products and services. They may also use information about your visits to our Website and other websites to target advertisements for goods and services in order to provide more relevant advertisements about goods and services of interest to you.

Links to Third Party Website and Platforms

  1. Our Online Platforms may contain links to websites, applications or social media platforms owned and operated by third parties. These sites and platforms are not covered by our Privacy Policy.
  2. We have no control over the types of information third-party site owners choose to collect and how they use it. ONTOPPA is not responsible for the privacy, security or data-handling practices of any third-party websites, applications or social media platforms linked from our Online Platforms, or the collection and use of your personal information by those third parties.
  3. If you access other websites, applications or social media platforms using the links provided, operators may collect information from you and use it in accordance with their own privacy policies, which may differ from ours. We recommend you carefully review the privacy policies of any third-party before providing personal information.

Use of Personal and Sensitive Information

  1. Any Personal Information (and for clarity, where relevant and with your consent, Sensitive Information) that we collect about individuals will be used and disclosed by us to provide the Services required or otherwise to enable us to carry out our functions.
  2. We also collect and use your Personal Information so that we can carry out the following actions:
  • provide you with information, including ongoing information about ONTOPPA and its activities, products or services;
  • create, set up and secure your member accounts, register you as a user of any of our Online Platforms, provide access to our platforms, process payments by you or to you in connection with our Services, and create tax invoices or receipts (electronic or otherwise);
  • operate our business, including for statistical and marketing analysis, systems testing and to diagnose technical and service problems, maintenance and development of our platforms;
  • communicate with you, including to promote and market our products, services and offers which might interest you, and for other targeted promotional purposes;
  • manage our relationship with you as our customer, personalise and customise your experiences on our Online Platforms, operate and improve our platforms or services (e.g. to respond to your inquiries or complaints);
  • conduct research for the purposes of improving existing products or services, creating new products or services, or identifying the needs of our customers;
  • provide you with third party information and offers in which we believe you may be interested;
  • provide your Personal Information to third parties such as course or training providers or RTOs when you have consented to us doing so;
  • comply with regulatory or other legal requirements; and/or
  • for any other use required or permitted by law or any other purpose communicated to you at the time that the Personal Information was collected or for which you provided your consent.
  1. ONTOPPA may use your Personal Information for a secondary purpose if that secondary purpose is related to the purposes set out in paragraphs 30 and 31, if we have your consent or if otherwise permitted by applicable law.

De-Identified Information

  1. We may use your Personal Information in de-identified form (as described in paragraph 15 above) to assist us in running our business. We may also provide, including by way of sale, de-identified information in aggregated form, to third parties. This information may include (but is not limited to):
    • age demographics;
  • purchasing trends;
  • trends and statistics in relation to the Services;
  • statistics about purchasing patterns of the Services; and/or
  • statistics surrounding the Services.
  1. When your Personal Information is included in de-identified, aggregated data, it is not possible to identify you or anything about you from that data.

Direct Marketing

  1. ONTOPPA complies with the Spam Act 2003 (Cth). We will not send you marketing communications unless you have consented to receive them, and you may withdraw consent at any time.
  2. ONTOPPA may use your Personal Information to provide you with direct marketing materials if you consent to receive direct marketing materials or on the reasonable belief that a potential customer would be interested in the subject matter. We will seek your consent to provide you with direct marketing materials if we have obtained your Personal Information from a third party. Direct marketing material may include promotional material about ONTOPPA or the products or services offered by ONTOPPA. In every case you or a potential customer will be provided with clear instructions on how to be removed from our mailing list.
  3. You can opt out of receiving marketing at any time by following the unsubscribe instructions in the communications or contacting us directly as noted paragraph 66.

Disclosure of Personal Information

  1. Depending on the nature of your relationship with ONTOPPA, we may use and share your Personal Information with:
  • Other users of the Online Platforms if you have selected particular services or features on the platform (e.g. sharing your fitness activities with friends through social media platforms or community forums);
  • If you joined ONTOPPA via a referral link sent to you by one of your contacts (like a friend, family member, or colleague), we may let that contact know you’ve created an ONTOPPA account, and provide them a referral bonus as a result;
  • Shareholders and officers of ONTOPPA, or other businesses within our group of companies;
  • Other companies, contractors or agents that assist us in providing services to you, including customer support, legal services, debt collection, administration services, and information technology support. If ONTOPPA engages with these persons or entities, their contracts with us require them to keep all such Personal Information confidential;
  • Service providers/contractors who assist us in our business operations (including parties that we engage to provide you with goods or services on our behalf such as course providers, personal trainers or industry experts/mentors);
  • Only where you have provided consent, other companies, contractors or agents in connection with our marketing efforts, or marketing platform providers;
  • Parties involved in the purchase or sale of, or potential purchase or sale of, any of our businesses, under strict non-disclosure restrictions, and solely in order to allow a buyer to determine whether to proceed with the transaction, or where such a determination is made, to complete it;
  • Third party social media platforms such as Facebook, Instagram, TikTok, Google, in various circumstances and with your consent, including for example where you connect your member account to your social media account, or where we use social media plugins on our Platform (e.g., a “share” or “like” button), and your use of these plugins may result in the disclosure of some of your information to that social media platform;
  • Government authorities, law enforcement bodies and regulators for compliance with legal requirements, or where otherwise required by applicable law;
  • Our legal and other professional advisers in order to enforce our legal rights in relation to our contract with you; and/or
  • Where you choose to post information on our platforms, the information that you share will be public information which can be viewed by anyone (whether or not they are a part of our community). Information posted in the Forum will be indexed to third party internet search engines (such as Google), websites and apps.

For the avoidance of doubt, where we hold Sensitive Information, we will only disclose it for the purposes set out in this Privacy Policy and where you have provided your consent, or where otherwise permitted by law.

  1. Individuals consent to Personal Information being disclosed to ONTOPPA support staff, employees and contractors where lawfully permitted, and placed on our secure internal systems (such as our intranet or secure cloud platforms) that are accessible only by authorised ONTOPPA employees and contractors, to enable those individuals to be recognised, managed and supported as an On Top member.
  2. Other than as described above in paragraph 38, ONTOPPA may also disclose your Personal Information to our Online Platform host or service providers in other limited circumstances, for example when our online platforms experience a technical problem or to ensure that they operate in an effective and secure manner.  To the extent that we do share your Personal Information with a service provider, ONTOPPA will make all reasonable efforts to ensure that the service provider complies with our privacy standards as described in this Privacy Policy.
  3. We may also share non-personal, de-identified and aggregated information for research or promotional purposes or for the purpose of improving our services.
  4. Unless otherwise specified in this Privacy Policy, ONTOPPA will not disclose any of your Personal Information to any other organisation unless the disclosure is required by law, it is under a legal requirement to do so (for example, under a Court order or an authorised request is made from a law enforcement agency), is otherwise permitted by the Privacy Act, or is with your consent.

Disclosure of Personal Information Overseas 

  1. ONTOPPA does not currently knowingly disclose Personal Information outside of Australia. However, if you access ONTOPPA’s Services from outside Australia, your Personal Information may be collected directly by us from that location. In such cases, the information will be handled in accordance with this Privacy Policy and the Australian Privacy Principles (APPs). ONTOPPA does not accept responsibility for compliance with the privacy or data protection laws of any foreign jurisdiction.
  2. Some of our third-party service providers may store or process data overseas (including but not limited to the United States, Singapore, and Ireland). 
  3. To the extent permitted by law, wherever personal information may be disclosed overseas, you consent to the transfer, storage and processing of your Personal Information outside Australia, including in countries that may not have the same level of privacy protection as Australia. Where reasonably practicable, ONTOPPA will take steps to ensure that overseas recipients handle your Personal Information in accordance with the APPs. However, by providing this consent, you acknowledge that APP protections may not apply once your information is overseas, and ONTOPPA will not be accountable for that handling under the Privacy Act.

Staff Records

  1. While ONTOPPA takes reasonable steps to protect all personal information it holds, the Privacy Act does not apply to employee records held by ONTOPPA in relation to current or former employment relationships. Employee information is managed in accordance with other applicable legal requirements. As such this Privacy Policy does not apply to the handling of employee related information, although internal records are handled consistently with privacy protections where practical. Please contact us directly for information about our employee information handling practices.

Storage and Security of Personal Information

  1. ONTOPPA will take reasonable steps to protect your Personal Information from misuse, interference and loss, and from unauthorised access, modification or disclosure.
  2. ONTOPPA aims to keep your Personal Information secure, accurate and up to date.  We will comply with our obligations under the Privacy Act in relation to any Personal Information that we handle, including information which is held on ONTOPPA’s computer systems, protected by usernames and passwords.
  3. Personal Information that is held by ONTOPPA in hard copy is stored securely on its premises and is only disclosed or used for the purposes described in this Privacy Policy.

Access, Removal and Correction of Personal Information

  1. You may request access to Personal Information we hold about you by contacting us. We will grant your request unless providing you with access would unreasonably impact upon the privacy of others, if an exception applies under the Privacy Act, or is not otherwise permitted under the Australian Privacy Principles or at law.  If we refuse your request to access your Personal Information, we will provide you with written reasons for the refusal.
  2. You are entitled to tell us if you do not wish us to hold your Personal Information, in which case we will take reasonable steps to remove such information from our database, subject to any legal or regulatory requirements that require us to retain certain records (for example, financial or tax records). Please note that if you request removal of your Personal Information, ONTOPPA may be unable to continue providing you with the Services, and you will forfeit access to any Online Platforms, memberships, subscriptions, content, or other features that depend on us holding your Personal Information. This may include termination of any current membership or subscription without refund of any unused portion, subject to the terms of your agreement with us. Requests of this kind will be handled consistently with our retention practices set out in paragraphs 54–56 of this Privacy Policy.
  3. A request for access can be made by contacting ONTOPPA in any of the ways specified in paragraph 66.
  4. We will take reasonable steps to ensure that the Personal Information that we hold is accurate, up-to-date and complete.  You have the right to ask us to correct information about you, which is inaccurate, incomplete or out of date. You can update your Personal Information at any time by contacting us in any of the ways specified in paragraph 66, or if you are a registered ONTOPPA user by logging in and updating your profile. We welcome any changes to your Personal Information so as to keep our records up to date.

Retention of Personal Information

  1. We will retain your Personal Information for as long as required to provide services to you, comply with our legal obligations (for example, tax and corporate record-keeping requirements of up to seven years), resolve disputes, and enforce agreements.
  2. Where we no longer need to keep your Personal Information in accordance with paragraph 54, we will take reasonable steps to destroy or de-identify your Personal Information. If we fully anonymise your personal data so that it can no longer be associated with you or identify you, we may use that information without further notice to you.
  3. If you wish to have your Personal Information destroyed or de-identified at any time, please let us know and we will take reasonable steps to do so (unless we need to keep it for legal obligations, auditing, insurance or internal risk management reasons or as otherwise required by law). For clarity, such requests will also be treated in accordance with paragraph 51 of this Privacy Policy, and you should be aware that destruction or de-identification of your Personal Information may mean we are unable to continue providing you with the Services. Information that you have shared on our Online Platforms may remain public even after you have closed your member account. When you choose to delete content that you have posted to the Online Platforms, the information will not be deleted from third-party websites, apps or internet search engine indexes instantly as removal of the content depends on third-party policies.

Data Breach Obligations

  1. ONTOPPA complies with the Notifiable Data Breaches scheme under the Privacy Act. In the event of a data breach that is likely to result in serious harm, we will notify affected individuals and the OAIC as required by law.

Social Networking Acceptable Use Policy

  1. ONTOPPA encourages respectful engagement on any of our social media platforms (such as Facebook, Instagram YouTube, Twitter and others), as we value feedback, insights, and conversation with our community of followers, customers, fans, clients and staff. While we welcome diverse views and constructive criticism, these platforms must not be used to abuse others, expose others to offensive or inappropriate content, or for any illegal or unlawful purpose. ONTOPPA reserves the right to moderate, hide, or remove content that breaches these conditions, in line with our Community Guidelines published on our social media platforms (which operate in conjunction with this Privacy Policy and our Terms and Conditions).
  2. It is your responsibility to protect your personal privacy when using our social media pages. We strongly advise you not to include any Personal Information (yours or others) in your posts or comments (such as email addresses, home addresses, or phone numbers). Any Personal Information you choose to disclose on a public platform is at your own risk.
  3. You should also refrain from posting material that infringes the intellectual property rights of others, contains defamatory, misleading, or unlawful content, or includes internet addresses, links or email addresses for promotional or unauthorised purposes.
  4. Information posted on ONTOPPA’s official social media accounts may be recorded and used for the purpose of administering those pages and responding to comments or issues raised. We may also use aggregated, non-identifiable insights for business and marketing purposes. ONTOPPA will not attempt to identify individual users except where authorised or required by law.
  5. ONTOPPA is not responsible for the privacy practices, content or policies of third-party social media platforms. Our responsibility is limited to our own official posts made on ONTOPPA’s verified accounts. We recommend you review the privacy policies of any third-party platforms before posting or engaging.

Children’s Privacy

  1. Our Services are primarily intended for individuals aged 18 years or over. Individuals aged 15 to 17 may access our Services in their own right, in accordance with guidelines from the Office of the Australian Information Commissioner (OAIC), provided they are capable of understanding and complying with our Terms and Conditions and this Privacy Policy (see https://www.oaic.gov.au/privacy/your-privacy-rights/more-privacy-rights/children-and-young-people). Individuals under 15 may only access the Services with the consent and responsibility of a parent or legal guardian.
  2. We do not knowingly collect Personal Information from minors without appropriate consent. If we become aware that such information has been provided, we will take reasonable steps to delete it in accordance with this Privacy Policy and applicable law, unless legally required to retain it.

Changes to Our Privacy Policy

  1. ONTOPPA reserves the right to change this Privacy Policy without prior notice. Any changes to this Privacy Policy will be posted on the ONTOPPA website or via our other online platforms or we may decide to inform you via other means (such as email). Any changes will take effect immediately upon being posted, unless otherwise stated. The date of the most recent update will be noted at the end of this document. Your continued use of our Services after such changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy regularly. If, at any time, you have questions, comments or concerns about our privacy commitment, or our privacy obligations, please contact us.

Contact Details

  1. If you feel that your privacy has not been respected or that ONTOPPA has conducted itself inconsistently with this Privacy Policy, the Australian Privacy Principles, a registered APP Code and/or the Privacy Act in respect of your Personal Information, or for any other queries, problems, complaints or communication in relation to this Privacy Policy, please contact us in any of the following ways:

Email: [email protected]

Postal Address:
Attention: Privacy Officer
On Top Pty Ltd, 63 Baileys Mountain Road, Willow Vale, Qld, 4209 Australia

You can find out more information about the Privacy Act and the Australian Privacy Principles from the Office of the Australian Information Commissioner. The Information Commissioner may be contacted at www.oaic.gov.au (email: [email protected]).

Last updated: August 2025