Privacy Policy

Metro Dietetics Pty Ltd, trading as The Energy Code (“The Energy Code”, “we”, “us” or “our”), respects your privacy and is committed to protecting the personal information we collect and hold.

This Privacy Policy explains how we collect, use, disclose, store and protect personal information when you visit theenergycode.org (the “Website”), submit information through the Website, request information from us, interact with our advertising or otherwise communicate with us.

We are an Australian company and provide services to people in Australia and the United States. We handle personal information in accordance with applicable privacy and data protection laws, including the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APPs”) where applicable, as well as applicable United States privacy laws.

1. Personal Information We Collect

The personal information we collect depends on how you interact with us. It may include:

• your name, email address and telephone number;
• your state, region or general location;
• business, occupation or employment information you choose to provide;
• responses you provide through forms or questionnaires;
• information supplied when requesting a report, guide, consultation, call or other resource;
• communications with us by email, telephone, SMS or other means;
• information relating to your interactions with our emails, Website and advertisements;
• IP address, browser and device information;
• referring website or advertising source;
• pages visited, actions taken, and advertising or analytics identifiers; and
• other information you voluntarily provide.

Health and wellbeing information

Some of our Website forms or questionnaires may ask for limited information about your health priorities, symptoms, energy levels, wellbeing goals or whether improving your health is currently a priority. This information helps us provide a requested resource, understand your enquiry and determine whether our services may be relevant to you.

Our general lead-generation forms are not intended for medical records, pathology results, diagnoses, detailed treatment histories or other extensive clinical information. Please do not submit this material through a general Website form unless we specifically request it through an appropriate channel.

Metro Dietetics Pty Ltd may collect additional health information when providing professional or health-related services. Where we do so, it will be handled in accordance with applicable privacy and health-information requirements.

2. How We Collect Personal Information

We may collect personal information directly from you when you:

• complete a form on our Website;
• request a free report, guide or other resource;
• respond to an advertisement;
• enquire about our services or request or book a call;
• communicate with us by telephone, email or SMS;
• become a client or prospective client; or
• otherwise voluntarily provide information to us.

We may also collect information automatically through cookies, pixels, analytics tools and similar technologies. Where permitted by law, we may receive information from third-party advertising, analytics and technology platforms in connection with your interactions with our Website or advertising.

3. How We Use Personal Information

We may collect, hold and use personal information to:

• provide information or resources you request and respond to enquiries;
• contact you regarding an enquiry or request;
• determine whether our services may be appropriate for you;
• arrange and conduct calls or consultations;
• provide and administer our services;
• communicate with prospective and existing clients;
• send marketing communications where permitted by law;
• personalise and improve our Website and communications;
• measure Website use, advertising performance, enquiries and conversions;
• create, measure or optimise advertising audiences where permitted;
• improve our products, programs, services and business systems;
• maintain business and administrative records;
• detect or prevent fraud, misuse or security incidents;
• establish, exercise or defend legal rights; and
• comply with applicable legal and regulatory requirements.

We will not use or disclose personal information for an unrelated purpose unless you have consented or we are otherwise permitted or required to do so by law.

4. Marketing and SMS Communications

If you provide your contact details and consent to receive marketing communications, or where we are otherwise permitted by law to contact you, we may communicate with you about The Energy Code, your requested resources, your enquiry, our services, programs and offers. Communications may occur by email, SMS, telephone or another channel you provide to us.

Where required, we obtain consent before sending commercial electronic communications. You may withdraw consent or opt out at any time. Marketing emails include an unsubscribe mechanism. For SMS, reply STOP to opt out or HELP for assistance. You may also contact [email protected].

We process valid opt-out requests in accordance with applicable law. Opting out of marketing does not prevent necessary communications about an existing appointment, transaction, service or request.

5. Cookies and Similar Technologies

We use cookies, pixels, server-side tracking technologies and similar tools to operate and improve our Website and understand interactions with our Website and advertising. These technologies may collect:

• IP address, browser and device type;
• pages viewed, links or buttons clicked;
• referring website and date and time of visits;
• advertising identifiers and campaign information;
• interactions with forms; and
• events or actions taken on our Website.

Some technologies are necessary for the Website to function. Others support analytics, advertising measurement and marketing. You may restrict cookies through your browser settings, although doing so may affect Website functionality. Where required by law, we will provide additional choices for non-essential cookies or tracking.

6. Google Analytics

We use Google Analytics and related Google technologies to understand Website use and measure performance. Google may collect or receive information such as your IP address, browser and device information, approximate location and Website activity.

We use this information to understand traffic, identify how visitors find and use our Website, and improve our Website and marketing. Google processes information according to its own privacy policies and terms.

7. Meta Pixel and Conversions API

We use Meta advertising and measurement technologies, which may include the Meta Pixel and Meta Conversions API. These technologies help us measure advertisement results, attribute conversions, optimise campaigns, understand interactions, and create or optimise advertising audiences where permitted by law.

Depending on our configuration, information transmitted to Meta may include Website events, browser or device information and identifiers or contact information. Identifying information transmitted through the Conversions API may be hashed before transmission. Hashing is a security measure but does not necessarily mean the information is no longer personal information. Meta processes information according to its own terms and privacy practices.

8. Sale, Sharing and Targeted Advertising

We do not sell personal information for money. We use advertising and analytics providers such as Meta and Google. Certain identifiers, device information, Website activity or other information may be disclosed to or collected by these providers for analytics, advertising measurement, attribution, audience creation and optimisation.

Some United States privacy laws define “sale,” “sharing,” “targeted advertising” or “cross-context behavioural advertising” more broadly than a sale for money. Where an applicable law gives you a right to opt out of a covered use or disclosure, and that law applies to us, we will honour valid requests as required.

This section does not alter our commitment that mobile phone numbers, SMS opt-in data and messaging consent will not be shared with third parties or affiliates for their own marketing or promotional purposes.

To make an applicable privacy request, contact [email protected].

9. Do Not Track and Online Tracking

Some browsers and devices provide Do Not Track signals or other tracking preferences. Because no single standard governs all Do Not Track signals, our Website may not respond to every signal. Third-party services, including Meta and Google, may collect information about activity on our Website and, depending on their services and your settings, across other online services.

Where applicable law requires recognition of a legally recognised opt-out preference signal, we will take reasonable steps to comply where it applies to our business and processing activities.

10. Third-Party Service Providers

We use third-party service providers to help operate our Website, communications, marketing and business. These include or may include:

• GoHighLevel for customer relationship management, forms, lead management, communications and marketing automation;
• Meta for advertising, audience management, conversion tracking, attribution and measurement;
• Google for analytics, Website measurement and related technologies;
• Eway for payment processing separate from our Website; and
• providers supporting hosting, email, telecommunications, data storage, security, administration and professional services.

We disclose personal information only where reasonably necessary for these services or otherwise permitted by law. Providers may process information according to their own terms, privacy policies and legal obligations.

11. Payment Information

We do not collect or process payment card information directly through theenergycode.org. Purchases may be processed separately through Eway or another payment provider.

We may receive transaction information such as your name, transaction amount, payment status, date and reference. We do not need to receive or store your complete payment-card details where payment is processed directly by the provider.

12. Disclosure of Personal Information

We may disclose personal information:

• to technology and service providers that help operate our business;
• to provide services or information you request;
• to advertising and analytics providers as described in this Policy;
• to professional advisers such as lawyers, accountants and consultants;
• to protect our legal rights, users or business;
• in connection with a business sale, restructuring or transfer, subject to law;
• where required or authorised by law; or
• with your consent.

We do not sell personal information for monetary consideration. Mobile information and SMS consent remain subject to the additional restrictions stated in Section 4.

13. Overseas Processing and Disclosure

Metro Dietetics Pty Ltd is located in Australia. Some providers operate internationally, so personal information may be transferred to, stored in, processed in or accessible from outside Australia, including the United States. Providers may also use infrastructure, affiliated entities or subprocessors in other countries.

Where the APPs apply, we take reasonable steps as required by applicable law in relation to overseas disclosures. Privacy and data-protection laws overseas may differ from Australian law.

14. Data Security

We take reasonable technical and organisational measures to protect personal information against misuse, interference, loss, unauthorised access, modification and disclosure. Measures may include access controls, password protection, authentication, reputable providers and other appropriate safeguards.

No internet transmission or electronic storage system is completely secure, and we cannot guarantee absolute security.

15. Data Retention

We retain personal information for as long as reasonably necessary for the purpose collected and for legitimate business, administrative, legal and regulatory purposes. The period depends on the information, its purpose, our relationship with you, legal requirements, security needs and potential legal claims.

When information is no longer reasonably required, we may delete or de-identify it, subject to applicable requirements.

16. Access and Correction — Australia

If the APPs apply to information we hold about you, you may request access and correction of information that is inaccurate, out of date, incomplete, irrelevant or misleading. Contact [email protected].

We may need to verify your identity. Applicable law may permit or require us to refuse a request in some circumstances, in which case we will provide an explanation where required.

17. Privacy Rights for United States Residents

Depending on your state, our activities and whether the relevant law applies to Metro Dietetics Pty Ltd, you may have rights to:

• know or confirm whether we process your information;
• request access, correction or deletion;
• obtain a portable copy of certain information;
• learn about categories of information collected or disclosed;
• opt out of certain sales, sharing or targeted advertising;
• withdraw consent to certain processing; and
• appeal certain privacy decisions where provided by law.

Rights vary by state and may not apply in every circumstance. Nothing in this Policy represents that a particular state law applies where its statutory thresholds have not been met. Where applicable, we will not unlawfully discriminate against you for exercising a right.

To submit a request, email [email protected] with enough information for us to understand it. We may need to verify your identity.

18. California Residents

California residents may have additional rights depending on which laws apply to our activities. Our Website may collect identifiers, internet or electronic activity information, general geolocation information and information you voluntarily provide, for the purposes described in this Policy.

We may disclose information to the service-provider and third-party categories described here, including technology, analytics and advertising providers. We do not sell personal information for money. Advertising technologies may, depending on the circumstances and law, constitute “sharing” or another regulated advertising-related disclosure.

Where California law provides an applicable right to opt out, we will honour valid requests as required. Contact [email protected].

19. Third-Party Websites

Our Website may link to third-party websites, applications or services. We are not responsible for their privacy, security or content practices. We encourage you to review their privacy policies when leaving our Website or interacting directly with them.

20. Children’s Privacy

Our Website and services are intended for adults and are not directed toward children. We do not knowingly use our general Website to solicit children's personal information for marketing.

If you believe a child has provided information inappropriately, contact [email protected] so we can investigate and take appropriate action.

21. Privacy Complaints

If you have concerns about our handling of personal information, contact [email protected] with enough information for us to investigate. We will respond within a reasonable period.

If Australian privacy law applies and you are not satisfied with our response, you may have the right to complain to the Office of the Australian Information Commissioner (OAIC). Nothing in this Policy limits a right to contact an applicable privacy or regulatory authority.

22. Changes to This Privacy Policy

We may update this Policy to reflect changes to our business, Website, information collection, providers, advertising practices or applicable laws. The current version will be published on our Website, and the date above identifies the latest revision.

We encourage you to review this Privacy Policy periodically. Where required by law, or where a change materially affects your rights, we may provide additional notice or request renewed consent.

23. Contact Us

For questions, privacy requests, access or correction requests, or complaints, contact: