EIR LIV Privacy Policy

1. Introduction

Safeguarding your privacy is important to us. EIR LIV is a member of the Florence Guild group of companies (“Florence Guild Group”) and is committed to protecting personal information that we collect and use.

EIR LIV operates a longevity centre, club lounge, and social club and provides a gym, fitness, group exercise, aquatic, and allied health facilities as part of its Services. We understand that health information you share with us deserves the highest standard of care and protection.

Our services are for health optimisation, fitness, recovery and wellness. We are not a registered health service provider. Nothing we provide constitutes medical advice, diagnosis or treatment. While we collect and facilitate access to health assessments and biometric data, we do so in our capacity as a wellness centre. If you need medical advice, please consult a registered medical practitioner.

2. About this Policy

This Privacy Policy (“Policy”) describes how EIR Group Pty Ltd (ABN 52 687 132 752) (“we” or “us”) collect, use, and disclose your personal information in connection with any website, application, or other service that refers to or links to the Policy (collectively, our “Services”), including our longevity centre, club lounge, and associated health and wellness programs. Please read the Policy carefully before you use our Services. You should not use our Services if you are not comfortable with or do not agree to this Policy. Where we are required by law to obtain your consent before collecting, using or disclosing your personal information (including sensitive health information), we will seek that consent separately and explicitly at the time of collection. Continued use of the Services alone does not constitute consent to the collection or use of sensitive health information under the Privacy Act 1988 (Cth).

We handle your personal information (including health information) in accordance with this Policy and our obligations under the Privacy Act 1988 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs), and where applicable, the Health Records and Information Privacy Act 2002 (NSW) (HRIP Act) and the Health Privacy Principles (HPPs).

3. Personal Information We Collect

We collect various types of personal information in connection with the Services, including information from our longevity centre and health programs, which may include but is not limited to:

  • Information you provide us directly, including health and medical information;
  • Information we collect about your device(s) and your use of our Services, including through cookies, web beacons, and other internet technologies; and
  • Information we obtain from third-party sources, including treating healthcare professionals.

3.1 Personal Information You Provide Us Directly

We collect various types of information and content that you provide us directly. In order to enrol as a member or to access some of our Services, you will be requested to provide us with your name, telephone number, email address, postal address, emergency contract
details, and where applicable company or organisation name.

In connection with our longevity centre and health programs, we may also collect:

  • Your date of birth and gender;
  • Health information, including blood type, weight, height, body composition metrics, resting heart rate, and other biometric measurements, as well as fitness assessment results, strength and cardiovascular performance data, exercise programming records, personal training session notes, injury history relevant to your fitness participation, and rehabilitation or return-to-exercise status;
  • Medical history, including existing conditions, prior diagnoses, medications, and surgical history;
  • Health and longevity goals, including information about your lifestyle, diet, sleep patterns, stress levels, and fitness objectives;
  • Results of health assessments, diagnostic tests, bloodwork, genetic screening, advanced imaging, and other longevity-related assessments carried out or facilitated by us;
  • Genetic information, where you elect to participate in genetic health assessments or testing programs;
  • Biometric information, including data collected from wearable devices, body composition scanners, or other health monitoring equipment used in connection with our services;
  • Name and contact details of your general practitioner, treating specialist or referring healthcare professional; and
  • Any other health or wellness information you provide to us when receiving services at our longevity centre or through our health programs.

We also collect other content and information that you provide us directly, including the content and information you may add to your member network or other community profile, photographs, and the communications that you transmit through our networks. We collect billing and payment information you provide when you access some of our Services or purchase products and services. We also collect information that you provide us when you subscribe to our mailing list, participate in our surveys, promotions, or events.

If you do not provide us with the requested information, we may be unable to deliver you the Services in full, including health and longevity services. Where health information is required as a condition of receiving a particular health service, we will inform you of this at the time of collection.

To the extent that you disclose to us any personal information of another individual, we assume that you have obtained such individual’s consent for the disclosure of such personal information as well as the processing of the same in accordance with the terms of this Policy.

3.2 What Is Health Information?

‘Health Information’ is defined in the Privacy Act and the HRIP Act, and means information or an opinion about the health or disability of an individual; information or an opinion about an individual’s expressed wishes about the future provision of health services; or personal information collected to provide, or in providing, a health service.

If you are a member accessing our longevity centre or health programs, much or all of the information we hold about you may constitute health information. Health information is a category of sensitive information that attracts a higher standard of protection under applicable privacy laws. We will only collect, use and disclose your health information where we are permitted to do so under the Privacy Act and the HRIP Act.

3.3 Information About Your Device(s) and Your Use of the Services

We collect information about how you use our Services and, depending on the access permissions you have chosen for your device, other information from and about the computers, phones, and other devices where you install or access our Services. We use standard internet technologies, such as cookies and web beacons, to collect information about your computer or device and your online activity.

The information we collect in this respect includes but is not limited to:

  • Your browser type and operating system;
  • IP address and device identifiers;
  • Your browsing behaviour on our Services, such as the amount of time spent viewing our online Services and the links you click within our online Services;
  • Whether you have opened or forwarded our e-mails or connected to offers or links that we send you; and
  • Your general or specific geographic location, such as through GPS, Bluetooth or WiFi signals, to the extent permitted by the settings of your devices.

If you use our internet connection, networks, telecommunications systems or information processing systems, your activity and any files or messages on those systems may also be monitored by EIR LIV at any time, in accordance with applicable law, for purposes of an investigation or to ensure compliance with company policies.

We may also collect location information about you each time you enter, exit and move within our facilities, including the exact date and time you entered and exited our longevity centre. This includes data generated by your membership access card or fob, locker assignment and usage data, class and lane booking records, and equipment reservation logs. We collect this information as part of our attendance data and for safety and operational purposes.

3.4 Information from Third-Party Sources

We obtain information about you from your company or organisation, including when they may create or supplement your profile for you in the member network. You can review and amend this profile at any time.

In connection with our longevity centre and health programs, we may also collect information about you from:

  • Your treating or referring general practitioners, specialists, or other healthcare providers, where you have authorised them to share information with us;
  • Pathology laboratories and diagnostic imaging providers in connection with tests conducted as part of your health program;
  • Third-party health and wellness application providers, where you have granted us access to your health data through those platforms (such as wearable device data or fitness tracking applications); and
  • Other health or wellness service providers involved in delivering services to you.

We also receive information about you from publicly and commercially available sources and other third parties as permitted by law. We may combine this information with other information we receive from or about you, where necessary to provide the Services you requested.

4. Use of Personal Information

We use the personal information that we collect as necessary and appropriate for the following purposes:

PurposeExplanation
Providing health and longevity servicesWe use your health information and personal information to provide you with our longevity centre services and associated health and wellness programs; to assess your health goals and create personalised health programs; to conduct health assessments and communicate results; to coordinate with your treating healthcare professionals; to manage your appointments and bookings; and to otherwise effectively provide our services to you.
General services and membershipWe use your personal information to provide you with the products, services, and features that you or your company or organisation have requested, including access to our longevity centre, club lounge, and social club; to respond to inquiries; to verify your identity; in connection with transactions you have initiated; to deliver notifications and other operational communications; and for troubleshooting.
Safety and emergency responsesContacting your emergency contact, responding to on-site emergencies, and managing facility safety.
Improving our servicesWe use personal information to analyse how members use our services. Where possible we use de-identified or aggregated data for this purpose; to manage the performance of our products and services; and to conduct quality assurance and improvement activities.
Administration and complianceFor audit and reporting purposes, to perform accounting and administrative tasks, to manage billing, and to enforce or manage legal claims.
Marketing and communicationsTo deliver advertising and promotional communications, subject to any legally required consent, which we will seek at the appropriate time. For example, we may periodically contact you with offers and information about our longevity and wellness programs, social club, club lounge, services, features, and events, as well as offerings from other Florence Guild Group members; to send you newsletters; to conduct surveys; and to otherwise promote our services and events.
Marketing across the Florence Guild GroupWe may use your personal information to keep you informed about products, services, events, and offerings available across the Florence Guild Group, including from other Florence Guild Group members, where you have not opted out of receiving such communications. We will only do so in accordance with applicable privacy and marketing laws and, where required, with your consent.
Security and legal complianceTo protect, enforce, or defend legal rights, privacy, safety or property, whether our own or that of our employees, members or others; to enforce compliance with EIR LIV policies; and to comply with applicable law and government requests.
Research and quality managementDe-identified health data may be used for internal research. We will not use identifiable health data for research without additional separate consent.

We will not use your personal information for a purpose other than those listed above without your consent, unless required or authorised by law.

5. Sharing of Personal Information

We disclose your personal information in the following circumstances to the following parties:
Recipient Explanation
Florence Guild Group EIR LIV is part of the Florence Guild Group of companies. We may share your personal information with other members of the Florence Guild Group for the purposes described in this Policy, including to provide you with information about products, services, events, and offerings available across the Florence Guild Group that may be of interest to you. Any such sharing is carried out in accordance with applicable privacy laws and, where required, with your consent. Members of the Florence Guild Group who receive your personal information will handle it in accordance with this Policy.
Healthcare providers As a member of our longevity centre or health programs, we may share your health information with treating healthcare professionals, allied health practitioners, clinical staff, specialists, and other healthcare providers involved in delivering services to you or managing your healthcare and wellbeing, including personal trainers, exercise physiologists, group fitness instructors, aquatic coaches, and other fitness professionals engaged by EIR LIV to deliver services to you, where you have consented to such sharing or where we are otherwise permitted to do so. EIR LIV does not control, nor is it responsible for, any third-party providers. We recommend you independently review their terms and privacy policies.
Health and wellness service providers We may share your personal information with providers of health and wellness testing, diagnostics, biometric assessment, and related equipment and products involved in delivering our longevity centre services.
Members network Our Services include online and offline member communities that allow you to share and connect with others. We make this possible by creating a member profile containing your name and company name. You can supplement this profile with additional information.

Note: we will never disclose your health information through member community features without your explicit consent.
Third party service providers We rely on third-party service providers to perform a variety of services on our behalf, including IT providers, payment processors, data analysis, and customer service. We may share your personal information with them for the purposes described under section 2 above.
Legal and regulatory bodies In some instances, we may disclose your personal information to law firms, auditors, consultants, the police, courts, tribunals and other law enforcement or government agencies: to comply with applicable law; to respond to legal process; to detect, prevent or respond to fraud; or to protect our rights, property, and safety or that of our members.
Corporate transaction If we sell or transfer our business, personal information may be transferred to the acquirer. Health information will only be transferred to an acquirer who agrees in writing to handle it in accordance with the Privacy Act and HRIP Act, and we will notify you before health information is transferred.
With your consent We may request your consent to share your personal information with third parties so that they may provide you with special offers, promotional materials, or other services of interest to you.
Our Services contain links to other sites that we do not own or operate. The linked services are subject to their separate and independent privacy statements, which we recommend you read carefully.

6. Consent

Where we are required by law to obtain your consent before collecting, using or disclosing your sensitive health information, we do so through a two-stage onboarding process:

  • Stage 1 — Health data consent notice: Before accessing health tracking, biometric monitoring or personalised wellness program features, you will be presented with a health data consent notice that explains: (a) the categories of sensitive health information we collect; (b) the purposes for which we use it; (c) who we share it with; and (d) your rights to withdraw consent at any time.
  • Stage 2 — Active consent capture: You must actively tick each consent checkbox (we do not use pre-ticked boxes) and sign or electronically acknowledge the form. Consent is granular — you may consent to biometric monitoring while declining genetic screening. Your consent record, including date, time, IP address and form version, is retained for the duration of your membership plus seven (7) years.
Withdrawing consent

You may withdraw consent at any time by written notice to admin@eirliv.com. On receipt of a revocation notice we will:

  • cease collecting the relevant data category with immediate effect;
  • cease processing that data except as required by law or to resolve an existing dispute;
  • notify Heads Up Health and any other relevant service providers to restrict further processing of that data category; and
  • confirm revocation to you in writing within 5 business days, together with details of any data retained and the legal basis for that retention

Revocation does not apply retrospectively to data already lawfully collected. Withdrawing consent for a data category that is necessary to deliver a specific service may affect our ability to provide that service; we will advise you of this at the time.

7. Information Security

We are committed to protecting your personal information, and ensuring that we securely store any personal information we collect. This is particularly important in connection with the health information we collect through our longevity centre and health programs, which attracts heightened obligations under applicable privacy laws.

We take all reasonable steps to ensure that any personal information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment protected from misuse, interference and loss, and from unauthorised access, modification or disclosure. In accordance with APP 11.3 (introduced by the Privacy and Other Legislation Amendment Act 2024 (Cth)), these steps include the implementation of appropriate technical and organisational measures, including physical security controls, access management systems, staff training, encryption of data in transit and at rest, and periodic security reviews and assessments.

FormExplanation
Paper-based filesWe store personal information in paper-based files in secure storage at our facilities. Personal information collected in paper-based form may be converted to electronic form for storage (with original documents archived or securely destroyed). We maintain physical security measures to protect paper-based files.
Electronic recordsWe store electronic records in secure databases, using trusted third-party storage providers. We maintain computer and network security through firewalls, user identifiers, passwords, and other appropriate technical controls.
Health recordsHealth information collected through our longevity centre and health programs is stored and handled in accordance with the heightened requirements applicable to health information under the Privacy Act and the HRIP Act. Access to health information is restricted to authorised personnel who need access to deliver services to you.
Websites and online paymentsOur websites use encryption and other technologies to ensure that your personal information is securely transmitted via the internet.
Staff trainingAll staff who handle personal information are trained in privacy obligations and our internal privacy policies.
Third-party providersService providers who access personal information on our behalf are contractually required to maintain equivalent security standards.

Although we take such steps to protect your information, no security program is foolproof and thus we cannot guarantee the absolute security of your personal or other information.

We will only keep your personal information for as long as is necessary for the purposes set out in this Policy or as required to comply with applicable legal obligations (including any applicable statutory retention periods for health records). For health records created in connection with our longevity centre and health programs, we will retain such records for seven (7) years from the date of last entry, in accordance with applicable health records legislation. Personal training programs, fitness assessments, and class attendance records will generally be retained for a period of two (2) years following the end of your membership, unless a longer period is required by law or is otherwise reasonably necessary. When we no longer require your personal information or are no longer required to hold that information by law, we will take steps to delete, destroy or de-identify that information.

8. Your Rights

To the extent provided for under applicable law, you have the following rights with respect to your personal information (including health information):

RightExplanation
Right of accessYou have the right to request access to and obtain a copy of any personal information we hold about you, including health information we have collected in connection with our longevity centre services. Please contact us in writing at admin@eirliv.com to make a request.
Right of correctionYou have the right to request correction of inaccurate or incomplete personal information we hold about you. We will take reasonable steps to correct the information if we agree it is inaccurate.
Right of erasureYou may request the deletion of your personal information in certain circumstances. Note that we may be required to retain certain health records for minimum periods under applicable legislation.
Right to withdraw consentWhere we process your personal information based on consent (including consent to collect sensitive health information), you have the right to withdraw that consent at any time. Withdrawal of consent may affect our ability to provide some or all of our longevity centre services to you.
Right to restriction of processingYou have the right to restrict our processing of your personal information in certain circumstances, such as where you contest its accuracy or where processing is unlawful.
Right to objectYou have the right to object to processing of your personal information where we rely upon legitimate interest, and to object at any time to processing for direct marketing purposes.
Right to complainYou have the right to lodge a complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au) if you consider that our handling of your personal information breaches applicable privacy laws.

If you would like to exercise any of these rights, please send an e-mail to admin@eirliv.com.

We may request proof of identity, and we reserve the right to charge a fee where permitted by law for requests that are manifestly unfounded or excessive. We will endeavour to respond within 30 days to your request for access and correction request.

9. Marketing

We may send you marketing communications about our services where you have consented or where the law otherwise permits (for example, where you are an existing member and have not opted out). As part of the Florence Guild Group, we may also use your personal information to keep you informed about products, services, and offerings available from other members of the Florence Guild Group that we think may be of interest to you.

We will only send these communications in accordance with applicable privacy and marketing laws (including the Privacy Act and the Spam Act 2003 (Cth)), and only where you have not opted out from receiving such communications. We will not use your health information for direct marketing purposes without your explicit consent.

If you opt in to receive marketing emails from third parties, EIR LIV will provide your personal information to those third parties, so that they may directly contact you about non-EIR LIV products and services. If you later choose to opt out of receiving marketing emails from third parties, please contact the third party directly and/or follow the unsubscribe instructions in their communications.

To opt out of receiving direct marketing from us, you can follow the opt-out instructions in any communication you receive, or contact us at admin@eirliv.com.

10. CCTV and Camera Surveillance

CCTV may be installed in EIR LIV’s buildings, including our longevity centre and club lounge, to protect the safety of EIR LIV’s employees, members, and guests and their property, and to improve our products and services. CCTV cameras may be positioned in gym floors, club lounge areas, corridors, car parks, and outdoor surrounds. CCTV is not installed in change rooms, shower facilities, toilets, or other areas where members have a reasonable expectation of privacy. Where CCTV is in operation, recordings may be accessed by EIR LIV personnel and may be shared with competent authorities in accordance with applicable laws. Recordings are retained for a limited period of time but may be kept longer for the investigation of an incident or where law enforcement agencies request us to retain them longer or as required by law.

We do not use CCTV footage for marketing purposes and do not share it publicly

11. Collection of Information from Children

The Services are not directed to children under the age of 18 and we do not knowingly collect personal information from anyone under the age of 18.

12. Third Parties That Provide Content or Functionality on Our Services

We partner with the following categories of third parties to collect, analyse, and use some of the personal information described in this Policy:

  • Third parties that provide features and functionality on the Services by means of plug-ins. Even if you do not interact with such plug-ins, they may collect information about you, such as your IP address and the pages that you view.
  • Advertising providers that help us provide targeted advertisements based on your online behaviour, and analytics companies that help us measure and evaluate the usage of our services.
  • Health technology providers that assist in delivering assessments, diagnostics, or health monitoring services through our longevity centre.
  • Other content providers that may offer products and services on our Services or conduct promotions or surveys.

These third parties may collect or receive certain information about your use of our Services, including through the use of cookies, web beacons, and internet technologies, and this information may be collected over time and combined with information collected across different websites and online services.

We are not responsible for the privacy practices of third-party sites linked from our website or through our app or platform.

13. Changes to This Privacy Policy

Automated Decision-Making

From 10 December 2026, the Privacy and Other Legislation Amendment Act 2024 (Cth) requires APP entities to disclose in their privacy policies how personal information is used in automated decision-making (ADM) systems that could reasonably be expected to significantly affect an individual’s rights or interests (APP 1.7).

EIR LIV may use computer programs or algorithmic tools to assist in the following types of decisions or recommendations: (a) personalised health or fitness program recommendations based on your assessment results or biometric data; (b) member risk stratification or clinical pathway suggestions made by health technology systems used in our longevity centre; and (c) marketing segmentation and communications targeting based on your usage and preferences.

These systems are used to assist, not replace, human judgment, and decisions with significant consequences for your health or membership status will always be subject to human review. If you have questions about whether an ADM system has been used in a decision affecting you, please contact us at admin@eirliv.com.

Privacy laws and guidelines are part of a constantly changing environment. We may make changes to this Policy from time to time. We will notify you of material changes by e-mail or by posting a notice on the relevant Services, and we will obtain your fresh consent. We recommend you review this Policy periodically to stay up to date with any changes.

Overseas Transfers of Personal Information

APP 8 of the Privacy Act 1988 (Cth) requires us to take reasonable steps to ensure that any overseas recipient of your personal information does not breach the Australian Privacy Principles in relation to that information. Your personal information may be transferred to, stored in, or processed in countries outside Australia in the following circumstances:

  • Cloud infrastructure and data storage: We use third-party cloud service providers (including providers such as Amazon Web Services, Google Cloud, and Microsoft Azure) whose servers and data centres may be located overseas. Your personal information (including health information) may be stored or processed on servers located in the following countries or regions: Australia, United States
  • Pathology and diagnostics: Pathology laboratories or diagnostic providers engaged in connection with your health program may operate or store data in, or transfer results through, overseas jurisdictions. We will inform you of specific overseas recipients at the time of referral where this is known to us.
  • Health technology providers: Health technology platforms and software providers used to deliver assessments, biometric monitoring, or longevity centre services may process data through servers located outside Australia.
  • Heads Up Health (United States): All member health data — including biometric measurements, health assessment results, wearable device data and related health information — is stored and processed by Heads Up Health LLC (headsuphealth.com), a company incorporated in Arizona, United States, that stores the member data in Australia. We have entered into Heads Up Health’s standard Data Processing Addendum (DPA) at headsuphealth.com/legal/DPA, which expressly covers Australia’s Privacy Act 1988 (Cth) as an Applicable Data Protection Law. Under the DPA: (a) Heads Up Health acts as our data processor on our documented instructions only; (b) it will not sell or share your personal information or use it to train AI models; (c) data is encrypted in transit (TLS 1.2 minimum) and at rest (AES-256); and (d) it must notify us of any security incidents without undue delay.

Before transferring your personal information overseas, we take reasonable steps to ensure that overseas recipients handle your information consistently with the Australian Privacy Principles, including through contractual protections, data processing agreements, and (where applicable) reliance on equivalent privacy frameworks. Where we are unable to ensure such protections, we will seek your consent before the transfer. You acknowledge that, where an overseas recipient is subject to a foreign law that compels disclosure of personal information (for example, a foreign government authority), we may be unable to prevent that disclosure.

Retention Schedule

We retain your personal information only for as long as is necessary for the purposes described in this Policy and for no shorter than the minimum periods prescribed by applicable law. At the end of the applicable retention period we will take reasonable steps to securely destroy or irreversibly de-identify the relevant information. These periods will be amended from time to time to reflect any changes in legislation or data retention requirements.

De-identified Data and Research

We may use or disclose de-identified or aggregated data derived from your personal information for research, analytics, quality improvement, and publication purposes. De- identified data is information from which all personal identifiers have been removed such that you cannot reasonably be identified, directly or indirectly. De-identified data is not “personal information” for the purposes of the Privacy Act 1988 (Cth) and its use is not subject to the

Australian Privacy Principles.

We will not use or disclose your personal information (i.e. information that could identify you) for research purposes beyond the purposes described in this Policy without first obtaining your separate, express written consent. Where research involving identifiable health information is proposed, we will comply with the National Health and Medical Research Council’s (NHMRC) National Statement on Ethical Conduct in Human Research.

You may opt out of your de-identified data being used for research or analytics purposes at any time by contacting us at admin@eirliv.com. Opting out will not affect the provision of health or longevity services to you. We will honour opt-out requests within 30 days of receipt

14. What happens if there is a data breach

We are covered by the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act. If we suffer a data breach that is likely to result in serious harm to any individual whose personal information is involved, we are required to notify the affected individuals; and notify the Office of the Australian Information Commissioner (OAIC).

We have an internal Data Breach Response Plan to ensure we can identify, contain, assess and notify eligible data breaches quickly. Our Privacy Officer oversees this process.

If you suspect that your personal information has been compromised, please contact our Privacy Officer immediately at admin@eirliv.com.

Upon becoming aware of a potential data breach, we will act immediately to contain the breach, assess whether it is an ‘eligible data breach’ under the NDB scheme, if eligible, notify affected individuals and the OAIC as required by law; and take steps to prevent recurrence.

15. Third-party services, plugins and cookies

Our website and digital platforms may use third-party plugins, analytics providers and advertising tools. These third parties may collect information about your online behaviour, including across other websites.

Categories of third parties we use include, website analytics providers (e.g. to understand how members navigate our site), advertising platforms (for targeted digital advertising based on your use of our site), health technology providers (for assessments, diagnostics or monitoring); and booking and member management platforms.

Our website uses cookies. A cookie is a small file stored on your device that helps our site remember your preferences. You can manage or disable cookies in your browser settings, though this may affect your experience of our website.

We are not responsible for the privacy practices of third-party sites linked from our website. We recommend you review those sites’ privacy policies before providing them with your information.

16. Questions or Comments

EIR LIV has appointed a designated Privacy Officer responsible for overseeing compliance with the Privacy Act 1988 (Cth), the Australian Privacy Principles, and this Policy.

If you have any questions, comments, or complaints regarding our Policy or our handling of your personal information (including health information collected through our longevity centre), please contact our Privacy Officer at:

Privacy Officer
c/o EIR LIV
L32, 200 George St, Sydney, NSW, Australia, 2000
Email: admin@eirliv.com

Effective Date: 23 July, 2026

EIR LIV Privacy Policy

EFFECTIVE April 1, 2026

Safeguarding your privacy is important to us. EIR LIV is committed to maintaining your trust by protecting personal information that we collect and use.

This Privacy Policy (“Policy”) describes how EIR LIV and its affiliated companies and subsidiaries (“we” or “us”) collect, use, and disclose your personal information in connection with any website, application, or other service that refers to or links to the Policy (collectively, our “Services”). Please read the Policy carefully before you use our Services. You should not use our Services if you are not comfortable with what is stated below, and your continued use of Services constitutes consent to the Policy and the use and sharing of your information as provided herein.

Personal information we collect

We collect various types of personal information in connection with the Services, namely:

  • Information you provide us directly;
  • Information we collect about your device(s) and your use of our Services, including through cookies, web beacons, and other internet technologies; and information we obtain from third-party sources.

Personal information you provide us directly

We collect various types of information and content that you provide us directly. In order to enrol as a member or to access some of our Services, you will be requested to provide us with your name, telephone number, email address, postal address, guarantor details and where applicable company or organisation name. We also collect other content and information that you provide us directly, including the content and information you may add to your member network or other community profile and photographs or other information or documentation you submit or provide us and the communications that you transmit through our networks. We collect billing and payment information you provide when you access some of our Services or purchase products and services. We also collect information that you provide us when you subscribe to our mailing list, participate in our surveys, promotions, or events. If you do not provide us with the requested information, we may be unable to deliver you the Services in full.

To the extent that you disclose to us any personal information of another individual, we assume that you have obtained such individual’s consent for the disclosure of such personal information as well as the processing of the same in accordance with the terms of this Policy.

Information about your device(s) and your use of the services

We collect information about how you use our Services and, depending on the access permissions you have chosen for your device, other information, as specified below, from and about the computers, phones, and other devices where you install or access our Services. We use standard internet technologies, such as cookies and web beacons, to collect information about your computer or device and your online activity, as explained in more detail in the section on cookies.

The information we collect in this respect is:

  • your browser type and operating system;
  • IP address and device identifiers;
  • your browsing behaviour on our Services, such as the amount of time spent viewing our online Services and the links you click within our online Services;
  • Websites you visit before or after our websites;
  • Whether you have opened or forwarded our e-mails or connected to offers or links that we send you;
  • and your general or specific geographic location, such as through GPS, Bluetooth or WiFi signals to the extent permitted by the settings of your devices.


If you use our internet connection, networks, telecommunications systems or information processing systems, your activity and any files or messages on those systems may also be monitored by EIR LIV at any time, in accordance with applicable law, for purposes of an investigation or to ensure compliance with company policies.

Information from third-party sources

We obtain information about you from your company or organisation, including when they may create or supplement your profile for you in the member network. You can review and amend this profile at any time.

We also receive information about you from publicly and commercially available sources and other third parties as permitted by law. We may combine this information with other information we receive from or about you, where necessary to provide the Services you requested.

Use of personal information

We use the personal information that we collect as necessary and appropriate for the following purposes:

  • To provide our products and services. We use your personal information to provide you with the products, services, and features that you or your company or organisation have requested; to respond to inquiries we receive from you or your company or organisation; to verify your identity; in connection with a transaction that you or your company or organisation has initiated; to deliver notifications and other operational communications; and for troubleshooting.
  • To improve our products and services and to analyse how users navigate and use our products and services and individual features. To manage the performance of our products and services.
  • For audit and reporting purposes, to perform accounting and administrative tasks, and to enforce or manage legal claims. To deliver advertising and promotional communications, subject to any legally required consent, which we will seek at the appropriate time. For example, we may periodically contact you with offers and information about our products, services, features, and events; to send you newsletters or other information about topics that we believe may be of interest; to conduct online surveys; and to otherwise promote our products, services, features, and events. We also may deliver targeted advertisements to you, both on and off the Services.
  • For security and to protect, enforce, or defend legal rights, privacy, safety or property, whether our own or that of our employees or agents or others, and to enforce compliance with Florence Guild policies and to comply with applicable law and government requests.

Sharing of personal information

We disclose your personal information in the following circumstances to the following parties:

Partners.
Our services are provided by partners of EIR LIV depending on where you are located and the services you use. EIR LIV shares personal information with those partners for the purposes mentioned above. These partners use your information in accordance with this policy.

Memberships.
Our Services include online and offline member communities, forums and networks that allow you to share and connect with others. We make this possible for EIR LIV members by creating a profile for new members that contains your name and the name of your company or other organisation. This profile is created automatically and is accessible to other members of the forum or network, some of which include all EIR LIV members. You can supplement your profile by adding additional information about yourself and your company or organisation and by posting content and comments and you may be able to share your profile with a broader audience.

Third party suppliers.
We rely on third-party service providers to perform a variety of services on our behalf. For example, we may rely on service providers to fulfil our product and service requests and answer your questions, send e-mails on our behalf, process payment card or other transactions, and analyse data to improve our products and services. To do so, we may need to share your personal information with them for the purposes described under “Use of Personal Information”.

Other parties when required by law and as necessary to provide and protect our services. In some instances, EIR LIV and our service providers disclose your personal information to law firms, auditors, consultants, the police, courts, tribunals and other law enforcement agencies:

  • to provide you with the services you or your company or organisation request, such as a disclosure of your information to a landlord in connection with a lease agreement, or to auditors or consultants;
  • to comply with the law or respond to legal process or a request for cooperation by a government entity or law enforcement (which may include lawful access requests by Australian and other courts, law enforcement and governmental authorities);
  • to detect, suppress, and prevent fraud or verify and enforce compliance with the policies governing our Services; 
  • or there permitted by law, to protect our rights, property, and safety or that of any of our respective affiliates, business partners, customers or employees and where otherwise required by law.


Corporate Transaction.
We will disclose your personal information to an acquirer in the event we sell or transfer all or a portion of a business or assets to that third party, such as in connection with a merger or in the event of a bankruptcy reorganisation or liquidation. Third-party partners, with your consent. We may request your consent to share personal information about you with third parties so that they may provide you with special offers, promotional materials, and other materials that may be of interest to you.

Organisation or company request.
In addition to the disclosures described in this Policy, we may share information about you with third parties when your company or organisation requests such sharing. For example, we periodically may partner with third parties to make products or services available to individual members or participating companies and organisations. If you or your company or organisation requests to participate, we may share your information with the relevant third party in connection with the requested product or service.

Anonymous and non-personal information. We also share with third parties information in a manner that does not identify particular individuals, for example, information that has been aggregated with other records.

Our Services contain links to other sites that we do not own or operate. We provide links to these third-party sites as a convenience to our members. They are not intended as an endorsement of or referral to the linked services. The linked services are subject to their separate and independent privacy statements, notices, and terms, which we recommend you read carefully. The collection, use, and disclosure of your personal information will be subject to the privacy policies of the third party and not this Policy.

Third parties that provide content or functionality on our services

We also partner with the following categories of third parties to collect, analyse, and use some of the personal information described in this Policy:

Third-parties that provide features and functionality on the Services by means of plug-ins. Even if you do not click on or interact with social networking services or other plug-ins, they may collect information about you, such as your IP address and the pages that you view.

Advertising providers help us and our advertisers provide advertisements on our Services or elsewhere, including advertisements that are targeted based on your online behaviour, and analytics companies help us measure and evaluate the usage of our services.

Other content providers may offer products and services on our Services and may operate contents, promotions, or surveys on our Services.

These third parties collect or receive certain information about your use of our Services, including through the use of cookies, web beacons, and Internet technologies and this information may be collected over time and combined with information collected across different websites and online services.

Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising. Please visit the websites operated by the Network Advertising Initiative and the Digital Advertising Alliance.

Information Security

We have in place various procedures to safeguard your information. Although we take such steps to protect your information, no security program is foolproof and thus we cannot guarantee the absolute security of your personal or other information.

Accessing, reviewing, and updating your personal information

To the extent provided for under applicable law, you may have the right to access your personal information and to update or correct inaccuracies in your personal information.

You may have rights to revoke consent you previously granted us with respect to processing personal information and to object to the use of your personal information for direct marketing or for other purposes that are not necessary in light of the nature of our legal relationship. Note that if you revoke your consent to such processing, we may be unable to provide you with certain aspects of the services.

If you would like to exercise any of these rights, please send an e-mail to connect@eirliv.com or a letter to Chief Operating Officer, c/o EIR LIV, 99 Elizabeth St, Sydney, NSW, Australia, 2000.

Marketing rules

If you opt-in to receive marketing emails from third-parties, EIR LIV will provide your personal information to third parties, so that those third parties may directly contact you about non-EIR LIV products and services. If you later choose to opt-out of receiving marketing emails from third parties, please contact the third party directly and/or follow the instructions at the bottom of their marketing emails.

Collection of information from children

The Services are not directed to children under the age of 18 and we do not knowingly collect personal information from anyone under the age of 18. Where different age limitations apply, we comply with them.

CCTV

EIR LIV’s buildings have CCTV installed to protect the safety of EIR LIV’s employees, members, and guests and their property, as well as to improve our products and services and to analyse how users navigate and use our spaces. Recordings may be accessed by EIR LIV in Australia and elsewhere and may be shared with competent authorities in accordance with applicable laws. The recordings are retained for a limited period of time but may be kept longer for the investigation of an incident or when competent authorities request us to retain them longer.

Your Rights

You have the following rights with respect to your personal data:

  • The right to withdraw consent, where applicable, you have the right to withdraw your consent at any time. For example, if you would like to opt out of receiving electronic marketing communications, you can request your email to be marked ‘unsubscribe’ by contacting us directly and we will stop sending you communications.
  • Right of access, rectification or erasure. You have the right to request access to and gain a copy of any of your personal data that we may hold, to request correction of any inaccurate data relating to you and to request the deletion of your personal data under certain circumstances. You can see the data by contacting EIR LIV directly at connect@eirliv.com. Right of data portability. Under certain conditions, you have the right to receive all such personal data which you have provided to us in a structure commonly used and machine-readable format, and also to require us to transmit it to another controller where this is feasible, technically.
  • Right to restriction of processing. You have the right to restrict our processing of your personal data where –
  • You contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;
  • The processing is unlawful but you do not wish to have the data erased by us;
  • We no longer need your personal data for the purposes of the processing, but you require such data for the establishment, exercise or defence of legal claims; or
  • You have been objected to processing justified on legitimate interest grounds (see below) pending verification as to whether we have overrising compelling legitimate grounds to continue processing.
  • Where personal data is subject to restriction in this way, we will only process it with your consent or for the establishment, exercise or defence of legal claims. Right to object to processing justified on legitimate interest grounds, where we are relying upon legitimate interest to process personal data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims where we reply upon legitimate interest as a justification for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
  • Right to object to processing for marketing purposes, where we process personal data for direct marketing purposes, then you have the right to object to that processing at any time.
  • You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes applicable law. You may contact the Australian Information Commissioner (www.OAIC.gov.au)


For further information regards your rights, to exercise any of your rights, or if you have any complaints or questions regarding the processing of your personal data, please contact Chief Operating Officer, c/o EIR LIV, 99 Elizabeth St, Sydney, NSW, Australia, 2000 or connect@eirliv.com
Please be advised that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for any instance if your request is manifestly unfounded or excessive. We will endeavour to respond to your request in a timely manner, as soon as possible and in any case within the applicable timeframes.

Changes to this privacy policy in the future

Privacy laws and guidelines are part of a constantly changing environment. We will notify you of material changes by e-mail or by posting a message on the relevant Services.

Questions or Comments

If you have any questions or comments regarding our Policy, please contact us at: Chief Operating Officer, c/o EIR LIV, 99 Elizabeth St, Sydney, NSW, Australia, 2000. Email: connect@eirliv.com

Effective Date: April 1, 2026