Privacy Policy - Australia and NZ

 

About us and this Policy

R-U-Ontrak Pty Ltd (we, us or our), owner and operator of R-U-Ontrak, is committed to the protection of your personal information.

R-U-Ontrak consists of a digital platform including the R-U-Ontrak app (App) and the R-U-Ontrak website (Website).

If you are a user of the App (User), you can:

  • Set goals that will impact on your quality of life, and target end dates to achieve these goals.

  • Connect some of your health, fitness and lifestyle apps, ie Apple Health on iOS, and calendar to the App, and you can communicate the details of your activities with your health service providers, trainers, and coaches (Providers).This enables your Providers to keep track of your progress towards your goals and set you activities to help you achieve them.

 

If you are a Provider, you can record data on and communicate with Users you are working with and set them activities through the Website.

So you can effectively use R-U-Ontrak, we will need to collect some personal information from you. If you do not provide the personal information that we request, your use of the R-U-Ontrak App and Website may be inhibited and we may not be able to provide the full functionality of those services to you.

This privacy policy (this Policy) sets out the way we will collect, use, disclose, store and protect your personal information. This Policy also describes the way in which you may access or correct the personal information we hold about you, and how to contact us if you have any complaints in relation to your privacy.

 

Our legal obligations

We will handle your personal information according to law, and we are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (APPs) and, if you are using R-U-Ontrak in New Zealand (a NZ User) the Privacy Principles contained in New Zealand’s Privacy Act 1993.

 

These laws set out strict requirements for the handling of your personal information.

 

What is ‘personal information’?

This Policy applies to our handling of personal information. ‘Personal information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether the information is recorded in a material form or not.

 

Personal information includes ‘sensitive information’, which is a particular type of personal information. Sensitive information includes identifying health information about you (for example, if you are a User this may include details of your injuries or conditions, or details of your interactions with Providers).

 

Why do we collect your personal information?

We collect your personal information so that you can effectively use R-U-Ontrak. For example, if you are a User, we will collect your personal information such as your contact details so R-U-Ontrak can help enable you to meet these goals and allow you to communicate with your Providers, and to enable billing for use of R-U-Ontrak (if applicable).  If you are a Provider, we will collect your personal information including your contact details so that Users can communicate with you, and to enable billing for use of R-U-Ontrak (if applicable).

 

How do we collect your personal information?

We will collect your personal information directly from you through your use of R-U-Ontrak or from third parties, such as family members or other persons you have authorised to provide your personal information to us.

We will collect your personal information in a lawful and fair way and in a manner that is not unreasonably intrusive.

We only collect your personal information where it is reasonably necessary for our activities in providing R-U-Ontrak to you.

We will only collect your personal information and sensitive information where you have consented through your use of R-U-Ontrak, or otherwise in accordance with the law.

If we collect your personal information, we will take reasonable steps to ensure that you are made aware of the details of the collection, including the purposes for which the information was collected, the organisations (if any) to which the information will be disclosed, and notify you that this Policy contains details on how you may access or correct your information, or raise any complaints.  We will whenever practical, provide you with access to this information through the R-U-Ontrak App and Website.

Using the group feature of R-U-Ontrak you can connect to and communicate with other Users and Providers (with your consent) all in the one group. 

A group could be made up of many different configurations of Users and Providers. For example, if you are a User, a group could include:

  • you, your coach, and your team of health service providers; or

  • you and other Users that are in the same sports team, and your coach.

 

The group feature will enable you and other Users and Providers to work together to help a User achieve their goals.

So you can connect to other Users or Providers in a group, we may collect personal information about you from other Users or Providers (such as your name, email address or phone number), just as you may provide these details for other Users or Providers.

You will only be connected to a group where a ‘join group’ invitation is accepted by the recipient.  You may send join group invitations and you agree that other persons using R-U-Ontrak may send you join group invitations. It is up to you whether to accept or decline any such invitation.

If you send or accept an invitation to join a group, you give your consent for us to disclose your personal information (including as applicable your full name, mobile number, email address, organisation and role and, if you are under the age of 18, the fact that you are under 18 and your parents’ or guardian’s names and details) to be shared with the other members of the group.

 

What types of personal information do we usually collect?

We may collect personal information such as:

  • your name;

  • your contact details, e.g. your email address and mobile phone number;

  • billing details (if applicable);

  • if you are a User:

    • the details of your activities and other data from your third party health, fitness and lifestyle apps and calendar, and other data and information you provide concerning your activities and goals;

    • the details of the Providers you see in relation to your goals and/or injuries;

    • the details of your health status including any injuries, and any actions you have taken to manage your health.

 

How do we use your personal information?

We use your personal information for the main purposes of providing you with access to R-U-Ontrak and so that you can effectively use the functions R-U-Ontrak as described in this Policy.

We may use your personal information (your name, email address and phone number) in order for you to connect to and communicate with Users and Providers.

We may also use your personal information for purposes which are directly related to providing you with the R-U-Ontrak App and Website, in circumstances where you would reasonably expect us to use your information for these purposes, such as for registration and administration purposes.

 

Do we disclose your personal information to others?

We respect the privacy of your personal information and we will take reasonable steps to keep it confidential and protected.

We will not disclose your personal information to any third parties unless you have consented through your use of R-U-Ontrak, or we are otherwise permitted or required to do so by law.

If you are a User, we may disclose your personal information (such as your name, contact details, and details of your goals, activities and health and fitness data) to the Providers you nominate when using R-U-Ontrak, so your Providers can communicate with you. If you are a Provider, we may disclose your personal information (such as your name and contact details) to the Users who have nominated you as their Provider, so Users can communicate with you. We may disclose your personal information to other third parties (such as family members or other persons) where you have consented. 

We will only disclose your personal information without your consent in accordance with the law, such as where we reasonably believe this is necessary to prevent or lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety.

Note that we do not endorse any Providers or any third party app providers, nor are we responsible for their handling of your personal information once it is shared or exported outside of the R-U-Ontrak App and Website. Before you provide your information to any Provider or any other third party, you should familiarise yourself with any privacy policies of the Provider or third party.

 

Will we disclose your personal information overseas?

We will not disclose your personal information to any recipient that is located outside of Australia, other than in the case of NZ Users where we may disclose your information to an authorised recipient located in New Zealand.

 

How do we hold and protect your personal information?

We will protect your privacy and the security of your personal information by taking steps to ensure that your personal information is protected against misuse, interference and loss, and unauthorised access, modification or disclosure.

These steps include using personal identification number (PIN) or password protection to ensure that only you or persons you have authorised can access your information through the R-U-Ontrak App or Website.

We also use a variety of reasonable physical and technological security safeguards to protect the personal information we hold.

We may hold your personal information in a number of ways including electronically and in physical format.

When you use R-U-Ontrak, your personal information will be stored in secure servers located in Australia and provided by a third party provider. From time to time, we may need to give the third party server provider access to personal information so that it can diagnose and resolve any software issues.

When the group feature of R-U-Ontrak is used, files containing user personal information for the invitation process and any messages sent between users are encrypted and transmitted using our secure servers located in Australia and provided by a third party provider.

We retain your personal information so that you can effectively use the R-U-Ontrak App and Website.

When your personal information is no longer required, we will take steps to securely destroy the information or to ensure that the information is de-identified.

 

Quality of the personal information we hold

We take reasonable steps to ensure that the personal information we collect, use and disclose is accurate, up-to-date, complete and relevant.  You can assist us in keeping your information accurate by updating your personal information through the R-U-Ontrak App and Website when there are any changes to your details. 

 

Can you access and correct your personal information?

You may request to access to the personal information that we hold about you using our contact details below.

In certain circumstances, we may refuse to allow you access to your personal information where this is authorised by the law, such as where the request is frivolous or vexatious; providing access would have an unreasonable impact on the privacy of other individuals; providing access would pose a serious threat to the life or health of any person or to public health or safety; or giving access would be unlawful.

If you believe that the personal information we hold about you requires correction, you may request that the information be corrected using our contact details below.

If we refuse your request for access or correction, we will provide you with reasons for the refusal in writing, and details about how you may complain about the decision. If we refuse your request for correction, you may request that we attach to the information a statement of the correction sought.

 

The R-U-Ontrak Website and cookies

We may collect your personal information through the R-U-Ontrak Website, such as your email address or other contact details when you use or make an enquiry regarding R-U-Ontrak. We will deal with this personal information in accordance with this Policy and the law.

We also collect data through our use of ‘cookies’ and other internet technologies. ‘Cookies’ are small data files that your internet browser stores on your computer or other mobile device.  Cookies are stored in order for your internet browser to navigate a website and the cookies themselves cannot collect any information stored on your computer or other device.

We will not use cookies to collect your identifying personal information. The cookies may collect statistical information about your visit to the R-U-Ontrak Website (such as the pages you visit on the Website) in order to remember your preferences and provide you with a more user-friendly experience.

Some of the cookies may be ‘session’ cookies, which will be deleted when you have ended your internet session and close your browser. Other cookies are ‘persistent’ cookies which are stored on your computer or device until its designated expiration date (e.g. 6 months or 2 years).

The default settings of most internet browsers is to accept cookies automatically, but you can actively delete or disable cookies by changing your browser settings.

 

Anonymous usage data

When you use R-U-Ontrak, we may use analytics tools to receive anonymous usage data and statistics, such as when R-U-Ontrak is being used, the country R-U-Ontrak is being used in, the type of device being used to access R-U-Ontrak, and reports of any crashes of R-U-Ontrak.  We use this data to improve R-U-Ontrak.  We will not collect your identifying personal information when we use these analytics tools.  The analytics tools we may use include:

 

Complaints

We respect your privacy and we take all complaints and concerns regarding privacy very seriously.

If you have any complaints or concerns regarding the way we handle your personal information please contact us using the details below.

We will investigate your complaint using our internal processes, under which we will assess your complaint and respond to you within a reasonable time.

If you are not satisfied with the outcome of our investigation, you may wish to contact the Commonwealth Office of the Australian Information Commissioner (OAIC). See www.oaic.gov.au.

 

If you are a NZ User, you may wish to contact the Office of the Privacy Commissioner. See www.privacy.org.nz.

 

Our contact details

If you:

  • would like to request access to or correction of your personal information;

  • would like further information about our privacy policies and procedures; or

  • have any complaints or concerns regarding your privacy,

please contact us using the following details:

The Privacy Officer

R-U-Ontrak Pty Ltd

Suite 3, 60-64 Railway Road, Blackburn, Vic 3130

 

or

 

Email the Privacy Officer at: hello@r-u-ontrak.com

 

Changes to this Policy

We may revise this Policy from time to time. We will update you on any changes to this Policy through the R-U-Ontrak App and Website.

Version Number 29.05.20 V6

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