About us and this Policy
R-U-Ontrak Pty Ltd (we, us or our), owner and operator of the R-U-Ontrak app and the R-U-Ontrak website, is committed to the protection of your personal information.
R-U-Ontrak allows you to provide personal information such as your name, location, and details of any goals and any minor injuries (‘tweaks’) you may have. This information will allow you to monitor, manage, and/or track your progress in achieving a goal you have set for yourself, and track your progress recovering from any tweaks you may have.
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) and, if you are using the R-U-Ontrak app or website in New Zealand (a NZ User) the Privacy Principles contained in New Zealand’s Privacy Act 1993 (APPs).
The APPs 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 (such as details of your injuries, your conditions or details of your interactions with health providers).
Why do we collect your personal information?
R-U-Ontrak allows you to:
provide personal information regarding your goals, and your management of these goals; and
provide personal information regarding your tweaks, and your management of these tweaks.
We collect your personal information so that you can effectively use R-U-Ontrak.
How do we collect your personal information?
We will collect your personal information directly from you through your use of the R-U-Ontrak app or website 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 the R-U-Ontrak app and website to you.
We will only collect your personal information and sensitive information where you have consented through your use of the R-U-Ontrak app or website, 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 chat feature of R-U-Ontrak you can connect to and communicate with other users of R-U-Ontrak, such as health service providers, trainers, coaches, and teams. So you can connect to other users we may collect personal information about you from other users (your name, email address and phone number, and optional business name and role), just as you may provide these details for other users.
R-U-Ontrak users will only be connected where a user’s invitation to chat is accepted by the recipient user. You agree that other R-U-Ontrak users may send you chat invitations. It is up to you whether to accept or decline any such invitation.
What types of personal information do we usually collect?
We may collect personal information such as:
your contact details, e.g. your email address and mobile phone number;
your age, weight, and height;
the details of your goals, and any actions you have taken in to achieve your goal (for example, the types of health providers you have seen);
the details of your tweaks, and any actions you have taken in to manage your tweak (for example, the types of health providers you have seen).
How do we use your personal information?
We use your personal information for the main purposes of providing you with information regarding your goals and your progress to achieving your goals, and providing you with information to track your tweaks. This occurs through the R-U-Ontrak app and website.
We may use your personal information (your name, email address and phone number, and optional business name and role) in order for you to use the chat feature of R-U-Ontrak and connect to and communicate with other users of R-U-Ontrak, such as health service providers, trainers, coaches, and teams.
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 may disclose your personal information to third parties where you have consented to let others track your goals or in order for you to use the chat feature of R-U-Ontrak. These third parties may include health service providers, coaches, teams, teachers, personal trainers, and family members.
When the tracking feature is used, the purpose of this disclosure is to allow these third parties to track your goals, and provide you with feedback or enter data on your progress. (You may also track other users of R-U-Ontrak in the same way with their consent.)
Any third parties that are tracking your goals will only be able to share or export your tracking information to another database with your consent. For example, we may share or export your information where you consent to your health provider including your tracking information in an electronic health record. (Note that we do not endorse any third parties nor are we responsible for their handling of your personal information once it is shared or exported outside of the R-U-Ontrak platform. Before you consent to provide your information to a third party database, you should familiarise yourself with any privacy policies of the third party.)
We will not disclose your personal information to any third parties unless you have consented through your use of the R-U-Ontrak app or website, or we are otherwise permitted or required to do so by law.
In accordance with the law, we will only disclose your personal information without your consent in circumstances 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.
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) protection to ensure that only you or persons you have authorised can access your information through the R-U-Ontrak app.
We also use a variety of physical and technological security measures 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 first use the R-U-Ontrak app, your personal information will be stored on your phone or mobile device only.
The R-U-Ontrak app and website will also allow you greater access to information where you agree to provide your information to us to include in our database. In that case, we will store your personal information in secure servers located in Australia and provided by a third party provider.
When the chat 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.
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.
We retain your personal information so that you can effectively use the R-U-Ontrak app and website to achieve your goals, and so that third parties authorised by you can track your goals.
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.
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 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.
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
What information is not personal information?
Information where we have removed any material that would reasonably identify a person (‘de-identified information’), is not personal information.
We may use de-identified information concerning your goals (that is, with all your identifying personal information removed) for the purpose of creating a greater database of goal information that you can access through the R-U-Ontrak app and website. For example, de-identified information may describe that 100 people sustained a particular type of injury and the time to achieve the same goal of those persons for that injury was on average two weeks.
We may share de-identified information concerning your injuries and Challenges (and that of other users of the R-U-Ontrak app and website) with third parties, such as:
health service providers;
academic institutions and other education providers;
government agencies; or
other for-profit and not-for-profit organisations.
The sharing of de-identified information with these third parties will be for the purpose of:
providing these third parties with information regarding the incidence and current management and/or prognosis of certain types of injuries, conditions and the common physical activity related goals;
to assist in the development of approaches to injury management, condition management and prevention of injury; and/or
to assist in the education of health, healthcare, wellness and fitness providers.
De-identified information will be stored in secure electronic servers located in the United States of America and provided by a third party.
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
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
Email the Privacy Officer at: email@example.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 01.12.17.V6