At InnoWell, we care about your data and we want you to be able to know and understand how we collect, use and disclose your personal information when you use the InnoWell website.

We’ve provided the essential information that you need to know in each of the items below. If you would like to dive into the issues that matter to you in more detail, click the heading to jump around this policy.

The Essentials

 

1. About this Policy

The policy sets out how we collect, use and disclose your personal information that is provided through our website. Our privacy policy that relates to the personal information you share with us through our platform is available here.

2. About InnoWell

We own and operate the InnoWell website which provides information about our platform and the service we provide. Our platform is a customisable digital platform that helps you to manage mental health and wellbeing with the help of your care service provider, friends and family.

3. How do we collect your data?

We collect your personal information when you share it with us through our website and through the use of cookies.

4. How does InnoWell use my personal information?

We mainly use your information to provide our business services to you.

5. How do you disclose my personal information?

We may disclose your information as required by law or to our advisers and consultants who assist us in providing our business services.

6. How do you keep my personal information secure?

We implement strict technical and procedural controls to protect your data from unauthorised access or disclosure.

7. Links to third party websites/platforms

Our website may contain links to third party websites who’s privacy practices we are not responsible for and have no control over.

8. How can I correct my personal information?

You can manage your personal information by contacting us at [email protected].

9. When is my data deleted?

We delete your data when it is no longer required for the purpose it was collected.

10. How do you deal with data breaches?

We will notify you and the OAIC of any unauthorised use or disclosure of data and take steps to remedy any data breach.

11. Who do I contact if I want to make a complaint?

You can contact [email protected] if you have any questions, complaints or feedback about your personal information or how we manage personal information.


About this policy

The Privacy Act 1988 requires organisations that are bound by the Australian Privacy Principles (APPs) to have a privacy policy. This privacy policy sets out the way in which we collect and handle personal information.

We may amend or update this policy from time to time. If this happens, we will publish any updates on our website. If you do not agree with the changes, you must cease accessing the website. If you continue to access or use the website after the changes come into effect, we will assume that you have agreed to them.

What is InnoWell?

InnoWell delivers digital health solutions to promote mental health and wellness and help people receive the right care at the right time. InnoWell is the owner of the InnoWell platform. More information about InnoWell can be found here.

References in this policy to ‘we,’ ‘our’ or ‘us’ means InnoWell Pty Ltd ACN 617 239 166.

How do we collect your data?

The main way we collect personal information about you is when you provide it to us. For example, when you use our website and share personal information with us via the website, communicate with us, participate in one of our surveys or interact with our website and advertising materials.

What type of information does the InnoWell website collect about you?

The InnoWell website collects data in order to provide services to you. These include:

  1. Technical data – the website gathers technical data through browsing and usage information, in particular via the use of cookies. Cookies are small data files transferred onto computers or devices by websites which tell us when you visit our website, the pages you visit and the information you download. They also remember your preferences and details so you can easily continue your browsing session when you return to our website. Acceptance of these cookies is required in order to use the website. The website also collects technical data associated with your smartphone, tablet or computer (such as IP addresses, access provider, hardware configuration, software configuration, country of origin), or associated with the website (such as log and history of all data exchanges, log and history of connections);
  2. Identity data – the website collects personal data when you submit a contact form. This data includes information about your identity such as full name and email address, details of products or services which we have provided to you or about which you have enquired and information contained in any communications between you and us; and
  3. Behavioural data – the website automatically collects behavioural data, including but not limited to data on location, device (phone, tablet or computer) and usage.
How does the InnoWell website use personal information?

We collect and use your personal information, lawfully and fairly, so we can perform our business activities and provide you with the platform services. We use personal information for several other related purposes, including:

  1. to provide you with our products and services;
  2. to give you information about our products and services;
  3. to interact with you;
  4. to administer surveys;
  5. to conduct product and market research;
  6. to develop consumer insights so we can better understand your preferences and interests, personalise your experience and enhance the products and services you receive;
  7. to perform administrative and operational functions;
  8. to comply with any legal requirements;
  9. for any related purpose for which we are entitled to use your personal information; and
  10. for any other purpose for which you give your consent.
How do we disclose your personal information?

We may disclose your personal information for purposes permitted by the APPs. These include disclosure to the following third parties for the purposes described in this policy:

  1. our employees, related entities and employees of those entities;
  2. our business partners;
  3. our professional advisers, dealers and agents;
  4. third parties and contractors who provide services to us, including customer enquiries and support services, debt-recovery functions, technology service providers, marketing, and advertising;
  5. any third parties authorised by you to receive information held by us; and
  6. government, regulatory and law enforcement agencies as required, authorised or permitted by law.
How do we keep your personal information secure?

We take all reasonable steps to protect your personal information from misuse, interference and loss as well as from unauthorised access, modification and disclosure. We:

  • only store your personal information on computer systems located in Australia;
  • ensure that access to these systems is highly restricted and controlled;
  • implement organisational, physical and logical security measures;
  • use strong encryption to protect data communications between the platform services;
  • encrypt data traffic via the Internet between the website and the systems; and
  • limit access to your data only to staff who have a need to access your information to perform a specific task or function are granted access to such information.

InnoWell employees must abide by this privacy policy and are kept up-to-date on security practices.

Although we take appropriate measures to safeguard the security of your personal information we cannot guarantee its security. To assist in preventing unauthorised use or disclosure of your personal information, you can protect your smart device (phone, tablet or computer) by use of a PIN code to restrict unauthorised access to your smart device.

In the event of any data breach, we will follow the specific requirements of the Privacy Act 1988 and the Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth) and notify you and other affected individuals as appropriate.

Note however, that your use of an Internet Service Provider (ISP) will be subject to the separately-provided terms of use of such services. In particular, note that any data processing and/or transmission of data by the ISP are outside the scope of this policy and not the responsibility of InnoWell.

Links to third party websites/platforms

Our website may contain links to websites, other apps and social media platforms operated by third parties.

Those links are provided for convenience and may not remain current or be maintained. Unless stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites.

The privacy policies that apply to third parties’ websites may differ substantially from this Policy, so we encourage you to read those privacy policies before using those websites.

How can you access and correct your personal information?

If you think that your personal information provided to us via the website is inaccurate, please get in touch by emailing [email protected] and we will take reasonable steps to ensure that it is corrected.

In order to protect your personal information we may require identification from you before changing or releasing any requested information.

You can request access to the personal information you provided us via the website also by emailing [email protected].

While we try to give you access to your personal information free of charge, we may charge you a reasonable fee to cover costs associated with:

  1. searching for, locating and retrieving your personal information; and
  2. reproducing and sending you your personal information.

In certain circumstances, we may not be able to give you access to your personal information. In these circumstances, we will write to you to explain why we cannot comply with your request.

How and when is my data deleted?

We are required by the Privacy Act 1988 to notify you and the Office of the Australian Information Commissioner in the event of a serious data breach, for example if a database containing personal information is hacked or personal information is mistakenly provided to the wrong person.

Our notification to you will be sent as soon as practicable and will contain:

  • a description of the data breach;
  • the kinds of information concerned; and
  • the steps we have or will take to rectify the data breach; and
  • recommendations about the steps you should take in response to the data breach.
Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our privacy policy or InnoWell’s privacy practices please contact us at:

InnoWell Privacy Officer

Call:
+61 2 8627 6933

Email:

[email protected]

Write:

InnoWell Pty Ltd,
Shop 1-3 66-70 Parramatta Road,
Camperdown
NSW 2050
Australia

We will quickly acknowledge access or correction requests, or complaints, and use our best endeavours to respond fully within 30 days of receipt of your request.

If you think that we have failed to resolve a complaint satisfactorily or you still have a concern, or would like more information you can contact the Office of the Australian Information Commissioner in any of the following ways:

Office of the Australian Information Commissioner

Online: https://www.oaic.gov.au/individuals

Call:
1300 363 992

Email:
[email protected]

Fax:
+61 2 9284 9666

Write:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney
NSW 2001
Australia

(or GPO Box 2999, Canberra ACT 2601, Australia)

Last update of these Terms of Use: 25 September 2019