Privacy Policy

Last updated: 26 August, 2019

Carefactor Life Pty Ltd ABN 92 607 608 346(“Carefactor”, “us”, “we”, or “our”) operates the Carefactor mobile application (“the App”) and the carefactor.life website (“the Website”). The App and the Website enable certain functionality which is the Services.

This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our App and the Website.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

Changes to this Privacy Policy are effective when they are posted on this page.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

Terminology

Member – The person who registers an account with us so they can use the App, the Website and the Services.

Care Focus – The individual (who may, or may not, be a Member) who is the focus of care of a Member(s).

Care Family – Relating to a specific Care Focus, it is the group of Members who have access to the Care Focus’ information stored by us.

Contacts – Relating to an identifiable person or service.

What Information we collect

Personal Information

You may browse the Website and download the App without providing us any Personal Information that expressly identifies you, however, in order to make full use of the App, you will be required to register with us. Personally identifiable information may include, but is not limited to, your email address, name and postcode (“Personal Information”).  To register as a Member, you need to provide your email address and you will need to provide a password. If you elect to enter any other Personal Information in the App we will collect that information and use it and share it as set forth below.  By using the App and the Website, you agree to the collection and use of information in accordance with this policy.

As a Member, you may also set up Care Focus’ and Contacts in the App.  A Care Focus may be yourself or a child, parent or other you care for.  When you set up a Care Focus or Contact we will collect and store any Information that you may elect to provide to us.  If the Care Focus is not the Member then consent should exist for the Member to set up the Care Focus from whom the Care Focus relates to.

Non-Personal Data

We may also collect information that your browser sends whenever you visit our Website (carefactor.life) or use our App.

This Log Data may include information such as the device’s (“IP”) address, geolocation, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.

When you access the Service through the App, this Log Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, geolocation, your mobile operating system and other statistics.

Analytic services enable us to monitor and analyse App usage and Website traffic and can be used to inform us of user behaviour. Our App and Website use third party services to collect, monitor and analyse this type of information in order to increase our App and Website functionality. This information is only used to improve the functionality of our App and Website.

Log data and the use of analytics are all reasonably necessary in order for us to provide the functionality of the Services to you.

How we use your Information

The purpose for which we collect Personal Information is to provide you with the best experience possible in relation to the Services, and for our internal business purposes that form part of normal business practices. Some provision of personal information is optional.

We do not and will not sell your Personal Information. We will use any Personal Information in your Account as well as information you provide the Services, complete your transactions, administer your inquiries, and present you with offers for products and services that we think may be of use or interest to you.

All Members may review, update, correct or delete their Account information and any associated Personal Information by contacting us or by accessing the App. If you would like to close your Account or delete any information from your Account, please contact us at info@carefactor.life

Information sharing and disclosure

Members: In the event that a third party registers for access to the App pursuant to an invitation issued by you, we will provide them with access to Care Focus and Contact information related to such specified by you. We cannot control how any Member may use or disclose or otherwise exploit any Personal Information or other content you may elect to make available to such party. We endeavour to provide clear information about consent and information sharing to enable decisions about information sharing. Any information you choose to provide and make available to third parties (including other Members) via the App should be limited to how much you want others to know about you and the individual who is the subject of the Care Focus.

Other Third Parties: If you elect to use or otherwise take advantage of some of the other third party services that we may provide and make available to you, we will share certain of your information with such third party and will disclose to you at the time what information would be necessary to share with such third party.

Aggregate Information and Non-Identifying Information: We may share aggregated information that does not include Personal Information and we may otherwise disclose non-Personal Information with third parties for industry analysis, demographic profiling and other purposes.

Service Providers: We will disclose disaggregated Personal Information to the third-party service providers that we engage to assist us in making the Website, and the App available. These service providers consist of our cloud services provider, customer support system provider, email service providers, and software development contractors. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Business Transfers: We may sell, transfer or otherwise share some or all of its assets, including your Personal Information and related Care Focus, Contacts, Care Family and content, in connection with a merger, acquisition, reorganisation or sale of assets or in the event of bankruptcy.

Cross-Border Disclosure: By registering as a user of and accessing our Site and/or the App, you agree:

• to and authorise us giving your Personal Information, in accordance with this Privacy Policy, to a third party who is not in Australia or a third party who may transfer and store outside Australia your personal information (Overseas Recipient)
• that, while we will take reasonable steps to ensure that an Overseas Recipient does not breach Australian Privacy Principals, Overseas Recipients are not bound by the APPs and subclause 8.1 of the APPs does not apply to the disclosure of your Personal Information to an Overseas Recipient*; and
• that, if an Overseas Recipient handles your information in breach of the APPs, you will not be able to seek redress under the Act.

Subclause 8.1 of the APPs requires us to ensure that Overseas Recipients comply with the APPs unless, in accordance with subclause 8.2, you agree otherwise. For more information, please check the Office of the Australian Information Commissioner (OAIC) website.

Maintaining your Data

Australian Privacy Principle 6 of the Privacy Act 1988 (Cth) allows you to get access to, and correct, the personal information we hold about you in certain circumstances. If you would like to obtain such access, please contact us at info@carefactor.life

Please note that the access and correction requirements under this Privacy Policy operates alongside and do not replace other informal or legal procedures by which an individual can be provided access to, or correction of, their personal information, including the requirements under the Freedom of Information Act 1982 (Cth).

Information Storage and Security

After installing the App you will be asked to register and create a Care Focus. Any information you enter into the App will be managed and stored using the following security protocols:

• Information is encrypted and transferred from the App to our systems via SSL
• Passwords are encrypted using secure password hashing
• Login information and App content are stored in separate systems
• When a Care Focus is removed in the App, any information associated with that profile is permanently deleted from our systems
• The data is stored on secure servers in the USA.

The security of your Personal Information is important to us, but please remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. We use commercially acceptable means to protect your Personal Information, but we cannot assure its absolute security. In the event we become aware of a security incident, we will notify you to the extent required under the applicable law.

Retention of Information

In accordance with our legal obligations, we retain Personal Information about a Member for as long as it is required in order to fulfil the purpose of collecting it. Usually that means for as long as a Member has an active account. We may dispose of information at our discretion without notice, subject to applicable law that specifically requires the handling or retention of information. Additionally, we may de-identify the information at our discretion. You must keep your own, separate back-up records.

You can remove any Care Focus that you have created in the App at any time by selecting ‘Delete Care Focus’ in the App. This will permanently delete all information relating to the Care Focus from our systems.

Compliance with Laws

We may disclose Personal Information in special situations where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring or interfering (intentionally or unintentionally) with our rights or property, users or anyone else who could be harmed by such activities.

We will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of our Website and App.

Consent

You warrant that you are able to give consents under your country’s Law or, in the event that you do not have the capacity to give consent, you warrant that your guardian or attorney is able to give any consent required under this Privacy Policy on your behalf.

You hereby expressly and voluntarily grant your informed consent to us to deal with your Personal Information and Care Focus’ information in accordance with the terms and conditions of this Privacy Policy. Should you retract your consent, please contact us. If you retract your consent, you acknowledge and agree that failure to provide certain types of Personal Information may not give you access to the full functionality of the Website and the App.

In the event you set up a Care Focus that relates to someone other than yourself, you are solely responsible for ensuring that you have any and all consents and permissions to share that Personal Information with us and to use that information as part of the App.  Please see our Consent Guidelines for more information.

You may provide us with Personal Information of a third party, to access a Care Focus that you create. If you elect to invite any third party to access a Care Focus connected to your Account, we will ask you for that third party’s email address. We will send the third party emails inviting them to register for the App. We store this information for the sole purpose of sending this one-time email. The third party may contact us at info@carefactor.life to request that we remove this information from our database. We cannot control whether that third party will elect to register to become a Member.

Children’s Privacy

We do not knowingly collect personally identifiable information from children under 18 without parental or guardian consent. If you are a parent or guardian and you are aware that your children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children under 18 without verification of parental or guardian consent, we take steps to remove that information from our systems or replace it with the Personal Information of the Children’s parent or guardian.

Reporting a Problem

Australian Privacy Principle 1 of the Privacy Act 1988 (Cth) allows you to make a complaint about any alleged breaches of privacy. In order to lodge a complaint with us, please contact us using the details above with the following information:

• Your name and address;
• Details of the alleged breach of privacy; and
• URL link to the alleged breach of privacy (if applicable).
• Please allow us 30 days to investigate your complaint, after which we will contact you immediately to resolve the issue.
• If you are not satisfied with the handling of your complaint, you may also complain to the Office of the Australian Information Commissioner by contacting their Enquiries Line on 1300 363 992 or enquiries@oaic.gov.au

Contact Us

If you have any questions about this Privacy Policy, please contact us at info@carefactor.life