CARER’S NOTEBOOK PRIVACY POLICY
(a) Our website www.carersnotebook.com.au (Site), the mobile application (Carer’s Notebook App) and the Services made available through the Carer’s Notebook App and Site are created and controlled by The Facere Group Pty Ltd (ACN 669 460 360) (Carer’s Notebook, our, us or we).
(b) Carer’s Notebook is committed to ensuring your Personal Information is protected. We manage your Personal Information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).
(c) By accessing and using the Site, Carer’s Notebook App and Services you agree to this Privacy Policy.
(d) This Privacy Policy outlines how Carer’s Notebook collect, store, process, share, use and disclose your Personal Information, and how you may access your Personal Information kept by us or how you may make a privacy complaint.
(e) For the purpose of this Privacy Policy:
(i) Collaborator means a user of the Carer’s Notebook App who is authorised or has been invited to access the Carer’s Notebook App and Services by the account owner.
(ii) Dependant means an individual who relies on support from another individual (such as a family member or carer) as they are unable to independently support or care for themselves without aid or support from a family member or carer;
(iii) Services has the meaning in the Carer’s Notebook App User Terms and Conditions;
(iv) Personal information has the same meaning that it has under the Privacy Act, namely, information means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and recorded in a material form or not; and
(v) Sensitive Information has the same meaning that it has under the Privacy Act, namely information or opinions about your health, political affiliations, sexual preferences, religious beliefs, racial or ethnic origin, criminal history or other such private information.
(f) A reference to ‘Personal Information’ in this Privacy Policy includes ‘Sensitive Information’ except where otherwise indicated and a reference to ‘you’ includes a ‘Collaborator’ except where otherwise indicated
2. The information Carer’s Notebook collects from you
2.1. Personal Information
(a) Carer’s Notebook collect and use Personal Information and Non-Personal Information from visitors to our Site, users of the Carer’s Notebook App and Services and Dependants whose Personal Information is published or uploaded by users to the Carer’s Notebook App, and any other individual who interacts with us.
(b) Carer’s Notebook will only collect and hold Personal Information from you and your Dependants that are reasonably necessary to undertake our business activities and functions, make the Carer’s Notebook App and Site available to you and deliver our Services to you, or as otherwise permitted by law.
(c) The type of Personal Information and non-Personal Information that Carer’s Notebook collects and uses depends on the type of dealings that you have with Carer’s Notebook and includes the following:
(i) your contact details and account registration information (for example, username, mobile phone number, email address or password);
(ii) general information about your Dependants (for example, full name, gender, date of birth and age)
(iii) health, medical and pharmaceutical related information and data about your Dependants (including, but not limited to, your Dependants’ treating medical practitioners and medical history (such as their height, weight, blood pressure, blood type, fluid intake and output, temperature, blood oxygen saturation, medications, allergies, dietary and nutritional information), notes relating to Dependants’ symptoms or diagnosis, specialist reports and test results, specialist and healthcare professional referrals, medical certificates, information about healthcare services your Dependants have received or are scheduled to receive, healthcare plans, action plans, photographs, videos, prescriptions and other pharmaceutical purchases and usage, hospital admission and discharge letters, demographic information, healthcare interventions, requests and recommendations, power of attorneys and advanced care directives and any other health and medical records, or any other data or information that is or may be deemed to be Personal Information or Sensitive Information;
(iv) marketing data and information relating to your dealings, or enquiries you have made, with us, including information about: (i) the Services you have used; and (ii) the third party products and services you have used or enquired about;
(v) device information which is automatically collected from you when you visit and navigate through the Carer’s Notebook App and Site and use the Services. Such information may include, but is not limited to, your device type, your device’s network connections, unique device identifier, your device’s name, your device’s IP address, screen size and calibration, information about your device’s web browser and internet connection you use to access the Carer’s Notebook App, Site or Services, geolocation information, browser characteristics, device characteristics, operating system and language preferences, dates and times of visits to the Carer’s Notebook App, Sites and other usage statistics; and
(vi) other information that you provide to us or that we may collect in the course of our relationship with you.
(d) We may also collect some information that is not Personal Information because it does not identify you, your Dependants or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how you use the Carer’s Notebook App and Services.
(e) If you are a candidate seeking employment with us, we will use your Personal Information to process your application and assess your suitability for any role. We may retain your information for future reference.
3. How Carer’s Notebook collects Personal Information
3.1. Direct collection from you
(a) We will collect Personal Information and non-Personal Information about you or your Dependants in a number of different ways. We may collect Personal Information and non-Personal Information about you or your Dependants directly from you or in the course of our dealings with you. For example, when:
(i) you setup and create a profile on the Carer’s Notebook App (including when you edit or update your profile on the Carer’s Notebook App or reset your password) and when you access and use the Carer’s Notebook App and Services (including when you upload, publish, download and edit data and information about your Dependants on, or via, the Carer’s Notebook App);
(ii) you visit, access and use our Site;
(iii) you visit the Carer’s Notebook App, our Site or submit information through the Carer’s Notebook App or our Site or complete any online forms or documents or when you enter or participate in competitions, promotions, events, sweepstakes, surveys and questionnaires; and
(iv) you otherwise contact, interact or communicate with us (such as by telephone, email or in person) with a query or request or make a comment on our social media sites or lodge a complaint about another user Carer’s Notebook App on, or via, the Carer’s Notebook App, by email, by telephone or through the Site; and
(v) from publicly available sources of information.
3.2. Collection from third parties
(a) We may also collect Personal Information about you from publicly available sources and third parties, including:
(i) when you provide your Personal Information to third parties (including to our related bodies corporate, business partners, service providers and third party contractors);
(ii) if you use our social media sites or applications or other third party products and services that interact with, or connect with, the Carer’s Notebook App and Site.
(iii) if third party payment processors are used by us to process payments made by you.
(b) When Carer’s Notebook collects your Personal Information from third parties, we shall take reasonable steps to make sure you are aware of the collection.
(c) If you provide us with Personal Information about another individual (as their authorised representative), we rely on you to:
(i) inform them that you are providing their Personal Information to us; and
(ii) advise them that they can contact us for further information.
(d) You must take reasonable steps to ensure the individual is aware of, and consents to, the matters outlined in this Privacy Policy, including that their Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual’s right to access that information, and who we are and how to contact us.
4. How Carer’s Notebook use your Personal Information
4.1. Purposes of use and disclosure
(a) Carer’s Notebook only use, process and disclose your and your Dependants’ Personal Information for the purposes for which it is collected.
(b) We use, process and disclose your Personal Information and Non-Personal Information to provide or deliver the Carer’s Notebook App, the Services and our other products or services to you.
(c) We also use, process and disclose your and your Dependants’ Personal Information (excluding Sensitive Information) and Non-Personal Information:
(i) to assist with, or respond to, your queries or respond to, or investigate, complaints raised by you about the Carer’s Notebook App, the Services, our other products or services or other users of the Carer’s Notebook App;
(ii) to conduct performance analytics activities (for example, we use your Personal Information (excluding Sensitive Information), in aggregated anonymised form, to improve Carer’s Notebook App, the Services, our other products or services and the quality of our data, to develop new products and services that meet your needs and understand and manage our risk better);
(iii) to manage, administer, improve, test, develop and upgrade the Carer’s Notebook App and our other products and services (including customising the advertising and content on the Carer’s Notebook App), informing you about scheduled maintenance or outages and managing our relationship with you;
(iv) to inform you about the Carer’s Notebook App, the Services, our other products or services or about offers, competitions, promotions, events, sweepstakes, surveys, questionnaires about us, the Carer’s Notebook App, Services, or other matters which we believe are of interest to you (such as recruitment or job opportunities);
(v) to verify your identity;
(vi) to conduct fraud, risk reduction and creditworthiness checks;
(vii) to perform research and analysis about the Carer’s Notebook App, Site and Services and for data analytics purposes, including usage patterns, trends, benchmarking and other statistical or behavioural data. Before we use your Personal Information for this purpose, we ensure Personal Information is made anonymous by removing data that can identify you;
(viii) to charge and bill when you use the Carer’s Notebook App and Services;
(ix) for direct marketing purposes (see section 6 below);
(x) to comply with regulatory or other legal requirements,
(xi) for any purpose to which you have consented; and
(xii) for any other purpose notified to you at the time of collection.
(d) In the event of a merger, acquisition or sale of the whole or part of our business or assets, we reserve the right to transfer your Personal Information as part of the transaction, without your consent or notice to you.
4.2. Disclosure to third parties
(a) With your consent, we may provide your Personal Information and Non-Personal Information to the following recipients:
(i) our employees, related entities, business partners, third party contractors, suppliers and agents from time to time for the purpose of delivering, providing and administering the Services (including customer support services and setup services), the Carer’s Notebook App, our Site, our promotions, deals and competitions;
(ii) third party service providers who process or use your Personal Information and Non-Personal Information for the purpose of performing functions on our behalf, but may not process or use such information for any other purpose. Examples of these third-party service providers include, but are not limited to, such as cloud-based accounting software platform, marketing and analysis organisations, financial and credit card institutions to process payments, third party payment processors, hosting companies, web and app developers, e-marketing platforms, internet service providers, customer service providers, customer support specialists, fulfilment companies and research and data analysis firms, government agencies, public registries, search agencies, regulatory and licensing bodies, parties to whom you refer us (for example, previous employers and referees); and
(iii) external business advisors, such as auditors, lawyers, insurers and financiers,
(collectively, Authorised Affiliates).
(b) When we disclose your Personal Information to any of our Authorised Affiliates, we will ensure that they undertake to protect your privacy. Authorised Affiliates are not permitted to use the information for any purpose other than the purpose for which they have been given access.
(c) Our Authorised Affiliates may also provide us with Personal Information collected from you. If you disclose Personal Information to an Authorised Affiliate, we rely on you to provide the Authorised Affiliates with consent for us to collect, storage, use, process, alter and disclose your Personal Information.
(d) Carer’s Notebook may also disclose any Personal Information we consider necessary to comply with any applicable law, regulation, legal process, governmental request or industry code or standard.
4.3. Third party payment processors
(a) Carer’s Notebook uses third party payment processors to process payments made to us. In connection with the processing of such payments, Carer’s Notebook do not collect, process, use, share, store or disclose any payment information (such as credit card and bank account details). Rather, all such information is provided directly to Carer’s Notebook’s third party processors, Apple Pay, whose use of your Personal Information (including payment information) is governed by their privacy policy, which may be viewed at www.apple.com/au/legal/privacy/data/en/apple-pay/.
(b) Apple Pay does not collect a Collaborator’s payment information.
4.4. Overseas disclosure
(c) In the course of providing you with access to, and use of, the Carer’s Notebook App, Site and Services, it may become necessary or desirable to disclose Personal Information to Authorised Affiliates located overseas. The countries in which these overseas recipients may be located will depend upon the individual circumstances. However, in the course of our ordinary business operations we commonly disclose Personal Information (excluding Sensitive Information) to:
(i) our third party payment processors located in the United States and elsewhere outside of Australia; and
(ii) our website and app developers (including website and app testers) located in Australia, India, Philippines, Sri Lanka and Vietnam.
(d) The laws where these overseas recipients may be located provide various levels of protection for Personal Information which are not always equivalent to the level of protection that may be provided for in Australia. Where we transfer your Personal Information overseas, Carer’s Notebook will take reasonable steps to ensure that your Personal Information is treated securely, and the means of transfer provides adequate safeguards.
(e) By accessing or using the Carer’s Notebook App, Services and/or Site, or providing your Personal Information to us, you explicitly and freely consent to the transfer of your Personal Information to our overseas Authorised Affiliates. If you do not wish to receive information from any of our Authorised Affiliates, please let us know using the details below. However, if you do not provide your Personal Information to us or our Authorised Affiliates, we may not be able to provide you with access to, and use of, the Carer’s Notebook App, the Services or Site.
4.5. Disclaimer
(a) Carer’s Notebook will not disclose your Personal Information to any third party (other than our Authorised Affiliates) without your written consent, unless:
(i) we are otherwise required by the relevant Privacy Laws;
(ii) we are permitted to under this Privacy Policy; or
(iii) such disclosure is, in our opinion, reasonably necessary to protect our rights or property, avoid injury to any person or ensure the proper functioning of the Carer’s Notebook App and/or Site.
(b) This Privacy Policy only covers the use and disclosure of information we collect from you. The use of your Personal Information by any third party is governed by their privacy policies and is not within our control.
5. Notifiable Data Breaches Scheme
In the event of any loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, Carer’s Notebook will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with notifiable data breach scheme contained in Part IIIC of the Privacy Act.
6. Marketing communications
6.1. Direct marketing
(a) Carer’s Notebook may use and disclose your Personal Information to send you information about the Carer’s Notebook App, our Site and/or Services and any other products or services we may offer from time to time, as well as other information that may be of interest to you.
(b) These communications may continue, even after you stop using the Carer’s Notebook App, our Site and the Services.
6.2. Communication channels
(a) Carer’s Notebook may send this information to you via the communication channels specific at the time you provide your consent.
(b) These communication channels may include mail, email, SMS telephone, social media or by customising online content and displaying notices or advertising on the Carer’s Notebook App and Site.
6.3. Opting-out
You can opt out of receiving these communications by:
(a) Contacting us using the details set out in section 11 below; or
(b) using the unsubscribe function in the email or SMS.
7. Storage and security
7.1. Protecting your Personal Information
(a) We take reasonable steps in the circumstances to keep the Personal Information and Non-Personal Information of you and your Dependant(s) safe. We use a combination of technical, administrative, and physical controls to protect and maintain the security of your Personal Information.
(b) Our officers, employees, agents and third-party contractors are expected to observe the confidentiality of your Personal Information and Non-Personal Information.
(c) Wherever possible, we procure that Authorised Affiliates who have access to the Personal Information and Non-Personal Information of you and your Dependant(s) take reasonable steps to:
(i) protect and maintain the security of your Personal Information and Non-Personal Information; and
(ii) comply with the Australian Privacy Principles when accessing and using your Personal Information.
7.2. No guarantee
(a) The transmission of information via the internet is not completely secure. While we do our best to protect your and your Dependant’s Personal Information and Non-Personal Information, we cannot guarantee the security of any Personal Information and Non-Personal Information transmitted through the Carer’s Notebook App or Site.
(b) You provide your and your Dependant’s Personal Information and Non-Personal Information to us at your own risk, and we are not responsible for any unauthorised access to, and disclosure of, your and your Dependant’s Personal Information and Non-Personal Information.
7.3. Destruction of Personal Information
We will destroy or de-identify Personal Information where it is no longer required, unless we are required or authorised by law to retain the information. However, Carer’s Notebook may retain Personal Information (including basic registration information) in accordance with documentation retention and destruction laws.
8. Accessing and correcting your Personal Information
(a) Carer’s Notebook shall use our reasonable endeavours to keep your and your Dependants’ Personal Information accurate, up-to-date and complete.
(b) You have the right to access any Personal Information we hold about you, subject to some exceptions under the Privacy Act.
(c) You have the right to access any Personal Information we hold about you and/or your Dependants, subject to some exceptions under the Privacy Act. We reserve the right to require proof from you that you are authorised to access the Personal Information of your Dependants.
(d) You can access, or request that we correct, your and/or your Dependants’ Personal Information by writing to us using the details set out in section 11 below. Carer’s Notebook may require proof of identity. If we do not allow you to access any part of your Personal Information, we will tell you why in writing.
(e) We will not charge you for requesting access to your and/or your Dependants’ Personal Information but may charge you for our reasonable costs in supplying you with access to this information.
(f) We will endeavour to respond to your request for access or correction within 30 days from your request.
9. Cookies policy
9.1. Cookie
(a) Carer’s Notebook and its Authorised Affiliates may collect information by automated means when you access and use the Carer’s Notebook App or Site by utilising features and technologies of your internet browser, including cookies and similar technologies. A cookie is a piece of data that enables us to track and target your preferences.
(b) The type of information we and our Authorised Affiliates collect may include statistical information, details of your operating system, location, your internet protocol (IP) address, the date and time of your visit, the pages you have accessed, the links which you have clicked and the type of browser that you were using and browser and login authentication status.
(c) We may use cookies and similar technologies to:
(i) enable us to identify you as a return user, make it easier for you to login to the Carer’s Notebook App and personalise and enhance your experience and use of the Carer’s Notebook App or Site; and
(ii) help us improve our Service to you when you access the Carer’s Notebook App or Site and to ensure that the Carer’s Notebook App and Site remain easy to use and navigate.
(d) Most browsers are initially set up to accept cookies. However, you can reset your browser to refuse all cookies or warn you before accepting cookies.
(e) If you reject our cookies or similar technologies, you may still use the Carer’s Notebook App or Site but may only have limited functionality of the Carer’s Notebook App or Site.
(f) We may also use your IP address to analyse trends, administer the Carer’s Notebook App, our Site and other websites we operate, track traffic patterns and gather demographic information.
9.2. Apple Analytics
(a) Services that Carer’s Notebook App may use from time to time include Apple Analytics, which transmits website traffic data to Apple servers. Apple Analytics does not identify individual users or associate your IP address with any other data held by Apple. We use reports provided by Apple Analytics to help us understand traffic and usage on the Carer’s Notebook App. By using the Carer’s Notebook App you consent to Apple processing your data in the manner described in Apple’s Privacy Policy (https://www.apple.com/legal/privacy/) and for the purposes set out in this Privacy Policy.
10. Privacy complaints
(a) If you have any issues about this Privacy Policy or the way Carer’s Notebook handle your and your Dependants’ Personal Information, please contact us using the details below and provide full details of your complaint and any supporting documentation.
(b) At all times, privacy complaints:
(i) will be treated seriously;
(ii) will be dealt with promptly;
(iii) will be dealt with in a confidential manner; and
(iv) will not affect your existing obligations or your commercial arrangements with us.
(c) Our Privacy Officer will endeavour to:
(i) respond to you within 15 business days; and
(ii) investigate and attempt to resolve your concerns within 30 business days or any longer period necessary and notified to you by our Privacy Officer.
(d) If you are dissatisfied with the outcome of your complaint, you may refer the complaint to Office of the Australian Information Commissioner.
11. How to contact us
Carer’s Notebook can be contacted by email at contactus@carersnotebook.com.au.
12. Changes to this Privacy Policy
(a) From time to time, it may be necessary for us to review and revise our Privacy Policy. We may notify you about changes to this Privacy Policy by posting an updated version on the Carer’s Notebook App and/or our Site.
(b) We encourage you to check the Carer’s Notebook App and/or our Site from time to time to ensure you are familiar with our latest Privacy Policy.