CANCERAID – PRIVACY POLICY

CancerAid Pty Ltd ABN 75 607 610 257 (we, us or our) understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing:

• our CancerAid training, support and education services for organisations such as employers or insurers (Organisations), and their personnel (Organisation Services);
• our web and mobile application to you (CancerAid App);
• our Aware by CancerAid questionnaire (Aware);
• our various CancerAid programs (CancerAid Programs), noting that our CancerAid Programs may be provided in conjunction with an Organisation with an existing relationship with the participant;
• you with support for the CancerAid App, a CancerAid Program or Organisation Services; or
• otherwise communicating with you or providing our products or services to you, (together, our Services).

This Privacy Policy takes into account the requirements of the Privacy Act 1988 (Cth) (the Australian Privacy Act) and the Australian Privacy Principles in Schedule 1 of the Privacy Act and the New Zealand Privacy Act 2020 (NZ Privacy Act) as applicable. The handling of your information, such as your health information, may also be subject to other Australian or New Zealand privacy laws, such as state and territory health record laws in New South Wales, Victoria and the Australian Capital Territory or the Health Information Privacy Code 2020 in New Zealand (together, Health Privacy Laws).

Types of information

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

Sensitive information: is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information.

Health information: is a sub-set of sensitive information under the Australian Privacy Act and is also used under Health Privacy Laws. For the purpose of our Services, health information is information or an opinion about your health, your expressed wishes about the future provision of health services to you, a health service provided, or to be provided, to you that is also personal information; as well as any other personal information collected to provide, or in providing, a health service to you.

Throughout this Privacy Policy, where we refer to “personal information” this includes sensitive information and health information. However, we also specifically refer to sensitive information and health information where relevant.

The people we collect personal information about

We may collect personal information about the following types of people:

• a user of our CancerAid App (Users);
• a person who participates in one of our CancerAid Programs (Participant);
• a person with a cancer diagnosis (Patient), noting that a Patient may be a Patient using our CanceAid App or a Patient participating in our CancerAid Programs (which makes them also a User or a Participant); and
• a person we communicate with at an Organisation (Organisation Personnel), who may or may not be a participant in Organisation Services.

How we collect personal information

We collect personal information in a variety of ways, including:

• Directly through sign-up for the CancerAid App: During the sign-up process for the CancerAid App you may provide personal information directly to us.
• Directly through a self-referral for a CancerAid Program: When you self-refer as a Participant for a CancerAid Program you will provide personal information directly to us.
• Directly through communication with you: When you request our assistance, such as via email or over the telephone you may provide personal information directly to us.
• Through your use of our website, App or program booking system: When you use our website, in your enquiries, when you are using the CancerAid App or a CancerAid Program booking system we may indirectly collect personal information about you.
• From Organisations:
  • When you are referred to us by an Organisation as a Participant for a CancerAid Program we will collect personal information about you from the Organisation provided that we understand you have consented to that information being shared with us.
  • When you, as Organisation Personnel, have your contact details shared with us by your Organisation for the purpose of communicating with you about the CancerAid Program(s) and/or the Organisation Services.
• From cookies and analytics providers: When you use our website, CancerAid App or online feature of a CancerAid Program we may collect personal information about you from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.

Note: If we collect personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have the required authority (i.e. you are their parent or legal guardian) or such person’s consent to provide the personal information to us, in accordance with applicable laws or regulations (including notifying the individual concerned of all the information required for collection under the applicable Health Privacy Law), and that our use in accordance with this Privacy Policy of the personal information provided by you will not infringe any rights of the relevant individual or violate any applicable laws or regulations.

The information we collect

Personal information: We only collect personal information for the purposes described below that are connected with a function of our business or the performance of our Services. The types of personal information we may collect about you include:

As a CancerAid App User:

• your email address;
• as a Patient, any health information you enter into the CancerAid App such as symptom data and medication information;
• details of any technical support requests made by you, and the assistance provided by us;
• details of products and services we have provided to you and/or that you have enquired about, and our response to you;
• your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
• information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
• additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
• any other personal information requested by us and/or provided by you or a third party.

As a CancerAid Program Participant:

• your full name;
• your contact details, including your email addresses (personal and work) and telephone number;
• your date of birth;
• your state or region;
• your date of illness or injury;
• your insurance claim number;
• information about your health whether provided to us by you or provided by the relevant Organisation;
• the dates and times of bookings with our coaches;
• records of your CancerAid Program sessions, including notes about what was discussed;
• details of any technical support requests made by you, and the assistance provided by us;
• your preferences and/or opinions with respect to our Services;
• information you provide to us through feedback, enquiries or customer surveys;
• details of products and services we have provided to you and/or that you have enquired about, and our response to you;
• when you use an online aspect of a CancerAid Program,
  • your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
  • information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
  • additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
• any other personal information requested by us and/or provided by you or a third party.

As Organisation Personnel:

• your name;
• your contact details, including email address and/or telephone number;
• the Organisation you work for;
• your job title;
• your preferences and/or opinions about our Services;
• information you provide to us through feedback, enquires or customer surveys;
• details of products and services we have provided to you (including things like training or workshops) and/or that you have enquired about, and our response to you; and
• any other personal information requested by us and/or provided by you or a third party.

As a user of our website:

• your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
• information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
• additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
• any other personal information requested by us and/or provided by you or a third party.

As a user of Aware:

• we do not collect any personal information when you use our Aware questionnaire. All information provided by you when participating in the Aware questionnaire is only utilised to prepare the Aware questionnaire response, and is immediately deleted. In any event, the information collected is not identifiable.
• once you leave the Aware webpage to book in an appointment with SwiftDoc, you acknowledge you will be subject to SwiftDoc’s Privacy Policy, available on their website: https://swiftdoc.com/.

Purposes for the collection, use and disclosure of personal information

Personal information

We may collect, hold, use and disclose personal information for the following purposes:

• to provide our Services to you, including to:
  • as a User, enable you to access and use our CancerAid App, including to provide you with a login;
  • as a User of the CancerAid App, to allow you to share your information with other Users of your choosing;
  • as a CancerAid Program Participant, to allow you to book and manage your coach meetings;
  • as a CancerAid Program Participant, to carry out your coach meetings, provide any other included services and communicate with you about your CancerAid Program;
• to contact and communicate with you about our Services, including to
  • to send you marketing material and promotional information about our products and services and information about third parties that we consider may be of interest to you;
• for internal record keeping, administrative, invoicing and billing purposes;
• for analytics, market research and business development, including to operate and improve our Services and associated applications;
• at your request, to refer you to a third party provider;
• to run promotions, competitions and/or offer additional benefits to you;
• to comply with our legal obligations and resolve any disputes that we may have;
• if you have applied for employment with us; to consider your employment application; and
• if otherwise required or authorised by law.

Sensitive information + Health Information

We only collect, hold, use and disclose sensitive information, including health information, for the following purposes:

• where you are a CancerAid Participant and your provider funds your participation in the CancerAid Program they may require that we provide information back to them about your participation in the program so that they can assess your engagement in the program and identify additional services that may be of benefit to you. Please check the privacy collection notice provided to you and/or the terms and conditions for your particular CancerAid Program to see if we are required to disclose your information to the Provider;
• any purpose you consent to, for example where you as a CancerAid Program Participant consent to us disclosing your personal information or outcomes from your CancerAid Program sessions with the relevant Organisation funding your participation in the CancerAid Program;
• the primary purpose for which it is collected, which may be as follows:
  • as a Patient User of the CancerAid App to allow you to log your health information;
  • as a Patient User of the CancerAid App, to allow you to share your health information logged in the CancerAid with other Users of your choosing;
  • as a CancerAid Program Participant, to book your coach sessions;
  • as a CancerAid Program Participant, to provide you with coaching, support or advice;
• secondary purposes that are directly related to the primary purpose for which it was collected, including disclosure to the below listed third parties as reasonably necessary for or directly related to the purpose for which it was collected;
• to contact emergency services, or to speak with relevant authorities, employers, providers, your family, partner or support person where we reasonably believe there is a serious risk to the life, health or safety of you or another person and it is impracticable for us to obtain your consent; and
• if otherwise required or authorised by law.

Disclosure of personal information to third parties

We will only disclose personal information to a third party where we are permitted to do so by law or you have consented. The types of third parties that we may disclose personal information to, include:

• third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation):
  • web-hosting and server providers that host on servers located in Australia for program delivery, email messaging and information storage;
  • IT service providers for development, deployment, program delivery, error monitoring and maintenance of the CancerAid App and CancerAid Program technology stack;
  • our email communication provider;
  • our telephone call and messaging provider;
  • our CancerAid Program calendar booking provider;
  • marketing and/or advertising providers,
  • professional advisors, such as lawyers and accountants;
• third party service providers for the purpose of obtaining medical opinions at your request;
• our employees, contractors and/or related entities;
• our existing or potential agents or business partners;
• sponsors or promoters of any promotions or competition we run (this does not include health information);
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights, including any right to payment;
• third parties to collect and process data, such as Google Analytics (please see below for further information), and/or other relevant analytics businesses; and
• any other third parties as required or permitted by law, such as where we receive a subpoena.

Overseas disclosure:

Where we disclose your personal information to third parties listed above, these third parties may store, transfer or access personal information outside of Australia including but not limited to, the United States of America.

We will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the privacy laws we are obliged to comply with or we will take such steps as are reasonable in the circumstances to ensure that those third parties protect and handle the personal information in a manner that is consistent with the principles contained in the Australian or New Zealand privacy laws applicable to our handling of your personal information.

Google Analytics:

We have enabled Google Analytics Advertising Features. We and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to charge a fee for access or to withhold access to your personal information.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. You also have the right to contact the relevant privacy authority.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, to the fullest extent permitted by law we do not guarantee the security of any information that is transmitted to or by us over the Internet, and the transmission and exchange of information is carried out at your own risk.

We will retain personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Cookies

We may use cookies on our online Services from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. If and when you choose to provide our online Services with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online Services.

Links to other websites

Our Services may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website at www.canceraid.com.au. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

If you have questions about our privacy practices, please contact our Privacy Officer at:

CancerAid Pty Ltd ABN 75 607 610 257
Address: The Privacy Officer, CancerAid Pty Ltd, National Innovation Centre, 4 Cornwallis St, Eveleigh NSW 2015, Australia
Email: contact@canceraid.com

Last update: 30 June 2022