Liminal Wellbeing Privacy Policy

The Liminal Wellbeing mobile application and web dashboard application (collectively, LW App) is a platform offered by Liminal Group Pty Ltd (ABN 51 642 091 423) (LW, we, us or our) to assist Organisations in managing and monitoring the overall health and wellbeing of their people. Some Australian Organisations including educational institutes, community organisations, and companies (Organisation) encourage their people to use the LW App to monitor the overall wellbeing of their Organisation. This Privacy Policy explains how and what of your personal information (including sensitive information) we collect, use, share/disclose and how we manage your personal information as:

a individual using the LW App (User);
a wellbeing coordinator, manager, or teacher at the Organisation (Staff);
a person nominated by the Organsiation to have elevated privileges to the LW App (Admin);
a User’s parent or legal guardian/caregiver (Parent); and/or
a Visitor to our website, liminalwellbeing.com.au (Website).

We are bound by and adhere to the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) under the Act (together, Privacy Act), the Health Records Act 2001 (Vic), the Health Records and Information Privacy Act 2002 (NSW), the Health Records (Privacy and Access) Act 1997 (ACT) and this Privacy Policy.

By using the LW App as a User, Staff, Admin, or a Parent, accessing the Website as a Visitor or providing any personal information whether via the LW app, the Website or otherwise to us, you agree and consent to us (as operator of the LW App and Website) collecting, using, and sharing your personal information (including your sensitive information) in accordance with this Privacy Policy.

By using the LW App as a User, Staff, Admin or consenting to your child using the LW App as a Parent you also agree and consent to:

the LW App Terms of Use; and
your Organisation collecting, using, and sharing your personal information (including sensitive information) in accordance with this Privacy Policy and the privacy policy of your Organisation and/or its governing body’s privacy policy.

If you do not consent to collection, use, and disclose of your (and for Parents consenting on behalf of a child, your child’s) personal information in accordance with this Privacy Policy and/or the LW App Terms of Use then do not provide us with your personal information or use the LW App and ensure your child does not use the LW App.

If you are a User aged 15 years or under you must show this Privacy Policy to a Parent and obtain their expression consent to LW collecting, using, or sharing/disclosing your personal information in accordance with this Privacy Policy by completion, signing and return of the “Consent Form” prior to your access to the LW App and/or Website.

There is no obligation for you to provide us with any of your personal information but, if you choose not to provide us with your personal information, we will not be able to provide you or your Organisation the information or services that you or it requires.

What personal information is collected and how?

For Users

As a User, when you install and open the LW App for the first time you will be asked to set up your personal profile. When you do this, you will be asked to give us (and we will collect):

your first name and last name (or initial of your last name);
your email address (which you use to log in to the App);
your age (Date of Birth);
your gender;
your year level at school (if applicable); and
the name of the person who has been assigned as your buddy at your Organisation.

When you use the LW App we collect information about how you are feeling about relationships, sleep, emotion, learning, and exercise. Some of this is health information because it tells us about your mental/psychological health. Health information is a type of sensitive information which is also considered generally as personal information. If you upload a photo of your face as your profile image (optional), this is also sensitive information. For sensitive information we must be extra careful about; (a) collecting it from you; and (b) keeping it safe.

We collect your personal information so we can manage your profile on the LW App, understand your wellbeing and give reports about your wellbeing to your Organisation’s wellbeing team. If we don’t collect this information directly from you, it is because your Organisation has created your profile on the LW App.

For Parents

Where you agree to use the LW App on behalf of your child as a User, please also see the section immediately above for Users, which is applicable to you as a Parent consenting to the use of the LW App by your child as a User. We otherwise do not collect your personal information.

For Staff & Admin

As Staff, we collect your full name, email address, a profile image (optional) and a short bio either directly from you or from the Organisation so we can provide you with access to the LW App, create a profile for you, allow you to see wellbeing metrics and progress of Users and access/export reports about User’ wellbeing.

For Visitors

As a Visitor, we collect your personal information when you provide it to us on the Website (i.e. entering information into a form or making an enquiry) and/or if your otherwise contact us by phone, email or mail. As a Visitor, we also collect information through the use of cookies in accordance with the Cookies section below.

For Everyone

If you provide us with or request us to access the personal information of other you represent and warrant to us that; (a) you are authorised by that other person to provide us or collect (as the case may be) their personal information (including sensitive information); (b) you have referred them to this Privacy Policy and obtained their express consent to LW collecting, using and disclosing their personal information in accordance with this Privacy Policy and/or disclosing their personal information to you; and (c) you have complied and will comply with the APPs in collecting that personal information, whether or not you are otherwise required to comply with the APPs.

How your personal information is used

For Users

As a User, we use the personal information we collect about you for the purpose of operating the LW App, in particular to respond to your enquiries, help with login issues and for other purposes as permitted or required by law. Your personal information (including sensitive information) is used to understand and follow your wellbeing over time. We generate reports about your wellbeing and provide these reports to your Organisation and Staff (i.e. your Organisation’s wellbeing team). We also combine information about your wellbeing with information about others’ wellbeing and generate reports about how everyone is feeling over time.

For Parents

Where you agree to the use of the LW App on behalf of your child, please also see the section immediately above for Users, which is applicable to you as a Parent, consenting to the use of the LW App by your child as a User.

For Staff & Admin

As Staff, we use your personal information to create an account for you on the LW App and to provide you with access to Users’ wellbeing reports via the online password-protected dashboard and for other purposes as permitted or required by law.

For Visitors

As a Visitor, we use the personal information we collect from you for the purpose of responding to your queries after you contact us and for other purposes as permitted or required by law.

For Everyone

Occasionally, we may use your personal information for maintenance, support and troubleshooting of the LW App.

How your personal information is shared/disclosed

For Users

We will share information about your wellbeing with Staff (i.e. your Organisation’s wellbeing team). This is so they know how you are feeling and can look after you if you need help. Staff can export a PDF of wellbeing metrics based on your health information, which they may share with other people including your Admin and Parents. For information on how your Organisation uses and shares your personal information, please check your Organisation’s privacy policy or the privacy policy of your Organisation’s governing body.

For Parents

We do not collect your personal information. However, your Organisation may have collected your personal information and may use it to share reports with you about your child’s wellbeing. For information on how your Organisation uses and shares/discloses your personal information, please read your Organisation’s privacy policy or the privacy policy of the Organisation’s governing body. Where you agree to this Privacy Policy on behalf of your child, please also see the section immediately above for Users, which is applicable to you as a Parent consenting to the use of the LW App by your child.

For Staff & Admin

We may share your personal information with the Organisation that employs you so they can oversee and manage your use of the LW App in connection with your role at the Organisation (e.g. as part of the wellbeing team).

For Everyone

We also share your personal information for other purposes as permitted or required by law.

The App is hosted on infrastructure located in Australia and provided by Amazon Web Services, Inc.

Research

Your personal information may be de-identified (so that it is no longer personal information) and aggregated for the purposes of internal statistical analysis and academic research. T

Your personal information may be de-identified (so that it is no longer personal information) and aggregated for the purposes of internal statistical analysis and academic research. This analysis and research are used for improving the App and improving the Website and will be shared with Organisations, Schools, State/Territory Education Departments and policy think tanks for the purposes of policy decision-making around mental health.

his analysis and research is used for improving the App and improving the Website and will be shared with Schools, State/Territory education departments and policy think tanks for the purposes of policy decision-making around mental health.

Marketing Communications

We may send marketing communications to Users, Staff, Admin, Organisations, and Visitors who give their prior consent to receive such communications.

These communications to Users, Staff, Admin, Organisations, and Visitors may be in various forms, including telephone, SMS or via email in accordance with the Spam Act 2004 (Cth). If you indicated a preference for a method of communication, we will endeavour to use that method to communicate with you whenever practicable to do so. If at any time you decide you no longer wish to receive marketing communications from us you may use the opt-out/unsubscribe facility option in our email or SMS or make a request not to receive marketing communications from us by contacting us using the details noted in the Contact Information section below, or by a request through our Website.

Security of your Personal Information

We take reasonable steps to protect your personal information from loss, misuse, and interference and from unauthorised access, modification and disclosure. We encrypt your personal information when it is transmitted over the internet.

We also monitor our systems for possible vulnerabilities and cyber-attacks. We will notify you and supervisory authorities such as the Office of the Australian Information Commissioner (OAIC) of data breaches where required by law or otherwise as we feel appropriate.

We take all reasonable steps to destroy or permanently de-identify your personal information where it is no longer required, once any legal obligation to retain it has been expired.

However, the measures we take are not a guarantee of the security of your personal information. You must also take care to protect your personal information. Please notify us as soon as soon as possible if you become aware of any security breaches.

Updating and/or accessing your personal information

We take reasonable steps to ensure that your personal information that we hold is accurate, complete, and up to date. To assist us to do this, please ensure you provide us with correct information and inform us whenever your personal information changes.

If you are a User, Staff, Admin, or Visitor and wish to access or update your personal information that we have, please contact us using the details noted in the Contact Information section below.

Where you request access to your personal information, we will respond to any such request within a reasonable period after the request is made. If we refuse to provide access to your personal information for any reason, we will provide you with a written notice of the reason(s) for such refusal and the procedure to complain about the refusal.

If we refuse to correct your personal information following a request by you to do so, then we will provide you with a written notice of the reasons(s) for such refusal and the procedure to complain about our refusal. We will respond to any requests regarding the correction of your personal information so that it is accurate, complete, and up to date within a reasonable period after a request is made. We will not charge you for any request to correct your information.

We may recover from you our reasonable costs of supplying you with access to your personal information, but we will not charge you for any request you might make to access your personal information.

Cookies

Information may be collected through the use of “cookies” on our Website and the LW App. Cookies are small text files that a website can use in order to recognise visitors who revisit a website so as to facilitate their ongoing access to and use of the site. They enable usage behaviour to be tracked and aggregate data to be compiled that would facilitate more targeted advertising and improved content. Typically, cookies involve the assigning of a unique number to the visitor. You can prevent the use of cookies by setting up your web browser to block them.

Links on your website

The Website may contain links to websites which are owned or operated by other parties. You should make your own enquiries as to the privacy policies of these parties/websites. We are not responsible for the information on, or the privacy practices of, such websites.

If you have a privacy complaint

We are committed to maintaining and protecting your privacy. If you wish to make a complaint, please contact us using the contact information in the Contact Information section below.

Please provide us with sufficient detail regarding your complaint and any supporting evidence. We will notify you in writing if we require any additional information or otherwise of the outcome of our investigation of the complaint.

If your complaint is not satisfactorily resolved, you may refer your complaint, as relevant, to:

the OAIC at oaic.gov.au/about-us/contact-us/;
the Victorian Health Complaints Commissioner at vic.gov.au/make-complaint;
the NSW Health Care Complaints Commission at hccc.nsw.gov.au/myComplaint; or
the ACT Human Rights Commission at act.gov.au/contact-us.

Contact information

Any queries about this Privacy Policy, correction or access requests or privacy complaints should be addressed to:

Liminal Group Pty Ltd

Email: support@liminalwellbeing.com.au