HEALTHILY – GOSHARE HEALTHCARE APP PRIVACY POLICY
The GoShare Healthcare web application (App) is owned and operated by Healthily Pty Ltd ACN 78 613 342 635 (Healthily, We or Us). GoShare is a platform for the distribution of health and lifestyle resources.
Healthily is committed to ensuring that your privacy is protected. This Privacy Policy describes how Healthily collects, uses, discloses and stores your personal information when you use or receive information from the App. We encourage you to read this Privacy Policy carefully and contact us at goshare@healthily.com.au if you have any questions.
Personal Information is any information about you where your identity is apparent or can reasonably be ascertained from the information. The Personal Information collected by Healthily when you use or receive information from the App is limited to your name, email address and phone number. We also record which health and lifestyle resources you wish to receive.
Sensitive Information is a subset of Personal Information which contains information or an opinion about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, sexual preferences or criminal records. Sensitive Information also includes any of your health information.
Healthily will not collect or use Sensitive Information when you use or receive information from the App other than information about the health or lifestyle resources you want to receive.
This Privacy Policy covers any Personal Information collected or received by Healthily as a result of your use of the App or your health practitioner’s use of the App to send you information with your consent.
By using the App, you are agreeing that Healthily may make use of the information we collect from you, including your Personal Information, in accordance with this Privacy Policy.
We endorse fair information handling practices and use of information in compliance with our obligations under the privacy laws in force in Australia from time to time. Any information provided, including identification of individuals, will be used only for the purpose/s intended or authorised and where the intention includes confidentiality, information will be treated as such unless otherwise required by law.
Healthily may change this Privacy Policy by updating this page from time to time. Any update to this Privacy Policy will be effective from the date that it is posted on the App or on our website, healthily.com.au (Site). You should check this page occasionally to ensure that you are familiar with any changes.
1. USE AND DISCLOSURE OF PERSONAL INFORMATION
Collection of Personal Information
We may collect Personal Information about you when:
- a health practitioner uses the App to provide you with health and lifestyle information, with your permission; or
- you click on the unique URL created for you by the App to access health and lifestyle information.
Registration is limited to your name, email address and/or mobile number, and you may elect not to provide your name.
It is your responsibility to keep your information up to date with GoShare. Should you wish to alter your Personal Information, please advise your healthcare provider.
Use of Personal Information
We may collect, use and disclose your Personal Information:
- for the purpose of providing the services you have requested to you;
- for the purpose of providing health, lifestyle and related resources to you; and
- any other purposes required or authorised by law.
Healthily may also disclose your Personal Information to its agents or sub-contractors for the above purposes, always on the condition that the agent or sub-contractor in question will be obliged to use that Personal Information in accordance with the terms, and subject to the disclaimers and limitations disclosed in this Privacy Policy.
Healthily may also use deidentified information for:
- the compilation and analysis of statistics relevant to public health and safety and complying with our legal obligations; and
- for purposes connected with the operation, administration, development or enhancement of the App.
Healthily will not use your Personal Information to enable direct marketing to you.
If we collect information about you from a third party, we will determine whether we could have lawfully collected that information directly from you and, if not, we will destroy or de-identify that information (provided it’s lawful to do so).
If we receive unsolicited Personal Information about you, we will ensure it is protected and secure in the same way that we treat Personal Information that we do intend to collect. If we could not have collected the information through our normal processes, we will de-identify that information (provided it’s lawful to do so).
Any complaints relating to the treatment of your Personal Information or breach of the relevant privacy laws in force in Australia from time to time should be directed to Healthily’s complaint management facility at goshare@healthily.com.au. We will respond to every email within a reasonable time period. We will endeavour to resolve all complaints as soon as possible.
We will keep your Personal Information for as long as it is required to provide you with our services and to comply with legal requirements
If we no longer require your Personal Information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or permanently de-identify your Personal Information.
If you no longer wish to receive communications from us, please use the unsubscribe link contained in all of our email communications or replying “STOP” to any SMS message. Alternatively, you may contact our Privacy Officer.
2. INFORMATION SHARING AND DISCLOSURE
Healthily may disclose Personal Information to a related body corporate or an unrelated third party as set out in this Privacy Policy or otherwise, if your consent has been granted for such disclosure.
Healthily does not rent, sell, or share Personal Information about you with third parties or non- affiliated companies, except to provide products or services requested by you and otherwise in accordance with this Privacy Policy.
In addition to the uses set out above, by proceeding to use the App, you consent to disclosure of your Personal Information as follows:
- to a trusted partner who works on behalf of or with Healthily under confidentiality agreements (Service Partner);
- to a Service Partner who requires access to your Personal Information to help Healthily communicate with you, eg: an email service (the Service Partner will not have the independent right to share, use or sell Personal Information or to contact you regarding any matter not related to Healthily). If the Service Partner requires you to leave the App e.g. Stripe, you will be subject to the Service Partner’s privacy policies and Healthily takes no responsibility or liability for such third party privacy policies. We encourage you to read their terms and policies;
- as required under a subpoena, court order, or legal process, or in order to establish, exercise or defend Healthily’s legal rights or otherwise as required by law;
- in order (in the reasonable opinion of Healthily) to investigate, prevent, or take action regarding illegal activity, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of Healthily’s Terms and Conditions;
- in order to enforce our Terms and Conditions; and
- in order to investigate or resolve complaints against or involving Healthily which raise civil liabilities and to aid any government agency in any investigation circumstances.
In the event that the App is sold by Healthily, the data, including your Personal Information may be transferred to the purchasing entity which would be bound to comply with the Privacy Act 1988 in relation to the access, storage and use of your Personal Information. Further, in circumstances where Healthily is sold or merged with another entity, the data, including your Personal Information, may be transferred to the purchasing entity, which would be bound to comply with the Privacy Act 1988 in relation to the access, storage and use of your Personal Information. Your Personal Information would not be disclosed to a buyer in either circumstance, other than as a part of the transfer of all data related to the App to that buyer.
3. CONFIDENTIALITY & DATA SECURITY
The App has been built with modern, best-practice web development methods, with security a foremost consideration. All Personal Information collected is stored on secure servers in Australia.
We take all reasonable steps to manage data stored on our servers to ensure data security and to prevent the loss, misuse or alteration of your Personal Information.
Access by Healthily’s employees or contractors to your Personal Information will be restricted to circumstances where we reasonably believe such access is needed in order to provide products or services to you. Any access provided by employees or contractors will be restricted to the minimum necessary for them to perform their jobs.
Physical, electronic, and procedural safeguards have been implemented in order to protect your Personal Information, and although we take all care to respect and protect your Personal Information:
- You are responsible for the security of your own device and we will not accept any responsibility for any unauthorised use of your account or of the App generally by third parties who access your device;
- the emails and SMS messages the App will send you are not encrypted and, in the event that your personal emails or messages are accessed by a third party, the information may be viewed by the third party;
- we use third party payment providers and gateways, we cannot ensure the security or privacy of transactions that do not occur within the App; and
- you are responsible for ensuring the content of your account information that you provide to us is accurate and up to date. You are responsible for the security of any password and details needed to access the App and/or GoShare at all times.
If we have reasonable grounds to believe that your Personal Information that we hold may be subject to unauthorised access or disclosure (eligible data breach), we will investigate and assess the suspected eligible data breach to determine whether the eligible data breach is likely to result in serious harm to you (Notifiable Data Breach). If a Notifiable Data Breach occurs, then we will notify you and the Australian Information Commissioner as soon as practicable after we become aware of the Notifiable Data Breach in accordance with our obligations under the Act. We will comply in every way with our obligations under Part IIIC – “notification of eligible data breaches” of the Act.
4. LINKS TO EXTERNAL WEB APPS
This Privacy Policy does not extend beyond the App. When following links to other Apps from this App, we recommend that you read the Privacy Policies of those Apps in order to familiarise yourself with their privacy practices.
5. COOKIES
Like many Apps, the App may use cookies from time to time on your computer to keep track of your login status.
Cookies are small data files that a web server places on a user’s computer hard drive to be a unique identifier. Cookies enable Healthily to save your log in details for further login to our services or product.
For example, we may use cookies to record that you have viewed a particular section of the App, that your browsing software is a particular version or to ensure that online applications and transactions do not require you to re-input information when moving between pages. In this way, cookies can improve the operation of the App, and make the experience more efficient, more enjoyable or more personalised.
Importantly, in depositing information on a user’s computer and referring to it later in the same session (sessional) or on a subsequent visit (persistent), cookies do not need to identify the user or record any Personal Information.
Our cookies do not have an expiration date.
The default settings of browsers like Internet Explorer may allow some or all cookies, but users can easily take steps to erase cookies from their hard-drive, block all cookies, or receive a warning before a cookie is stored. However, some parts of the App may not function fully for users that disallow cookies.
6. CHANGING INFORMATION AND PREFERENCES
You are entitled to access any of our records that contain your Personal Information.
Healthily will, at your request, correct as soon as reasonably possible any of our records that contain your Personal Information and which you advise are inaccurate.
Although Healthily may charge a fee for a complex or resource intensive change to your Personal Information there will normally be no fee charged for processing an access or correction request.
You can lodge a request to access and/or correct your Personal Information, edit your account information at any time or cancel your registration by contacting support at goshare@healthily.com.au. Any request received by Healthily will be dealt with within a reasonable time period and if, for any reason, we decline your request for access, we will give you reasons for our decision when we respond to your request.
We reserve the right to delete your Personal Information unless we are required by law to retain it. You may contact us using the above email address if you wish us to delete your Personal Information. Healthily will comply with a request to delete Personal Information unless we are required by law to retain it.
Despite anything contained in this Privacy Policy to the contrary, the Freedom of Information Act 1982 continues to apply to any Personal Information held by us. The access and correction requirements in the Privacy Act 1988 operate 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.
7. CONTACT HEALTHILY
If you would like further information about:
- how you may access and request correction of your personal information that is held by Healthily; or
- how to make a complaint about the handling of your personal information and how your complaint will be dealt with by Healthily, please contact our Privacy Officer.
Contact details:
Email: goshare@healthily.com.au Phone: (03) 9534 7222
Facsimile: (03) 9534 7333
Postal address:
Privacy Officer Healthily
Level 5, 492 St Kilda Road
Melbourne VIC 3004
Last reviewed: July 2023