Privacy Policy

We respect your privacy and are committed to protecting your personal information. We are bound by the Privacy Act 1988 (Cth). This document explains how HealthChase Pty Ltd (ACN 603 184 532) (“HealthChase”, "we", "us", "our") manages the personal information we collect about you including the information you provide through our website/app habitjam.io.

What personal information do we collect about you?

Personal information is any information or an opinion about an identified person or from which they are reasonably identifiable.

The types of personal information we may collect about you includes:

  • your name,

  • your location,

  • your mobile telephone number,

  • your device and browser information,

  • your email address, and

  • any content (such as photographs) that you upload using our services.

To allow you to use certain features of our services, you may choose to (but you do not have to) provide us with additional information, like information regarding your behaviours, and user-generated content such as uploading text or photographs to the services. If you do not provide this information to us, you may not be able to use some features of our services.

What we do not collect

We only collect the information stated above for the purpose of delivering you the application functionality necessary. We do not collect additional data about your social media presence, your demographic, your ethnicity, or other sensitive information.

How do we collect your personal information?

We collect your personal information in several ways, including

  • information we collect directly from you, for example, when you provide information to us by email or register for the HabitJam platform through our website habitjam.io,

  • from information, data and images (user-generated content or UGC) you enter about your lifestyle and HabitJam game activities during a HabitJam program and from feedback surveys you complete, or

  • from your employer or organisation(s) that participates, promotes, sponsors or funds your use of the HabitJam platform.

We also collect personal information from contacts we deal with at client or potential client organisations, and for prospective employees we may require personal information such as your resume and work history. 

Website collection

We may collect personal or usage information about you from our website when you interact with our website or communicate with us. Our systems also record certain information about your use of our website, for example the web pages you access and the date and time of your access. We use this information to assist in the performance of our website and to support log in processes. This may involve the use of 'cookies' on our website. Cookies are small text files that help a website to remember your preferences and improve your experience. Many websites use cookies as a matter of course.

If our cookies collect any of your personal information we will treat this information in the same way as other personal information we collect about you. We may also collect your Internet Protocol (IP) address when you visit our website for internet session management and security purposes.

How do we use and disclose your personal information?

We use and disclose your personal information for the following purposes:

  • to verify your identity,

  • to conduct our business,

  • to run the HabitJam Program (meaning all programs and games presented under the HabitJam name including the workshops and information provided throughout the program and on the HabitJam website),

  • to manage our website,

  • to communicate with you as part of the HabitJam Program,

  • to respond to your enquiries and concerns,

  • to conduct research,

  • to include in HabitJam program reports,

  • to develop new products and services, and

  • to comply with our legal obligations.

Disclosure of your information to third Parties (including overseas)

We prepare HabitJam Program Reports and HabitJam Program results presentation slides for each business or organisation that runs a HabitJam Program. These include aggregated and de-identified data and information from the HabitJam Program and survey feedback, the name of the highest point scorer in each category, winners and may also include UGC in the form of images and comments that have been made throughout the Journey.

We may also disclose your personal information to companies that we have engaged to provide us with services and carry out functions and activities on our behalf (as explained below), to our professional advisers and insurers or to anyone else to whom you authorise us to disclose it. We may also disclose your personal information to law enforcement and national security agencies, and other government and regulatory authorities as required or authorised by law.

The services performed by third parties on our behalf are located in Australia and overseas and/ or the servers they may use are located in various countries, and they include:

  • Email service providers who send you our emails during a HabitJam Program

  • Cache storage service provider who store cached versions of images uploaded and downloaded onto the Game website. If you are a player in Australia cached versions of your images will be stored in Australia. If you are a Player in another country cached versions of images uploaded or accessed will be stored at the nearest location of the provider;

  • Suppliers of webhosting, website design, SEO and other online services;

  • Analytics service providers who analyse traffic at our website (information collected through such analysis is anonymous);

  • Suppliers of infrastructure services. For Journeys in Australia, servers will be located in Australia. For international Games, AWS servers nearer the players' location may be used for the best service.

Amazon Web Services (AWS) supports a number of these services and further details of their privacy policy can be found here. Our relationships with these third party service providers are governed by our contracts with them and they are required to hold your personal information strictly confidentially and use it only for providing us with their services.

Your rights to access and control your personal information

What are your rights?

1.    Correction of your personal information

We take all reasonable steps to ensure that the personal information we collect and hold is accurate, complete and up-to-date. If you believe that your personal information is inaccurate, you have the right to contact us and ask us to correct such personal information.

You can also update your name by accessing your settings in a HabitJam Game located under your avatar on your dashboard.

2.    Restriction of processing

You have the right to request that the processing of your personal information be restricted in some circumstances. For example, you have the right to request the restriction of your personal information if you contest the accuracy of your personal information and we need some time to verify its accuracy.

3.    Access to your personal information

You have the right to request information about what personal information we process about you, to access all your personal information, and to receive a copy of it. We may charge you for our reasonable costs in supplying you with access to this information.

4.    Erasure of your personal information

You may ask us to erase your personal information if you withdraw your consent to processing, or if you believe such processing is unlawful. Please be aware that erasing some personal information may affect your experience using certain features of HabitJam that rely on historical data.

Security of your personal information

Our staff are required to respect the confidentiality of personal information and the privacy of individuals. We protect personal information held from misuse and loss and from unauthorised access, use, modification or disclosure for example by physical security of our servers, firewalls and restricted access to electronic records. We take reasonable steps to destroy personal information no longer required by us for a permitted purpose.

Complaints and concerns

1.    Time to process request

We will address your request within 30 days after receipt. It can take us up to 90 days in some cases, for example for full erasure of your personal information stored in our backup systems. We will let you know if we need more time and explain the reasons for the delay.

2.    Vague or unreasonable requests

Please keep in mind that if we receive a vague request, we may contact you to better understand the request before doing anything. We may also refuse to comply with or charge a reasonable fee for a request that is manifestly unfounded and/or excessive (repetitive) requests.

3.    Clarification and verification of your identity

We will require you to prove your identity. Normally, we will verify that the request is coming from the same email that you provided when registering. If you have not registered your account, we may ask you to undergo additional verification checks to ensure we can appropriately respond to you.

4.    Complaints

You may have the right to lodge a complaint with your local data protection authority about any of our activities. If you have any concerns about our privacy practices, please let us know by emailing admin@habitjam.io.

If you are still not satisfied with the outcome, you may complain to the Privacy Commissioner at the Office of the Australian Information Commissioner (OAIC) whose details are:

Phone: 1300 363 992
Post: GPO Box 5218, Sydney NSW 2001
Online form: www.oaic.gov.au (Privacy Complaint Form)

Data retention

Except as set out below, we will retain your personal information for as long as needed to provide you with HabitJam or otherwise fulfil the purposes for which it was collected.

International operations and data transfers

We are based in Australia. Personal information we collect may be transferred to and processed in the United States (US) and to other countries.

Transfers of personal data outside of the European Union, the European Economic Area, and the United Kingdom

Personal information in the European Union (EU), the European Economic Area (EEA), and the United Kingdom (UK) is protected by the General Data Protection Regulation and Data Protection Act 2018 (GDPR), but some other countries may not necessarily have the same standard of protection for your personal information.

United States Privacy Disclosures

We do not sell your information for monetary gain.

Under certain state laws (including California), if we disclose personal information to a third party for any benefit, this can be considered a “sale” or “share” or personal information, even if the third party does not use the personal information for any other purpose. We “share” personal information if we disclose personal information to a company for purposes of cross-context behavioural advertising.

Request to opt out: While we do not sell your personal information for monetary gain, you have the right to opt out of our “sale” or “sharing” of your personal information (as defined under California or other US state legislation) to our analytics and advertising partners. This statement does not apply to aggregated or de-identified data, which may be shared in this way (but you may still opt out). To exercise this right, contact us at admin@habitjam.io.

Limiting the use of sensitive personal information: Sensitive personal information that we process is limited to only those purposes that are necessary to provide products or services to you.

Request to know/access: In addition to the other rights mentioned in this Privacy Policy, you have the right to request to know (i) the personal and sensitive information we have collected about you and our purposes of use; and (ii) the categories, sources, and third parties involved in personal information we have collected about you or “sold” or disclosed in the past 12 months. You may exercise your right to request to know twice a year, free of charge.

Shine the Light: California residents may also request information from us once a calendar year about any personal information shared with third parties for their own direct marketing purposes. We don’t share information with third parties for their own marketing uses, but please email us at admin@habitjam.io if you have questions. You’ll need to specify “California Privacy Rights Request” in the subject line of the email, and also include your name, street address, city, state, and ZIP code.

References to “personal information” in this policy include “sensitive/personal information” as defined under California laws.

Updates to this Policy

This Policy may be updated from time to time to take account of new laws and technology and any changes to our business and information handling practices. The most current version can be found on our website habitjam.io or can be obtained by contacting our Privacy Officer.

How to contact us

If you have any queries in relation to this Privacy Policy, or wish to request access or updates to your personal information or you wish to make a complaint, please contact our Privacy Officer by email at admin@habitjam.io or by calling us on 03 9502 0751.

 

This Policy was last updated: December 2024