THIS POLICY DESCRIBES HOW EHUB MAY USE AND DISCLOSE THE PERSONAL INFORMATION THAT YOU PROVIDE IN CONNECTION WITH YOUR USE OF THE MOODGYM WEBSITE. PLEASE REVIEW IT CAREFULLY.
eHub recognises the importance of ensuring your personal information is kept secure and we understand that we have a legal obligation to protect your personal information. This page sets out the policy which eHub Health Pty Limited will follow when managing, using and disclosing personal information collected through the Moodgym website ('Moodgym').
When this policy uses 'I', 'we', 'us', 'our' or 'eHub' it means eHub Health Pty Limited.
If you do not agree to the collection, use and disclosure of your personal information as described in this Privacy Statement, you will not be able to register and use the Moodgym website.
Who does this policy apply to?
What is collected?
The type of information we may collect and hold through the Moodgym website includes personal information about users of the Moodgym website. If your subscription to Moodgym requires payment of a fee, we may use Paddle or other payment providers to facilitate the subscription process.
The personal information we collect and hold relating to the Moodgym website consists of:
- age group, gender;
- email address, password nominated by you, answers to secret questions nominated by you, and the information you submit when using the Moodgym website (including quizzes, workbooks and diaries);
- information about your usage of the Moodgym website by using transient cookies including your browser's internet address; the date and time of your visit to the site; the pages you've accessed and documents downloaded; the type of browser you are using; the number of bookmarks created; the last viewed date; and the time of your visit; and
- details about your subscription excluding credit card details
collectively referred to as User Data.
We do not store your credit card details in any form.
How do we collect and hold personal information?
The Moodgym website is hosted on servers located within Australia, and data, including any personal information, is stored on these servers located in Australia. The servers are provided by an Infrastructure as a Service (IaaS) provider, and the server operating system and program software are managed by eHub.
We collect personal information from you directly when you provide your information to us by entering data in the Moodgym website or from you indirectly through emails, forms and telephone conversations).
Protection of user privacy is a high priority for eHub and we take reasonable steps to protect the security of personal information. Our personnel are required to respect the confidentiality of personal information and the privacy of individuals. We take reasonable steps to protect personal information held from misuse and loss and from unauthorized access, modification or disclosure, for example by use of physical security and restricted access to electronic records. Despite these measures, there is always some risk that an unauthorized third party will find a way to penetrate eHub’s security or that personal information transmitted over the internet will be intercepted.
Why do we collect, hold, use and disclose personal information?
In general, we may collect, hold, use and disclose your personal information collected through the Moodgym website for the following purposes:
- to deliver the Moodgym website;
- to generate aggregated reports for user analysis (which include no identifying User Data);
- to communicate with you to provide our services;
- to purchase goods or services;
- to help us manage and enhance the delivery the Moodgym website;
- to facilitate payment and management of subscriptions; and
- to comply with our legal obligations.
Where your access to Moodgym has been made available to you by your employer or another organization, your personal information (but not User Data) may be used to generate aggregated reports to your employer or the organization that provided you with access for the purpose of managing and recording the progress and completion of the Moodgym website. User Data is excluded from reports to your employer or the other organization that provided you with access.
You grant eHub and all other persons or entities involved in the operation of the Moodgym website the right to transmit, retrieve, store, use and monitor the information you enter so that they may operate the website and make the information available as described above.
Who do we disclose your personal information to?
We may disclose your other personal information:
- where we are required to do so by law;
- with your prior written content;
- to your employer or other entity that provided you with access to the website but only in the form of aggregated reports for user analysis (which include no identifying User Data); and
- to entities who assist us in providing our services (including hosting and data storage providers and payment providers).
In addition, we may release your personal information (1) in response to a court order, search warrant, subpoena or other legal action, (2) to protect persons or property or to defend or assert legal rights or (3) in connection with a transaction or proceeding resulting in the transfer of eHub assets or an eHub business operation that includes or uses such information.
Are we likely to disclose your personal information outside of Australia?
We may disclose your personal information to the following recipients outside of Australia:
- to other companies or individuals who assist us in providing services or who perform functions on our behalf (such as third party service providers and specialist consultants); and
- to anyone described above under “Who do we disclose your personal information to?”
How can you access and correct your personal information?
Subject to the exceptions set out in the Australian Privacy Act, you may seek access to and correction of the personal information which we hold about you by contacting us at firstname.lastname@example.org. We will require you to verify your identity and to specify what information you require. If a fee is charged for providing access, you will be advised of the likely cost in advance.
How can you make a privacy related complaint?
If you have any questions about privacy-related issues or wish to complain about a breach of the Australian Privacy Principles or the handling of your personal information by us, please contact our Privacy Officer at email@example.com. We may ask you to lodge your complaint in writing.
If we are unable to satisfactorily resolve your concerns about our handling of your personal information, you can contact the Office of the Australian Information Commissioner:
GPO Box 5218
Sydney NSW 2001
Tel: 1300 363 992
Children's Privacy (USA and Canada)
The Moodgym website is not intended for use by children under the age of 18 in the USA or Canada. We do not knowingly collect information from any person under the age of 18 in the USA or Canada, and you should not submit such information to us.
Additional information: processing of personal data which is applicable under the GDPR (Europe)
In accordance with Art. 15 GDPR you can request information about your personal data processed by us. In particular, you may request information on the purposes of processing, the categories of personal data, the categories of recipients to whom your data have been or will be disclosed, the planned storage period, the existence of a right to rectification, deletion, restriction of processing or opposition, the existence of a right of appeal, the origin of your data, if not collected by us, about a transfer to third countries or international organisations and the existence of automated decision-making including profiling and, if applicable, meaningful information on their details.
In accordance with Art. 16 GDPR you can immediately demand the correction of incorrect personal data or the completion of your personal data.
Pursuant to Art. 17 GDPR, you may request the deletion of your personal data stored by us, provided that the processing is not necessary to exercise the right to freedom of expression and information, to fulfil a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims.
In accordance with Art. 18 GDPR, you can request the restriction of the processing of your personal data if you dispute the accuracy of the data, if the processing is unlawful, if we no longer need the data and if you refuse their deletion because you need them to assert, exercise or defend legal claims. You are also entitled to the right under Art. 18 GDPR if you have filed an objection to the processing pursuant to Art. 21 GDPR.
Pursuant to Art. 20 GDPR, you may request that the personal data you have provided us with be received in a structured, current and machine-readable format or you may request that it be transmitted to another person responsible.
In accordance with Art. 7 (3) GDPR you can withdraw your consent at any time. As a consequence, we are no longer allowed to continue the data processing based on this consent for the future.
You can exercise your rights by contacting us at firstname.lastname@example.org. We will ask you to verify your identity and indicate what information you wish to receive.
The Moodgym website uses 'transient cookies'. Cookies are pieces of information that a website transfers to your computer's hard disk when you open the website. Cookies by themselves do not identify you but they do identify your web browser.
When you access the Moodgym website our server makes a record of your visit and logs the following information: your browser's internet address; the date and time of your visit to the site; the pages you've accessed and documents downloaded; the type of browser you are using; the number of bookmarks created; the last viewed date; and the time of your visit.
The information collected through the Moodgym website is used for statistical purposes and system administration tasks to maintain this service.
Because the Moodgym website uses 'transient cookies' your computer does not retain the information delivered in the cookies once you leave the eHub website. When you close your browser, the transient cookie set up by the eHub Access website is destroyed and no information is retained which could identify you or your browser next time you log onto the Moodgym website.
The Moodgym website pages may use third-party tools to better understand how people use the site. This makes information similar to that of routine server logs available to Google or other third-party statistics providers. The analytic reports that are produced are aggregated and do not identify individual users.
The Moodgym website uses Google Adwords Conversion Tracking which helps us to track how many people who click on our Google Ads end up registering on Moodgym. This sets a tracking cookie on your browser only when you click on a Google Ad. These cookies expire within 30 days and do not contain information that can identify you personally. You can read more at the Google Advertising Privacy Notice including information about how to opt out.
Please be aware that any changes in the privacy practices of your employer or other organization through which you received access to the website will not be posted on the Moodgym website.
Last updated: 10 May 2018