privacy policy

THIS POLICY DESCRIBES HOW MINDCOMPASS MAY USE AND DISCLOSE THE PERSONAL INFORMATION THAT YOU PROVIDE IN CONNECTION WITH YOUR USE OF THE MINDCOMPASS APPLICATION. PLEASE REVIEW IT CAREFULLY.

Introduction

MindCompass 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 MindCompass (a trademark of Anywise Consulting Pty Ltd and SelfTherapy Pty Ltd) will follow when managing, using and disclosing personal information collected through the MindCompass web and mobile application ('MindCompass').

When this policy uses 'I', 'we', 'us', 'our', 'e-hub Health' or 'e-hub' it means MindCompass. 'MindCompass application' means this mobile and web application provided at www.mindcompass.ai.

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 use the MindCompass application.

In order to ensure privacy was considered when developing this website, a privacy impact assessment was undertaken.

Who does this policy apply to?

This privacy policy applies to all current, future and past users of the MindCompass application whose personal information has been collected by us.

What is collected?

The type of information we may collect and hold through the MindCompass application includes personal information about users of the MindCompass application. If your subscription to MindCompass requires payment of a fee, we may use RevenueCat, Stripe or other payment providers to facilitate the subscription process.

The personal information we may collect and hold relating to the MindCompass application consists of:

age group, gender;
whether you identify as Aboriginal and/or Torres Strait Island origin;
whether you are in a city or rural area;
whether you were referred by a health professional;
email address, password nominated by you, answers to secret questions nominated by you;
the information you submit when using the MindCompass application;
information about your usage of the MindCompass application 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 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 MindCompass application 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 servers and program software are managed by SelfTherapy Pty Ltd.

We collect personal information from you directly when you provide your information to us by entering data in the MindCompass application or from you indirectly through emails and forms.

In order to use the MindCompass application you are required to register and log in using an email address. If you wish to remain anonymous, you are welcome to create a new email address or use an email alias if your email provider supports this, to protect your anonymity. The email address you supply will be used only to send a welcome email, for retrieval of your login details should you forget your password, and in extreme circumstances, to notify you if you have been affected by a data breach. When we share aggregated reports with other parties detailed in the ‘Who do we disclose your personal information to?’ section, we ensure email addresses are not shared so that de-identified data cannot be re-identified by any party.

In addition to the information that we collect, RevenueCat (or our other payment providers that we may use from time to time) may collect personal information from you for the purposes of processing your recurring or one-off payment. For more detailed information about how your personal information is collected, held, used and disclosed, you should consult the website and/or privacy policy of the relevant payment provider. You can read RevenueCat’s privacy policy here and Stripe’s privacy policy here.

Protection of user privacy is a high priority for MindCompass 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 unauthorised 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 unauthorised third party will find a way to penetrate MindCompass’ security or that personal information transmitted over the internet will be intercepted.

Where we no longer require your personal information we will take reasonable steps to destroy it. We reserve the right to delete your information if we reasonably believe that your use of the MindCompass application has ended. We typically will delete your information if you have not logged in to the MindCompass application for 24 months, or if our arrangement with your employer or the organisation that provided you with access has terminated. We are not obligated to delete your information from your account unless you direct us to do so (such as through the user tools in the MindCompass application), but your personal information may continue to be maintained in backup media. We may continue to store, use and maintain a de-identified version of your personal information as described in this Privacy Policy.

Why do we collect, hold, use and disclose personal information?

MindCompass allows you to enter and store personal information on a voluntary basis. The MindCompass application is designed to allow access only to the person who entered the information using the Login Access as described in the Terms of Use.

In general, we may collect, hold, use and disclose your personal information collected through the MindCompass application for the following purposes:

to deliver the MindCompass application to you;
to generate aggregated reports for user analysis (which include no identifying User Data);
to generate research reports for user analysis (only in the situation where your Login Access has been provided as part of a research trial);
to communicate with you to provide our services;
to help us manage and enhance the delivery the MindCompass application;
to facilitate payment and management of subscriptions; and
to comply with our legal and professional obligations.

Where your access to MindCompass has been made available to you by your employer or another organisation, your personal information (but not User Data) may be used to generate aggregated reports to your employer or the organisation that provided you with access for the purpose of managing and recording the progress and completion of the MindCompass application. User Data is excluded from reports to your employer or the other organisation that provided you with access.

Where your access to MindCompass has been made available to you by a research institution that is conducting a research trial (the RO), your personal information, including User Data, may be used to facilitate the research and generate research reports for the RO. These reports may contain your registration data, conversational metadata and information about your progress through the app and may be used by the RO to undertake that research trial.

You grant MindCompass and all other persons or entities involved in the operation of the MindCompass application 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;
where your access to the website has been made available to you by your employer or other entity, to this employer or entity, but only in the form of aggregated reports for user analysis (which include no identifying User Data);
where your access to the website has been made available by a research organisation that is conducting a research trial, to this research institution;
where you purchase access to the website via an individual subscription, to RevenueCat (but only your email address so that RevenueCat can communicate with you about your purchase);
to staff from Anywise and SelfTherapy who assist MindCompass in providing our services; and
to our Service Providers that enable our platform to provide the services to you such as, backup and servers hosting solution providers, data security, data analytics providers and/ or software and IT maintenance providers, service providers who assist with the authentication of individuals and payment processing.

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 MindCompass assets or an MindCompass 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 anyone described above under “Who do we disclose your personal information to?”
MindCompass strives to limit storage of personal information to within Australia where possible. Our related entitles Anywise and SelfTherapy and Service Providers may access or store Personal Information in Canada, United Kingdom, European Union, United States.

Whenever we transfer your personal data to a third country or to an international organisation, we ensure that an adequate level of protection is afforded to it by ensuring that adequate safeguards are implemented.

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 or deletion of the personal information which we hold about you by contacting us at info@selftherapy.ai. 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 generic mindcompass email. 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
www.oaic.gov.au

Children's Privacy

The MindCompass application is not intended for use by children under the age of 16 or for children under the age of 18 in the USA. We do not knowingly collect information from any person under the age of 16 or from any person under the age of 18 in the USA, 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 generic mindcompass email. We will ask you to verify your identity and indicate what information you wish to receive.

Cookies Policy

The MindCompass application uses 'transient cookies'. Cookies are pieces of information that a website transfers to your computer's hard disk when you open the website or application. Cookies by themselves do not identify you but they do identify your web browser.

When you access the MindCompass application our server makes a record of your visit and logs the following information: your browser's internet address or type of device; 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 MindCompass application is used for statistical purposes and system administration tasks to maintain this service.

Because the MindCompass application uses 'transient cookies' your computer does not retain the information delivered in the cookies once you leave the MindCompass application. When you close your browser, the transient cookie set up by the website is destroyed and no information is retained which could identify you or your browser next time you log onto the MindCompass application.

We also make available a Status Page and display widget to communicate the program’s system status and details of any maintenance or incidents, and analytics software that tracks and reports aggregate website and application traffic without compromising on your privacy. These services only reports on aggregates and does not collect personal data or use cookies.

Adwords tracking (Australia)

The MindCompass application uses Google Adwords Conversion Tracking which helps us to track how many users from Australia who click on our Google Ads end up registering on MindCompass. 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.

Changes to this Privacy Policy

This Policy will be reviewed and may be revised from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. You will be made aware of any changes to the privacy policy when you log in to your account and will be prompted to agree to the changes. The changes shall be effective immediately upon posting to the MindCompass application unless otherwise stated on the website. By continuing to use this website you accept the Privacy Policy then currently in effect.

Please be aware that any changes in the privacy practices of your employer or other organisation through which you received access to the website will not be posted on the MindCompass application.

Last updated: 1 November 2024