Thrive by Five International Parenting App

Privacy Policy

1. Introduction

The Minderoo Foundation Pty Ltd (ACN 098 198 684) as trustee for The Minderoo Foundation Trust (ABN 24 819 440 618) (‘we,’ ‘us’ and ‘our’) is committed to ensuring the confidentiality and security of the personal information we collect and store when you access or use the Thrive By Five International Parenting App (App).

This Privacy Policy outlines how we collect, use, disclose and protect your personal information, as required by the Privacy Act 1988 (Cth) (Privacy Act). It also outlines how you can access and change your information, ask a question or make a complaint. Whether or not the Privacy Act applies to your personal information that we collect or hold, we will comply this Privacy Policy.

By accessing or using the App you agree that we can handle your data as stated in this Privacy Policy and that you will be bound by the Terms and Conditions of Use available within this app.

2. Collecting personal information

2.1 What is personal information?

Personal information is information that identifies you as an individual or from which you can be reasonably identified.

We have designed the App so that it collects very little information about you and your child. In many cases, the information you enter into the App will not be able to identify you. For example, only first names are asked for, and you do not need to enter your real name or the real name of your child. Any photos or videos you use with the App will be stored only on your device and we will not be able to access them.

However, in some circumstances, the information provided could be combined with other information to identify you. Therefore, we will treat it as personal information as stated in this Privacy Policy.

2.2 What personal information do we collect through the App?

When you use the App, you have the ability to enter certain information. If you choose to enter it, we will collect your first name and the first name, birth month and birth year of a child that you are using the App with. We will also collect your preferences that you enter into the App, including feedback and information you enter about your experience with the App. We may also collect other information about you that you provide to us directly or indirectly.

2.3 What is the purpose of collecting personal information?

We only collect personal information that is reasonably necessary for us to perform our functions and activities. For example, we may use your personal information to provide you with the App, provide services to you, and improve and personalise the App. We may also use your personal information for ancillary purposes and generally in the process of providing a quality service and experience while you access or use the App.

We will provide your personal information entered into the App to third parties as stated in section 3 for the purpose of providing you with the App. Although unlikely, we may also provide your personal information to third parties in connection with these purposes. We will take reasonable steps to ensure that any such third party treats your personal information in accordance with the terms of this Privacy Policy.

2.4 How do we collect personal and non-personal information?

We can only collect personal information about you in ways that are lawful and fair. We largely collect information from you directly, such as when you create a profile in the App or tell us how a child is engaging with and responding to activities and strategies recommended by the App. You may restrict the personal information you provide to us directly by using the “skip” functionality when creating a Profile.

We will also collect information such as the server your device is logged on to, your regional location, the time when you access the App and how long you access the App for.

If you choose to provide us with personal information by using the App and creating a Profile in the App, the information we collect through user-event tracking about how you access or use the App may reasonably identify you.

3. How we use and disclose your personal information

3.1 How we use and disclose your personal information

We only hold, use and disclose personal information about you for the purposes stated in section 2.3, or for related purposes that might be reasonably expected, unless you provide your consent to other purposes.

Such disclosure may include disclosure of your personal information to third parties who:

(a) are our service providers (such as web hosting or data storage providers);

(b) are regulatory bodies, government agencies, law enforcement bodies or courts; or

(c) are your authorised agents, executors, administrators or legal representatives.

We may also hold, use and disclose your personal information in connection with suspected fraud, misconduct and unlawful activity.

We may also be required to disclose your personal information by law.

3.2 Overseas transfer of information

Your personal information may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. For example, we store your information in a secure hosting environment in Australia.

By using the App, you consent to the collection, use, storage and processing of your personal information in Australia. In Australia, the Privacy Act regulates you rights in respect of your personal information and how other parties must treat such information.

4. Keeping personal information secure

We have designed the App so that we only collect and store your information directly within our own-cloud environment hosted in Australia. We have security measures in place to protect your personal information that we hold. We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure.

We may hold your information in either electronic or hard copy form. We implement security measures (including encrypting your information where appropriate) to ensure the physical security of personal information held on our premises and systems. When records containing personal information are no longer required, we delete the information or permanently de-identify it.

However, as the App is provided through the Internet, we cannot guarantee the security of transmission of information you communicate to us. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the Internet. Accordingly, any personal information or other information that you transmit to us is transmitted at your own risk.

5. Access and correction of personal information

5.1 Access

You have the right to access the personal information we hold about you. You have the right to access that information in any reasonable and practicable manner that you request.

If you make a request, we will need to validate your identity so that we do not provide your information to someone else.

We will provide you with access within 30 days if it is reasonable and practicable to do so, but in some circumstances it may take longer.

If we refuse access, we will explain our decision to the extent practicable and your options to make a complaint.

We will not usually charge you for access to your personal information. However, if the request is complex, we may charge you our cost of providing the access, such as the cost of our staff locating and gathering information.

To contact us to access the personal information we hold about you, please use one of the methods stated in section 6 below.

5.2 Correction

You can tell us at any time if any of the personal information we hold about you is incorrect, inaccurate or incomplete and you want us to correct that information.

If you would like to do so please contact us using the contact details in section 6 below.

We will normally respond to correction requests within 30 days, but in some circumstances it may take longer.

We will not charge you any amount to correct your personal information held by us.

If we do not agree that your personal information needs to be corrected or changed, then we will add a note to the personal information stating that you disagree with it.

You can also correct any information stored in your Profile yourself on the Profile settings page in the App.

6. Privacy contact

If you believe that we have not complied with our obligations relating to your personal information, or if you would like access to your personal information, please contact us using the following details:

By phone:

+61 8 6460 4949 between 9:00am and 5:00pm Monday to Friday.

By mail:

Thrive by Five
Minderoo Foundation
PO Box 3155 Broadway Nedlands WA 6009.

By email:

hello@thrivebyfive.com

If you feel we have not properly dealt with a complaint, you may contact the Office of the Australian Information Commissioner at enquiries@oaic.gov.au or on 1300 363 992.

7. Updates

We may review and amend this Privacy Policy from time to time to address changes to laws and to reflect our current operations and practices.

You can obtain a copy of the current version on request.

Last updated: [July 2021]