MPGo App Privacy Policy

MPGO App Privacy Policy 

 

1. Introduction

 

• This mobile application (MPGO App), our website (mpgo.com.au) (Site), and the Services made available through the MPGO App are created, operated and controlled by MPGO Pty Ltd (ACN 680 099 281) (MPGO, we, our or us).

 

• The MPGO App is a mobile application that allows enterprise, businesses and organisations to upload share, display or otherwise transmit data, materials and information (such as photos, video, documents, sessions summaries, tasks lists, business announcements and staff profiles) for clients or customers to view through the MPGO App (collectively, the Services).

 

• We are committed to ensuring your Personal Information is protected. We manage your Personal Information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).

 

• By downloading, visiting, accessing or using the MPGO App and Services, you agree to this Privacy Policy.

 

• This Privacy Policy outlines how we collect, store, process, use and disclose your Personal Information, and how you may access your Personal Information kept by us or how you may make a privacy complaint.

 

• For the purpose of this Privacy Policy:

 

• Authorised Users means a client or customer who is granted a licence to access and use the MPGO App and the Services by the Organisation for the purpose of communicating with the Organisation; and

 

• Organisation means the person or entity who has been granted a licence to access and use the MPGO App for the purpose of communicating with its customers or clients.

 

2. The information we collect about you

 

• Personal Information

 

• Personal information has the same meaning that it has under the Privacy Act, namely, information means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and recorded in a material form or not.

 

• Sensitive Information has the same meaning that it has under the Privacy Act, namely information or opinions about your health, political affiliations, sexual preferences, religious beliefs, racial or ethnic origin, criminal history or other such private information. A reference to Personal Information in this Privacy Policy includes Sensitive Information except where otherwise indicated.

 

• We collect and use Personal Information and non-Personal Information from you who upload, publish and store information on, or via, the MPGO App, and any other individual who interacts with us.

 

• We will only collect and hold Personal Information about you that is reasonably necessary to undertake our business activities and functions, to make the MPGO App and the Services and our other products and services available to you, or as otherwise permitted by law.

 

• The type of Personal Information and non-Personal Information that we collect and use depends on the type of dealings that you have with us.

• Authorised Users

 

We collect, store and hold Personal Information about Authorised Users of the MPGO App as well as information or data that does not contain Personal Information. For example, the type of Personal Information and non-Personal Information that we collect includes:

 

• contact details and account registration information (for example, your full name, phone number, date of birth, address, and email address);

 

• account credentials (for example, any username and password created by you as a user of the MPGO App and the Services);

 

• any content, materials, information, photographs, images, videos, reports, documents and other data about an Authorised User that is posted, published, uploaded or submitted on, or via the MPGO App by the Authorised User or an Organisation;

 

• marketing data and information relating to your dealings or enquiries you have made with us in relation to the MPGO App and the Services (including information about the third party products or services you used, ordered or enquired about) and the Organisation that you connect with, or interact with, through the MPGO App; and

 

• other information that you provide to other users or that we may collect in the course of our relationship with you.

 

 

• Organisation

 

We collect and hold Personal Information as well as information or data that does not contain Personal Information about Organisation that access and use on, or via, the MPGO App. For example, the type of Personal Information and non-Personal Information that we collect includes:

 

• contact details and account registration information (including your authorised representative’s full name and email address, the Organisation’s business name, ACN, ABN or other business identifiers, address, phone number, website address, and description of the products and services provided by the Organisation);

 

• account credentials (for example, any username and password created by you as the account holder on behalf of the Organisation);

 

• any content, materials, information and other data about the Organisation that is posted, published, uploaded or submitted on, or via the MPGO App by the Organisation;

 

• marketing data and information relating to your dealings or enquiries you have made with us in relation to the MPGO App and the Services (including information about the third party products or services you used, ordered or enquired about) and the Authorised Users that you connect with, or interact with, through the MPGO App;

 

• payment or billing details (for example, credit card, debit card or bank account details); and

 

• other information that you provide to us or that we may collect in the course of our relationship with you.

 

 

• Other information

 

• We may also collect some information that is not Personal Information because it does not identify you or anyone else. For example, we may collect:

 

• information regarding your access and use of our Site, the MPGO App and the Services, including location information, your computer’s internet protocol (IP) address, unique device identifier, browser characteristics, geolocation information, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our Site and on the MPGO App, dates and times of visits to our Site and the MPGO App, and other usage statistics; and

 

• anonymous answers to surveys or aggregated information about how you access and use the MPGO App and interact with other users of the MPGO App.

 

• If you are a candidate seeking employment with us, we will use your Personal Information to process your application and assess your suitability for any role. We may retain your information for future reference.

 

• Sensitive Information

We may collect information about you which is Sensitive Information, namely information or opinions about your physical or mental health condition or other such private information, such as provision of health care to the individuals including services being received, medical and allied health reports, prescriptions or medication use, genetic information, goals and wishes about future health services, incident reports and summaries from therapy services.

 

 

 

 

 

3. How we collect Personal Information

 

• Direct collection from you

 

• We will collect Personal Information and non-Personal Information about you in a number of different ways. We may collect Personal Information and non-Personal Information directly from you or in the course of our dealings with you. For example, when you:

 

• in case of Authorised Users, when you:
  1. download, access and use the MPGO App and Services (including when you open an Account or create or update your Account on, or, via, the MPGO App);

 

1. upload, publish or display information, data and materials or otherwise submit information or data on, or via, the MPGO App; and
2. connect with, and interact with, Organisation through the MPGO App or request information, data and materials that contains Personal Information and/or Sensitive Information from Organisation.

• in case of Organisation, when you:
  1. download, access and use the MPGO App and Services (including when you open an Account or create or update your Account on, or, via, the MPGO App);
  2. upload, publish or display information, data and materials or otherwise submit information or data on, or via, the MPGO App; and
  3. connect with, and interact with, Authorised Users through the MPGO App or request information, data and materials that contains Personal Information and/or Sensitive Information from Authorised Users;
• when you visit the Site and/or the MPGO App, contact or correspond with us via email or telephone or when you submit your query or complaint through our Site or the MPGO App (including on, or via, our related social media accounts) in relation to the MPGO App, the Services and other our products and services (including third party products and services).
• when complete any online forms or documents or when you enter or participate in competitions, promotions, events, sweepstakes, surveys and questionnaires; and
• when otherwise legally authorised or required to do so.
  • By providing your Personal Information to us, you acknowledge that you are authorised to provide such information to us.

 

 

 

 

• Collection from third parties
  • We may also collect Personal Information and non-Personal Information about you from third parties, including:
    • in the case of Authorised Users, from Organisation;
    • in the case of Organisation, from Authorised Users;
    • when you provide your Personal Information to our Authorised Affiliates or other third parties;
    • if you use third party products or services that interact with the MPGO App, the Services or our other products and/or services (for example, third party payment processors).
  • When we collect your Personal Information from third parties, we shall take reasonable steps to make sure you are aware of the collection.
  • If you provide us with Personal Information about another individual (as their authorised representative), we rely on you to:
    • inform them that you are providing their Personal Information to us; and
    • advise them that they can contact us for further information.
  • You must take reasonable steps to ensure the individual is aware of, and consents to, the matters outlined in this Privacy Policy, including that their Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual’s right to access that information, and who we are and how to contact us.
  • Upon our request, you must also assist us with any requests by the individual to access or update the Personal Information you have collected from them and provided to us.

 

• Third party payment processor

We use a third party payment processor to process payments made to us. In connection with the processing of such payments, we do not collect, process, use, share, store or disclose any Personal Information or payment information (such as credit card and bank account details). Rather, all such information is provided directly to our third party processor, Woocommerce and Stripe, whose use of your Personal Information is governed by their privacy policy, which may be viewed at https://woocommerce.com/it/privacy-policy/  and https://stripe.com/au/privacy .

 

4. How we use your Personal Information

 

• Purposes of use and disclosure
  • We do not sell your Personal Information. We only use, process and disclose your Personal Information for the purposes for which it is collected.
  • We use, process and disclose your Personal Information and non-Personal Information to provide or deliver the MPGO App and the Services to you and to make third party products and services available to you.
  • We also use, process and disclose your Personal Information (excluding Sensitive Information) and non-Personal Information to:
    • assist with, or respond to, your queries or respond to, or investigate, complaints raised by you about the MPGO App, the Services, our other products or third party products and services;
    • conduct performance analytics activities (for example, we use your Personal Information (excluding Sensitive Information), in aggregated anonymized form, to improve MPGO App, the Services, our other products or services and the quality of our data, to develop new products and services that meet your needs and understand and manage our risk better);
    • manage, administer, improve, test, develop and upgrade the MPGO App and our other products and services, informing you about scheduled maintenance or outages and managing our relationship with you or to otherwise investigate complaints about the MPGO App, the Services, an Organisation or Authorised User;
    • inform you about the MPGO App, the Services, our other products or services or about offers, promotions, surveys, questionnaires about us, the MPGO App, Services, or other matters which we believe are of interest to you;
    • charge and bill an Organisation to access and use the MPGO App;
    • verifying your identity;
    • for internal record keeping;
    • to comply with our legal and regulatory obligations;
    • for any purpose to which you have consented; and
    • for any other purpose notified to you at the time of collection.
  • In the event of a merger, acquisition or sale of the whole or part of our business or assets, we reserve the right to transfer your Personal Information as part of the transaction, without your consent or notice to you.
• Disclosure to Authorised Affiliates
  • In order to provide or deliver the MPGO App, the Services, our other products or services and third-party products or services to you, we may disclose your Personal Information (but excluding Sensitive Information) and non-Personal Information to:
    • all personnel of an Organisation and other service providers who are involved with, or who provide care and services to, the Authorised User and who have been authorised to access and use the MPGO App and the Services;
    • our parent entity and related bodies corporate, service providers, third party contractors, agents, or suppliers;
    • authorised external service providers who perform functions on our behalf, such internet and technology services providers, app and website software developers, hosting and data storage companies, marketing, advertising and security service providers, third party payment processors, fulfilment companies, credit reporting agents, debt collection agents, market research and recruitment service providers; and
    • external business advisors, such as auditors, lawyers, insurers and financiers,

(collectively, Authorised Affiliates).

• We may also disclose your Personal Information and non-Personal Information:
  • to any other party with your consent and direction;
  • to law enforcement bodies or regulatory authorities to assist with their functions, or as otherwise required or authorised by law; or
  • where we consider it necessary to comply with any applicable law, regulation, legal process, governmental request or industry code or standard.
• When we disclose your Personal Information or non-Personal Information to any of our Authorised Affiliates, we will ensure that they undertake to protect your privacy. These Authorised Affiliates are not permitted to use the information for any purpose other than the purpose for which they have been given access.
• Our Authorised Affiliates may also provide us with Personal Information and Non-Personal Information collected from you. If you disclose Personal Information to an Authorised Affiliates, we rely on you to provide the Authorised Affiliates with consent for us to collect, storage, use, process, alter and disclose your Personal Information.

• Overseas disclosure
  • In the course of providing you with access to, and use of, the MPGO App, the Services and our other products and services, it may become necessary or desirable to disclose Personal Information to Authorised Affiliates located overseas. The countries in which these overseas recipients may be located will depend upon the individual circumstances. However, in the course of our ordinary business operations we commonly disclose Personal Information to:
    • our third party payment processors located in the United States and elsewhere outside of Australia; and
    • our website and app developers located in Australia, Malaysia and the Philippines.
  • The laws where these overseas recipients may be located provide various levels of protection for Personal Information which are not always equivalent to the level of protection that may be provided for in Australia. Where we transfer your Personal Information overseas we will take reasonable steps to ensure that your Personal Information is treated securely and the means of transfer provides adequate safeguards.
  • If you have any questions in relation to the transfer of your Personal Information please contact us using the contact details set out in section 11 below.
• Disclaimer
  • We will not disclose your Personal Information to any third party (other than our Authorised Affiliates) without your written consent, unless:
    • we are otherwise required by the Privacy Act;
    • we are permitted to under this Privacy Policy; or
    • such disclosure is, in our opinion, reasonably necessary to protect our rights or property, avoid injury to any person or ensure the proper functioning of the MPGO App.
  • This Privacy Policy only covers the use and disclosure of information we collect from you. The use of your Personal Information by any third party is governed by their privacy policies and is not within our control.

 

5. Notifiable Data Breaches Scheme

 

In the event of any loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, we will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with notifiable data breach scheme contained in Part IIIC of the Privacy Act.

 

6. Marketing communications

 

• Direct marketing
  • We may use and disclose your Personal Information (excluding Sensitive Information) to send you information about the MPGO App, the Services, our other products or services or information (including third party products and services), and other information that may be of interest to you.
  • These communications may continue, even after you stop using the MPGO App.
• Communication channels
  • We may send this information to you via the communication channels specified at the time you provide your consent.
  • These communication channels may include mail, email, SMS telephone or by customising online content and displaying notices or advertising on the MPGO App.
• Opting-out
  • You can opt out of receiving these communications by:
    • contacting us using the details below; or
    • using the unsubscribe function in the email or SMS.

 

7. Storage and security

 

• Protecting your Personal Information

 

• We take reasonable steps in the circumstances to keep your Personal Information and non-Personal Information safe. We use a combination of technical, administrative, and physical controls to protect and maintain the security of your Personal Information and non-Personal Information.
• Our officers, employees, agents and third-party contractors are expected to observe the confidentiality of your Personal Information and non-Personal Information.
• Wherever possible, we procure that Authorised Affiliates who have access to your Personal Information and non-Personal Information take reasonable steps to:
  • protect and maintain the security of your Personal Information and non-Personal Information; and
  • comply with the Australian Privacy Principles when accessing and using your Personal Information.

 

• No guarantee
  • The transmission of information via the internet is not completely secure. While we do our best to protect your Personal Information and non-Personal Information, we cannot guarantee the security of any Personal Information and non-Personal Information transmitted through the MPGO App.
  • You provide your Personal Information and non-Personal Information to us at your own risk, and we are not responsible for any unauthorised access to, and disclosure of, your Personal Information and non-Personal Information.

 

• Destruction of Personal Information

 

We will destroy or de-identify Personal Information the earlier of 12 months from the effective date of termination of our agreement with you or in circumstances where it is no longer required, unless we are required or authorised by law to retain the information.

 

8. Accessing and correcting your Personal Information
   • We shall use our reasonable endeavours to keep your Personal Information accurate, up-to-date and complete. You have the right to access any Personal Information we hold about you, subject to some exceptions under the Privacy Act.
   • You can access, or request that we correct, your Personal Information by writing to us using the details below. We may require proof of identity. If we do not allow you to access any part of your Personal Information, we will tell you why in writing.
   • We will not charge you for requesting access to your Personal Information but may charge you for our reasonable costs in supplying you with access to this information.
   • We will endeavour to respond to your request for access or correction within 30 days from your request.
9. Privacy complaints
   • If you have any issues about this Privacy Policy or the way we handle your Personal Information, please contact us using the details below and provide full details of your complaint and any supporting documentation.
   • At all times, privacy complaints:
     • will be treated seriously;
     • will be dealt with promptly;
     • will be dealt with in a confidential manner; and
     • will not affect your existing obligations or your commercial arrangements with us.
   • Our Privacy Officer will endeavour to:
     • respond to you within 10 business days; and
     • investigate and attempt to resolve your concerns within 30 business days or any longer period necessary and notified to you by our Privacy Officer.
   • If you are dissatisfied with the outcome of your complaint, you may refer the complaint to Office of the Australian Information Commissioner.

 

10. Children’s policy
    • We may collect and process Personal Information and Sensitive Information from, or about, persons under the age of 18 years of age (Children) without the consent of a parent or guardian.
    • If we become aware or you make a complaint that any Personal Information and/or Sensitive Information relating to a Child has been provided without the consent of a parent or guardian, we will use reasonable endeavours to:

(i)       delete the Personal Information and/or Sensitive Information from MPGO App as soon as possible; or

(ii)       ensure, where deletion is not possible, that the Personal Information and Sensitive Information is not used further for any purpose or disclosed further to any Authorised Affiliate.

• Any parent or guardian with queries regarding our collection, use, processing or disclosure of Personal Information and Sensitive Information relating to their Child should contact us using the details below.

11. How to contact us

We can be contacted by email at info@mpgo.com.au.

 

12. Changes to this Privacy Policy

 

• From time to time, it may be necessary for us to review and revise our Privacy Policy. We may notify you about changes to this Privacy Policy by posting an updated version on the MPGO App and/or Site.
• We encourage you to check the MPGO App and/or our Site from time to time to ensure you are familiar with our latest Privacy Policy.