Privacy Policy
SleepWellBaby (we, us, our) is bound by and committed to complying with its obligations under, the Privacy Act 1988 (Cth) (Privacy Act) and General Data Protection Regulation EU and UK (GDPR) in relation to your personal information.
Personal information
Personal information is information about you, or which identifies you, such as your name, contact details, and records of your dealings with us. It includes sensitive information about you, such as health information.
The types of personal information that we typically collect include:
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Users of the SleepWellBaby Platform & Programs: Email address and responses to our questions in providing the Program to you. Where follow up is indicated, we may collect your phone numbers and work and home addresses.
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Business contacts: Your work contact details and information about our business relationship with you.
Why we handle your personal information
We collect, hold, use and disclose your personal information for the following purposes:
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to interact with you
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provide you with our services and products, including our SleepWellBaby Platform and Programs
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to maintain our business records
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to provide you with information about products and services that may be of interest to you
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to obtain payment for services that we provide to you such as from your health fund or employer
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to connect or refer you to other health provider(s) or specialist services
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any purpose required or permitted by law
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any purpose disclosed to you and to which you have consented
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any purpose that you would otherwise reasonably expect, and
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otherwise to run our business including development and research
Collection of your personal information
We only collect personal information by lawful and fair means. We collect personal information directly from users when they engage with our SleepWellBaby Platform and Programs.
Disclosing your personal information
We will not sell or rent any of your personal information. We may disclose your personal information to third parties, such as:
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your agents or representatives, including your general practitioner or medical specialist.
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government, regulatory and law enforcement authorities.
Where you are engaging with our SleepWellBaby Platform and Programs through a service provider or employer, the personal information you provide to SleepWellBaby will be confidential. Your service provider or employer will not access any of that information, although we may report aggregated, anonymised information about users to the provider.
Accessing and correcting your personal information
Right to access: A user of SleepWellBaby has the right to view all personal information that we have collected about them, as well as the disclosure of this data. To receive a copy of this data, please contact our Chief Technology and Data Protection Officer. The first copy of this information is provided free of charge, and in a portable / common electronic form (e.g., CSV file). After this, we may seek to recover reasonable costs incurred for data retrieval.
Right to accuracy: A user of SleepWellBaby has the right to ensure that the data we have stored is accurate. In most cases, the system allows you to directly modify your own information. However, if there is incorrect data within our system that you are not able to change, please contact our Chief Technology and Data Protection Officer and we will work directly with you to update this information.
Right to deletion: A user of SleepWellBaby has the right to request deletion of all data within the system. To request your data be deleted, please contact our Chief Technology and Data Protection Officer. In most cases, your request will be completed within 30 days. If circumstances require a delay to this deletion, we will notify you directly explaining the reason for the delay. If there is a legal requirement to hold on to your data, we will notify you directly.
Right to withdraw consent: A user of SleepWellBaby has the right to withdraw their consent at any time by contacting our Chief Technology and Data Protection Officer. Please note that without consent to process your data, we will be unable to deliver the SleepWellBaby program.
Right to notification of disclosure: In addition to the right to request disclosures of your data specified in the "right to access" above, we will notify you as required by law if there has been a breach of the security of your identifiable health information.
Cookies
We may store cookies (small text files managed by your web browser) on your computer in order to improve your experience with SleepWellBaby Programs. For example, we use cookies to recognise you when you return and maintain your data, survey responses and personal preferences for your convenience.
You may refuse to accept cookies by changing the settings on your device to prevent cookies from being set. However, if you select this setting you may be unable to access certain parts of SleepWellBaby’s Programs. Unless you have adjusted your browser setting so that it will refuse cookies, our system may issue cookies when you visit us.
Security of your personal information
We hold your personal information in both paper-based and electronic files. Electronic information is transferred to and stored on a secure third party server within Australia. We seek to ensure that personal information that we hold is protected from misuse, interference and loss caused by unauthorized access, modification or disclosure. Our employees and agents are obliged to treat any personal information held by us confidentially.
SleepWellBaby will retain all health-related information in electronic format only and for a period of at least 7 years and may thereafter dispose electronically.
Marketing
We may use the personal information that we hold about you, including your contact details, to provide you with information about products and services that may be of interest and value to you. These products and services may be offered by us, or one of our preferred suppliers by various means including by mail, telephone, SMS, push notifications, or through social media or targeted advertising through SleepWellBaby or non-SleepWellBaby websites or products or services, You may opt-out of receiving all or certain types of marketing information from us at any time from within the SleepWellBaby app or by contacting us at the details provided below.
Questions and complaints
If you believe that any of your rights with respect to your or others’ identifiable health information have been violated by us, our employees or agents, please contact our Chief Technology and Data Protection Officer. You may also lodge a complaint with the Office of Australian Information Commissioner by calling 1300 363 992 or sending an email to enquiries@oaic.gov.au.
Changes to this Privacy Policy
We reserve the right to revise this Policy without notification. Any changes or updates will be effective immediately upon posting to our website. Your continued use of SleepWellBaby Programs constitutes your agreement to abide by the Privacy Policy as changed. Under certain circumstances (for example, if we expand the ways in which we use your personal information beyond the uses stated in our Privacy Policy at the time of collection), we may also elect to notify you of changes or updates to our Privacy Policy by additional means, such as by sending you an email.
Cyber security standards followed by our organisation?
We are ISO 27001 certified. This certification means that we follow the global best-practice approach to effectively identify and assess threats and monitor our information security risks by addressing people, processes, and technology. It means that we have security built into every facet of our operations and strive to improve our security posture through continuous improvement.
Who can you contact?
Chief Technology and Data Protection Officer
Daniel Butt
daniel.butt@sleepfit.com.au
Suite 1, 11 West St,
North Sydney,
NSW, Australia 2060
These terms and conditions were last updated on 22nd June 2023.