Privacy Policy

Introduction

NeuroCog® Pty Ltd recognises that your privacy is very important to you and that we are under a legal obligation to protect the integrity of your personal information. In accordance with the Privacy Act 1988 (Commonwealth) and the Health Records and Information Privacy Act 2002 (NSW), we comply with the National Privacy Principles. This page sets out the policy which NeuroCog® Pty Ltd will follow when managing, using and disclosing personal information collected through the website and the App (NeuroCog®).

When this policy uses 'I', 'we', 'us', 'our' or 'NeuroCog®' it means NeuroCog® Pty Ltd. 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 NeuroCog® website and the NeuroCog® App.

What is collected?

The type of information we may collect and hold through the NeuroCog® website and the NeuroCog® App includes personal information about users of the NeuroCog® website and the NeuroCog® App. If your subscription to NeuroCog® requires payment of a fee, we may use payment providers to facilitate the subscription process. The personal information we collect and hold relating to the NeuroCog® website and/or NeuroCog® App consists of:

• age group, gender;
• email address, password nominated by you, and the information you submit when using the NeuroCog® website and the NeuroCog® App (including Emotion Log, Client Feedback and exercises);
• information about your usage of the NeuroCog® website and the NeuroCog® App 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.

Data for research purposes

NeuroCog® website and the NeuroCog® App collects information on your birth year, postcode, gender, as well as your answers to mental health questions and your entries while tracking or completing any of the exercises. This data is referred to as “your input”. This input is stored securely on NeuroCog® servers and is only accessed by those with appropriate authorisation. Your input is used for the following purposes:

• To give you personalised feedback
• To evaluate the usefulness of the program
• To standardise our tools/exercises
• To contribute to e-mental health research outcomes

At no point in time will your data be identifiable when used for research purposes. All of your personal information will remain strictly confidential and all use of data will strictly comply with:

• the institute’s privacy policy, and
• the NeuroCog® specific privacy policy.

How do we collect and hold personal information?

The NeuroCog® website and the NeuroCog® App are 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 NeuroCog®.

We collect personal information from you directly when you provide your information to us by entering data in the NeuroCog® website and the NeuroCog® App or from you indirectly through emails, forms and telephone conversations.

In addition to the information that we collect, 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.

Protection of user privacy is a high priority for NeuroCog® 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 the 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 NeuroCog®’s 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 NeuroCog® website and NeuroCog® App has ended. We typically will delete your information if you have not logged in to the NeuroCog® Website and NeuroCog® App for 24 months. 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 NeuroCog® website), 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?

NeuroCog® allows you to enter and store personal information on a voluntary basis. The NeuroCog® website and NeuroCog® App are 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 NeuroCog® website and the NeuroCog® App for the following purposes:

• to deliver the NeuroCog® 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 of the NeuroCog® website;
• to facilitate payment and management of subscriptions; and
• to comply with our legal obligations.

Who do we disclose your personal information to?

We may disclose your personal information:

• where we are required to do so by law;
• with your prior written consent; 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 NeuroCog® assets or NeuroCog® 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 [email protected]. 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.

Your role in protecting personal information

By keeping your personal information secure and being aware of security, you can play an important part in protecting your personal information. You are responsible for maintaining the security and confidentiality of your username and password. Always log off from NeuroCog® after completing your session, and do not let other people use your NeuroCog® account.

Please notify us immediately if there is any unauthorised use of your account by any other Internet user or any other breach of security.

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 protected]. 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

Cookies Policy

The NeuroCog® website uses cookies to improve the quality of its service. Cookies are pieces of information that are transferred to your computer’s hard disk when you open the NeuroCog® web pages. Cookies by themselves do not collect any personal information but they do identify your browser.

The NeuroCog® Site uses ‘session’ cookies. These are destroyed when you log out or close your browser or exit the Site in any other way. You must allow this cookie in your browser in order to retain your login throughout your visit.

When you use the NeuroCog® Site, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol (IP) address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser. We use this information to evaluate our website performance and continually improve our services for you.

Most web browsers are set up to accept cookies, and while you can set your browser to not accept cookies, the NeuroCog® Site may not function properly if you do this.

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. We may revise this Privacy Policy whenever we choose without notice to you. The changes shall be effective immediately upon posting to the NeuroCog® website unless otherwise stated on the website. You agree to review this Privacy Policy periodically to make sure that you are aware of any changes. By continuing to use this website, you accept the Privacy Policy then currently in effect.