Any Personal Information and Personal Data collected from you will be used by us in accordance with and as described in this Privacy Statement. Definitions In this Privacy Statement: ·
Any reference to “MindBodyBrain”, “we”, “us” and “our” includes a reference to MindBodyBrain Pty Limited (ACN 144895330); ·
The “MindBodyBrain Service” is defined as the software program which delivers the MindBodyBrain program with all its supporting components. This includes, but it is not limited to, the Resilience Survey, education content, mindset tools, meditations, resources, recipes, exercises and Ritual Board;
The “Corporate Website and Application” is defined as the publicly available information found on www.MindBodyBrain.com. This website is designed to support the marketing of MindBodyBrain Pty Ltd and does not form part of the MindBodyBrain Service beyond the provision of access to the MindBodyBrain Service;
· The “Privacy Act” refers to the Australian Privacy Act (1988);
· The term “Australian Privacy Principles” has the meaning attributed in the Australian Privacy Act (1988);
· “GDPR” means the General Data Protection Regulation, being Regulation 2016/679 of the European Parliament and of the Council;
· The term “Personal Information” has the meaning attributed in the Privacy Act;
· The term “Personal Data” has the meaning attributed to that term in the GDPR;
· “Resilience Survey” refers to the MindBodyBrain online survey which captures information on self-reported resilience and mood.
Collecting Information on Corporate Website Users
MindBodyBrain collects non-Personal Information on corporate website visits by users including, without limitation, which sections of the corporate website are most frequently visited, how often, and for how long. This data is always used as aggregated, non-Personal Information.
MindBodyBrain’s web servers gather your IP address to assist with the diagnosis of problems or support issues with our services, and to monitor the use of our corporate website and application, including the monitoring of the location of our users.
MindBodyBrain captures and records page visits linked to IP addresses
Personal Information is captured where users complete any of the contact forms on the MindBodyBrain Corporate Website. These include, but are not limited to, Contact Us, Request a Demo and registering for any of the MindBodyBrain white papers or other assets.
Collecting Information on users of the MindBodyBrain Service
In order to use the MindBodyBrain Service interested parties must complete the registration process. The registration process collects, but is not limited to, information including first name, last name, email, post code and phone number. Other information collected is grouped as follows:
Resilience Survey: The resilience Survey is made up of a series of questions on resilience and mood and this information is used to provide the user with a baseline score.
Ritual Completion: MindBodyBrain supports our users to make small changes to lifestyle which over time become enduring habits. Using a number of behaviour change tools and techniques users are encouraged to log their day to day attainment. As such, MindBodyBrain logs the completion of these Rituals over an extended period of time.
MindBodyBrain Profile: Users of the MindBodyBrain Service have a profile automatically generated for them. This profile can be viewed at any time using the menu. When users accept Friend requests these Friends automatically gain access to the user’s profile. Users can review access at any time and change settings using the Settings option in MindBodyBrain.
Data Reporting: When using the MindBodyBrain Service as part of a corporate program the corporate sponsor will receive reports on the overall profile of the user population as well as reports on engagement levels. Any information shared with corporate sponsors is aggregated de-identified data. Individual users are not identified via these reports. Reports for corporate sponsors can be segmented into sub groups e.g. individual departments. To minimise the risk of identification of individual users these reports are withheld when the group size is below a minimum threshold of users.
Storage & Security of Personal Information
MindBodyBrain takes all reasonable steps to ensure the security of our system and to protect your information from misuse, interference and loss as well as unauthorised access, modification or disclosure. MindBodyBrain allows you to access your information at any time to keep it accurate and up to date. Any information which we hold for you is stored on secure servers, located regionally in secure facilities. In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality and privacy of any Personal Information held by MindBodyBrain. Except in the case of breaches of our obligations under the Privacy Act to protect your Personal Information, MindBodyBrain will not be held responsible for events arising from unauthorised access of your Personal Information. In the event of a data breach, MindBodyBrain is committed to complying in all respects with the requirements of all Australian Privacy Laws and where required, the provisions of the GDPR. You can also play an important role in keeping your Personal Information secure, by maintaining the confidentiality of any password and accounts used to access the MindBodyBrain Service. Please notify us immediately if there is any unauthorised use of your account by any other user, or any other breach of security relating to your account.
Accessing & Correcting Your Information
Unless you become a Registered User, or contact us via the corporate website, MindBodyBrain does not collect information that identifies you personally. If you become a Registered User, you are able to change or update your Profile at any time by logging in to the ‘Profile’ area of the Site. At MindBodyBrain we do everything we can to keep your personal information accurate. If you find that any information we hold about you is incorrect, you can contact us at support@MindBodyBrain.com.au or as per the contact details below and we will endeavour to assist you with your questions. Please bear in mind that under Australian privacy laws, there may be situations where we cannot provide access to such personal information. For instance, if it would reasonably affect someone else’s privacy.
MindBodyBrain collects Personal Information and Personal Data on registered users of the MindBodyBrain Service. This data is held through the duration of the corporate contract, assuming all users are accessing via a corporate engagement. On completion of the corporate contract all data is anonymised and retained for MindBodyBrain research purposes. This anonymisation process occurs quarterly. Should you wish for MindBodyBrain to delete your Personal Information and Personal Data at any time please contact us at support@MindBodyBrain.com.
Data Sharing & Transfers
MindBodyBrain does not share any data with 3rd parties.
If you have any complaints or feel that there has been a breach of the Australian Privacy Principles, you can contact us at support@MindBodyBrain. If you are not satisfied with the process of making a complaint to MindBodyBrain you may make a complaint to the Information Commissioner on the details below:
Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001 Email: firstname.lastname@example.org Telephone: 1300 363 992 Fax: 02 9284 9666
We understand that your personal information is important to you and are thrilled that you made it this far! If you have any questions or concerns about this policy or our practices you can get in touch with us in the following ways:
Phone: +61 431 386 587
Address: MindBodyBrain , Trading as Body-Brain Performance Institute Pty Ltd, 22 Kunyung Road, MOUNT ELIZA, VIC, 3930
If you are a resident of the European Union for the purposes of the GDPR, then in addition to what is set out above, the following applies to you. MindBodyBrain is a data controller and processor for the purposes of the GDPR and by your consenting to this Privacy Statement MindBodyBrain is able to processes your Personal Data in accordance with this Privacy Statement. Our Contact details are set out in the “Contact Us” paragraph above. In providing its services to you, MindBodyBrain may make use of a number of automated processes using your Personal Data and your activity whilst using the MindBodyBrain Service. In addition to your rights set out above, you may:
· Update or rectify any of the Personal Data that we hold about you, in the manner described in the “Accessing & Correcting Your Information” paragraph above.
· Withdraw your consent to MindBodyBrain’s use of your Personal Information as described in this Privacy Statement by contacting support@MindBodyBrain.com
· Request that MindBodyBrain:
provides you with a copy of the Personal Data MindBodyBrain holds about you in a portable and machine-readable form; or
share your Personal Data with a nominated third party;
All requests can be completed using any of the contact details set out in the “Contact Us” paragraph above. Should you have any concerns in relation to MindBodyBrain’s collection and/or processing of your Personal Data, then in addition to the process set out in the “Complaints Handling“ section above (including the right to complain to the Office of the Australian Information Commissioner), you have the right to complain to a supervisory authority (within the meaning of the GDPR). Our representative for the purposes of the GDPR is set out below:
Director, MindBodyBrain Performance Institute