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Privacy Policy

Our privacy commitment

Worry Safe is committed to protecting the privacy of your personal information. We manage your personal information in an open and transparent way.

We will only use your personal information when it is necessary for us to undertake our services or perform other necessary business functions and activities.

We will not use or disclose your personal information for purposes unrelated to our services or business, unless we first obtain your consent.

Who are we and how to contact us

‘We’, ‘us’, ‘our’ refers to Struthio Pty Ltd t/a Worry Safe (ACN 663 559 340) and our Worry Safe app and website, www.worrysafe.com.

If you have any questions regarding our Privacy Policy, please contact us.

The Privacy Officer
Worry Safe
Email: hello@containyourbrain.com

Privacy

To the extent necessary, the Privacy Act 1988 (Australia) and Australian Privacy Principles regulate how applicable businesses may collect, use, disclose and store personal information.  These laws also specify how individuals may access and correct personal information held about them.

‘Personal Information’ means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. For example, these types of information could include your name, contact details, age, image and health information.

By visiting our website and/or providing your personal information or data to us, you consent to the terms and conditions in this Privacy Policy, unless you tell us to the contrary by contacting us.

Our Privacy Policy is effective from the moment it’s published on our websites.  From time to time, our policies and procedures will be reviewed and, if appropriate, updated.  If any changes are made to our Privacy Policy then the most recent version will be posted on our websites.

Personal Information Handling

From whom does Worry Safe collect personal information?
We may collect personal information from clients, employees and suppliers (including prospective ones), employee referees and their next of kin, our network, associations and partners with whom we collaborate, participants in courses that we make available, the public at large and regulators.

How and why does Worry Safe collect and hold your personal information?
We will only collect personal information about you by lawful and fair means, and not in an unreasonably intrusive manner.

We do not require or collect your personal information to use the Worry Safe App. Upon purchase, the app is installed on your phone for your personal use. The Worry Safe app enables you to password protect and or access the app via fingerprint or facial recognition as to provide you with additional security. The privacy, confidentiality and security of the information your store in the App is your sole responsibility as set out in the Worry Safe Terms of Service (Terms and Conditions).

On the Worry Safe website, it is our usual practice to collect personal information directly from you when you:

  1. open an account with us
  2. subscribe or sign up to one of our courses
  3. seek our services
  4. subscribe to our email newsletters or communications
  5. join, like or comment on our business pages and groups on social media sites e.g. Facebook, LinkedIn & Instagram
  6. apply for or obtain a job with us or participate in alumni events
  7. quote, tender or provide us with goods or services, or such other means by which we may source goods or services
  8. request information from us
  9. visit or use our websites or services (including any participation in forums)
  10. complete an online form on one of our websites or social media channels
  11. participate in a survey, enter a trade promotion or competition
  12. complete a hard copy form
  13. speak with us or one of our representatives
  14. contact us, including without limitation by telephone, mail, e-mail, messenger service, chat function or online

We may also collect personal information about you from a third party or a publicly available source (including social media), but only if you have consented to such collection, or would reasonably expect us to collect your personal information in this way, for instance job applicants and employees provide referee and next of kin details to us, clients might provide us with trade references, participants in and audiences at events that we stream.

If you participate in a Course (including group Courses), discussion forum, chat room or webinar, you should be aware that the information you provide might be made broadly available to others, potentially inside or outside our organisation, who have access to that group, discussion forum, chat room or webinar.  

If we receive information about you from a third party and we don’t need it in respect of our business activities or record keeping requirements, we will use our reasonable endeavours to destroy or de-identify that information (provided it is lawful to do so).

What kind of personal information does Worry Safe collect and hold?

Any personal information that you provide via our websites or directly is collected and managed by Worry Safe.

If you provide your personal information to a third party, eg via a link from a Worry Safe website or an introduction from us or a group course that we make available, that information is collected and managed by those third parties. You should familiarise yourself with their privacy policy prior to deciding whether you wish to provide them with your information.

The types of personal information Worry Safe may collect includes your:

  1. name;
  2. date of birth;
  3. gender;
  4. marital status and family details;
  5. residential, business and postal address;
  6. email address;
  7. contact telephone numbers;
  8. employment and education history;
  9. identification details;
  10. testimonials or opinions;
  11. images, audio & videos of you;
  12. financial information, such as salary bands;
  13. written or verbal contact with Worry Safe, including voice recordings of telephone conversations you have had with our employees; and
  14. activities, including but not limited to lifestyle and other interests.

Whilst you may opt not to provide us with your personal information, you should be aware that without this personal information, we might not be able to do business with you, employ you, seek your input or feedback, provide you with some of the courses, services and/or products you are seeking.

If you provide us with information about any third party, you must obtain that person’s permission to give us the information and inform them that you have given the information to us.

How does Worry Safe use your personal information?

We use your personal information for a variety of reasons including to:

  1. contact you
  2. provide our services, including (without limitation) making information, resources and courses available to you
  3. conduct market research, trade promotions or competitions
  4. to seek your opinion
  5. answer your inquiries
  6. deliver customer service or account management
  7. promote a testimonial from you
  8. enable us to undertake a credit assessment
  9. consider receiving goods or services
  10. meet our legal obligations
  11. consider making offers for employment purposes
  12. manage and resolve any legal, consumer or commercial complaints and issues
  13. carry out internal functions including training
In what circumstances will Worry Safe disclose your personal information?

In the course of conducting our business we may disclose your personal information.

We only disclose personal information for the purposes for which it was given to us, or for purposes which are directly related to one of our functions or activities.  We do not give it to anyone else unless one of the following applies:

  1. you have consented to the disclosure,
  2. you would reasonably expect, or have been told, that your information is passed to those individuals, businesses or agencies,
  3. it is necessary for us to provide our services, or
  4. it is otherwise required or authorised by law.

If we engage third party agents or contractors, we will take all reasonable steps to ensure that they do not breach privacy requirements in relation to the information, before we share your personal information with them.

Who does Worry Safe disclose your personal information to?

We may disclose your personal information to:

  1. a related business or entity
  2. to companies that provide us with goods or services or perform services on our behalf
  3. professional advisers (such as lawyers or accountants)
  4. payment systems operators, financial institutions, superannuation funds
  5. organisations authorised by us to conduct promotional, research or marketing activities
  6. upon lawful request from law enforcement agencies or government authorities
  7. any persons acting on your behalf including those persons nominated by you, including executors, trustees and legal representatives.

In all circumstances where your personal information is disclosed, we will take reasonable steps to ensure that these third parties undertake to protect your privacy.

Direct marketing

We are committed to compliance with all laws and requirements relating to the use of your personal information.  We will only use or disclose your personal information for direct marketing purposes if you have provided your information for that purpose (or you would expect us to use the information for that purpose), or if you have provided consent for your information to be used in this way.

From time to time, we may contact you with information about opportunities, products and services offered by us, our related entities, our clients and our business partners, which we think may be of interest to you.  When we contact you it may be by mail, telephone, email, SMS/text message or social media message.

Where we use or disclose your personal information for the purpose of direct marketing, we will:

  1. allow you to request not to receive direct marketing communications (also known as ‘opting-out’); and
  2. comply with your request to ‘opt-out’ of receiving further communications within a reasonable timeframe.

Worry Safe will only ever contact you if it’s necessary to communicate with you about our business relationship or if you have consented to this, and you can ask to be removed from our marketing lists at any time by contacting us directly.

If you do not wish to be contacted by us please e-mail us at hello@containyourbrain.com and put Privacy in the subject line.

Does Worry Safe disclose your personal information to overseas recipients?

Your personal information may be disclosed to or stored with our related entities, clients, business partners and service providers in Australia and overseas.  

The jurisdictions this information may be disclosed to will vary from time to time, but may include Australia, the United States of America and the European Union.

Sometimes we use third party platforms and services, including cloud services, to store, backup and process data (including financial data), provide support, account manage, send marketing messages, facilitate our services, customer relationship management. These services are hosted and managed by organisations other than ourselves, and some of these services are hosted overseas. We use products and services maintained in Australia, the United States of America and the European Union.

All such third parties are bound by the same laws and regulations that we are, wherever they are located in the world, and we require them to adopt and apply data protection policies and practices that are consistent with this policy.

How you can access or correct your personal information

You can request access to the personal information we hold about you at any time, and we will provide you with that information unless we are prevented by law from giving it to you.

If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.

You will not be charged for accessing your information, although we might have to charge the reasonable cost of processing your request, including photocopying, administration and postage. We will advise you of any fee payable before we process your request.

If you believe that your personal information is not accurate, complete or up to date or you have any other privacy concerns then please contact us (refer to details above).

If you consider your privacy concerns have not been resolved satisfactorily by us, or you wish to obtain more information on privacy requirements, you can contact the Office of the Australian Information Commissioner on 1300 363 992 or visit their website at www.oaic.gov.au.

General

Use of Government Identifiers

We will not use Government Identifiers, such as a driver's licence number as its own identifier of individuals.

Data Quality and Security

We will take all reasonable steps to ensure that your personal information is stored securely and is protected from misuse and loss and from unauthorised access, modification or disclosure.

The personal information that we collect about you is stored on our internal and third-party database servers & filing systems managed by us in Australia.

Website usage

Our website is professionally hosted and operates in a secure environment. You should however be aware that there is always an inherent risk in transmitting your personal information via the Internet.

To make sure you are accessing a secure server, check for the unbroken key or closed lock symbol located generally near a corner of your browser window or the address bar.  If it appears, then SSL is active. You can double check this by looking at the URL as well. If SSL is active, then the first characters of that line will read ‘https’ rather than just ‘http’. It is important for you to protect against unauthorised access to your password and to your computer.

Ensure you logout when you have finished visiting our websites especially if you accessed them from a shared computer.

Cookies

Cookies are pieces of information that a website transfers to your computer for record-keeping purposes. The information collected may be used by us to improve your experience on our website.

If you visit an area of the website where you are not required to log on, to read, browse or download information, our system might record the date and time of your visit to our site, the pages viewed and any information downloaded.

Any personal information that you submit to us using our website or in an e-mail will only be used in accordance with this privacy policy.

Our websites use Google Analytics Services, for more information about cookies used, see Google Cookies Policy.

Links to third-party sites

Whilst links to third party websites may be provided on our website, we are not responsible for the content or practices of these third party websites.

These links are provided for your convenience and do not represent our endorsement of any linked third-party website. We recommend that you check the privacy policies of these third parties prior to providing them with your personal information.

No links may be made to this website without our prior written consent.

Business transactions

Worry Safe may assign or transfer this Privacy Policy, and your user account and related personal information, to any person or entity that acquires all or substantially all of the shares, business or assets of, or is merged with Worry Safe. We may also transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, liquidations, dissolutions, or similar transactions or proceedings, provided that the recipient of such information will continue to be bound by the terms of this Privacy Policy.

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