1. Our commitment to your privacy
Spokle Group Ltd [ACN 612 554 739] (“Spokle”) is committed to protecting and respecting your privacy. We are bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth) (“the Privacy Act”).
Personal information is defined in the Privacy Act and means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
Spokle owns and operates the Website across desktop, mobile, tablet and apps and including any subdomains.
2. Why do we collect your personal information?
We only collect personal information for the purposes of conducting our business as an online service provider (which includes providing remote therapy support). The personal information we collect from you will include information you give us when you:
(a) register or subscribe to the Website or Applications;
(b) communicate with us through correspondence, chats, email, or when you share information with use from other social applications, services or websites or;
(c) interact with our speech and language rehabilitation services or other content.
3. What personal information do we collect?
The personal information that we collect on individuals may include, but is not limited to:
(a) your name;
(b) your location;
(c) your contact details including your telephone numbers, email, home/delivery address and billing address;
(d) your payment details;
(e) language or speech difficulties;
(f) age or date of birth;
(g) device ID, device type, geo-location information, computer and connection information, statistics on page or app views, traffic to and from the Website and Application and standard web log information;
(h) your gender;
(i) your child’s name;
(j) your child's age or date of birth;
(k) your child’s gender;
(l) health related information about your child such as their speech and language abilities; and
(m) other personal information that we collect in the course of a transaction or that you provide to us when you contact us.
We only collect sensitive information in circumstances where you consent to the collection of this information, or it is reasonably necessary for, or directly related to, the purposes outlined above.
4. How do we collect your personal information?
We will collect your personal information through various channels. These may be in person, over the phone, by post, facsimile or online through our Website and Applications.
Where reasonably practicable, we attempt to collect information directly from individuals, and in the case of a child, from their guardian. When we collect information, we will generally explain to the individual why we are collecting it, to whom we give it and how we will use or disclose it or, alternatively, those matters will be obvious from the circumstances.
The Website or Application may have a pop up which asks you for permission to access your location. This is in order for the Website or Application to provide the best possible services to you and to tailor the Website or Application to your location.
5. How do we use your personal information?
If Spokle holds personal information that was collected for a primary purpose, then Spokle must not disclose the personal information for a secondary purpose unless users have consented to the use of the personal information or the users would reasonably expect that Spokle would use the information for the secondary purpose which is directly related to the primary purpose.
We may collect, hold, use and disclose your personal information for the following purposes:
- to enable you to access and use our Website and Application;
- to operate, protect, improve and optimise our Website, Application, services, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
- to administer surveys or other promotional activities or events sponsored or managed by us or our business partners; and
- to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.
If we collect information about an individual from someone else, we will take reasonable steps to ensure that the individual is made aware of the matters above. In the event that Spokle receives unsolicited personal information, then Spokle will, as soon as practicable but only if lawful, destroy the information or ensure that the information is kept confidential.
We will collect personal information from you by lawful and fair means and not in an unreasonably intrusive way.
We may send you direct marketing communications, information about our products and services, conduct surveys and contact you for trouble-shooting. This may take the form of emails, SMS, mail or other forms of communication, in accordance with applicable laws. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).
6. To whom do we disclose your personal information?
(a) our employees and related bodies;
(b) third party suppliers and service providers;
(c) payment system providers; and
(d) specific third parties authorised by you to receive information held by us; and/or
(e) other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
7. Collection of non-personal information
Spokle may collect non-personal information on the Website visits including, without limitation, which sections of the Website are most frequently visited, how often, and for how long.
Spokle may also collect non-personal information on its Applications including, without limitation, which part of the apps are most used, how often and for how long they are used.
This data is always used as aggregated, non-personal information, and may be shared with Spokle partners to provide them with information relating to how Spokle visitors access and use the Website and Applications. This is done for the purpose of providing you with the best and most efficient services.
8. How do we provide security of personal information?
We take reasonable steps to protect the personal information we hold against loss, unauthorised access, use, modification or disclosure and against other misuse. When no longer required, personal information is destroyed in a secure manner or deleted.
9. How can you access your personal information?
Under the Privacy Act you have certain rights to access the personal information we collect and hold about you.
Information we hold about you can be accessed by logging into your account on the Website or Applications, or by contacting us for further information. We will provide this information to you within a reasonable time. When requesting such access, please identify the precise type(s) of information requested.
We will process your request to provide you with your personal information held by us within 30 days. However, your rights to access personal information are not absolute and privacy laws dictate that we are not required to grant access in certain circumstances.
If we refuse to grant you access to your personal information, we will provide you with reasons for that decision (unless it is unreasonable to do so). If you would like to appeal this decision, we will inform you of the avenues available to do so.
If you would like a relative or spouse to have access to your account, we will require your written or verbal consent before speaking with them.
10. How can you update or correct your personal information?
We take reasonable steps in the circumstances to ensure that the personal information that we collect, use and disclose is accurate, up to date and complete. Where an individual requests to have personal information corrected, we will take reasonable steps to correct the information, having regard to the purpose(s) for which it is held.
To request your personal information to be updated, please contact us at firstname.lastname@example.org
11. Disclosure of personal information outside Australia
We may disclose personal information outside of Australia to third party suppliers and service providers located in countries where we market our product (which currently includes Australia, Indonesia and New Zealand).
We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.
12. How can you complain about privacy and the Spokle Website or Applications?
Any complaints received by us will be referred for prompt investigation by our compliance team and a written response will be provided to you as soon as possible.
If you are not satisfied by our response, you may acquire further information regarding privacy from the Office of the Australian Information Commissioner.
13. What happens if there are Privacy & Website Changes?
14. How can You Contact Us?