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FollowApp Care Limited

Website Privacy Notice

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FollowApp Care Limited

Privacy Notice

Application Registration & Website Users in Australia

Last Updated: 11th January 2024

Who we are and what we do

We are FollowApp Care Limited (“FollowApp”, “we”, “us”, “our”). We are a limited company registered in England and Wales, registration number 09356705, with our registered office at 19 Wimpole Street, London, United Kingdom, W1G 8GE. We are a Controller of the Personal Data we process, registered in the UK with the Information Commissioner’s Office (“ICO”), registration number ZA160682.

We are a business-to-business provider of fully managed transport services for agencies, employers, schools and universities.

We are committed to the protection of the Personal Data we process in line with the data protection principles set out in the relevant Data Protection Laws. These Data Protection Laws include the Commonwealth Privacy Act 1988 (Privacy Act), Spam Act 2003, and the Australian Privacy Principles (APPs), collectively referred to herein as the “Data Protection Law”.

Personal Data means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or job role, or an online identifier such as a username or IP address.

Purpose of this privacy notice

The purpose of this Privacy Notice (this “Notice”) is to explain what Personal Data we collect and how it is processed. This Notice also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below in the ‘How to contact us’ section. 

Who this Notice applies to

This Notice applies to you if:

• you visit our website;
• you download and register on the FollowApp Application (the “Application”);
• you are a Customer;
• you enquire about our services; or
• you sign up to receive newsletters or other promotional communications from us.

Personal Data we collect

The type of Personal Data we collect will depend on our relationship with you, but may include your:

• Name;
• Company Name;
• Job Title;
• Email Address;
• Phone Number;
• Mobile Phone Provider;
• Mobile Data Provider
• Medical or health information;
• Device Identifiers;
• Location Data;
• Payment Details;
• Cookie Information; and
• Any other information you provide to us.

The above list is not exhaustive and may change.

How we collect it

We collect most of the Personal Data directly from you in person, by telephone, text, email, via our website or App. However, we may also collect your Personal Data from:

• events and webinars;
• reputable companies who provide lead generation contact lists;
• other companies to whom you have provided consent to share your Personal Data; or
• publicly available sources, such as social media platforms.

Purposes for which we use Personal Data and the legal bases

We will only use your Personal Data when the law allows. Most commonly, in the following circumstances:

Where Personal Data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.

Sharing your Personal Data

We may share your Personal Data with trusted third parties who provide us with services relevant to our provision of services to you. This includes our providers of medical services (External Services), professional advisers, IT service providers, cloud software provider and other suppliers and sub-contractors.

If the third party needs access to any of your Personal Data to carry out any of the activities described above, we will ensure your Personal Data is handled safely, securely and in accordance with your rights, our obligations and the third party or our client obligations under the law. We will do this by entering into a Data Processing Agreement with them. This will ensure that the third-party company will only process your Personal Data in accordance with our strict instructions and will not use it for their own purposes.

In some limited circumstances, we may be legally required to share certain Personal Data, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. Our lawful basis in these circumstances is legal obligation or legitimate interests, depending on the situation.

How long we keep your data

We will retain your Personal Data for as long as is necessary to provide you with our services and for a reasonable period thereafter to enable us to meet our contractual and legal obligations and to deal with complaints and claims.

At the end of the retention period, your Personal Data will be securely deleted or anonymised, for example by aggregation with other data, so that it can be used in a non-identifiable way for statistical analysis and business planning.

Security of your information

We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. We will store all the personal information you provide on our secure (password and firewall protected) servers.

While we use SSL encryption to protect data in transit, transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You are responsible for keeping your password and other login details confidential. We will not ask you for your password (except when you log in to the Application). If you lose your password or give it out, your personal information may be compromised. If that happens, please use the “Forgot Password” button on the Application’s login page to change your password immediately. We cannot be held responsible for your failure to keep your password secure and failure to do so may violate the terms in our ‘Legal Information’ section.

International Transfers

FollowApp is a UK-headquartered, global business and to respond properly to your enquiry or provide you with our services, your personal information may be disclosed to third parties (some of whom are data processors) who assist us to carry out the above activities both inside and outside of Australia, such medical and health service providers, overseas data storage (including ‘cloud’ storage) and data handling providers, legal and other professional advisers. Some of these third parties may be located in other countries including in Europe or the USA.

It is possible that we may be required to share your data to comply with applicable laws or with valid legal processes, such as in response to a court order or with government or law enforcement agencies.

Your rights and how to exercise them

Individuals whose personal data we hold, and process have the following rights:

• You have the right of access to your personal data and can request copies of it and information about our processing of it.
• If the personal data we hold about you in incorrect or incomplete, you can ask us to rectify or add to it.
• Where we are using your personal data with your consent, you can withdraw your consent at any time.
• Where we are using your personal because it is in our legitimate interests to do so, you can object to us using it this way.
• In some circumstances, you can restrict our processing of your data, request a machine-readable copy of your personal data to transfer to another service provider and compel us to erase your personal data

If you wish to exercise your rights, please contact us at info@followapp.care.

If the information that we hold about you is incorrect or not up to date, we will update it as soon as possible after you have shown us how and why it is incorrect.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. In the unlikely event that we are unable to provide you with access to your Personal Information for legal reasons as specified in the Privacy Act, we will provide you with reasons for denying access

If you wish to make a complaint, you can write to the Privacy Officer at the address provided below. We will respond to your complaint within one month.

In addition to the above, if you are not satisfied with our response to your complaint, question or concern, you may wish to lodge a complaint with the Office of the Australian Information Commissioner. Further information can be found on the Commissioner’s website at https://www.oaic.gov.au/or by calling (+61) 1300 363 992.

How to contact us and our Data Protection Officer

If you wish to contact us in relation to this Notice or if you wish to exercise any of your rights, please contact us as follows:

FollowApp Care Limited

19 Wimpole Street

London

W1G 8GE

Email: info@followapp.care

We have also appointed a Data Protection Officer (“DPO”), Evalian Limited, who can be contacted at dpo@evalian.co.uk.

Changes to this Notice

We may update this Notice from time to time. When changes are made, we will amend the ‘last updated’ date at the top of this Notice. We will also notify you of the changes where required by applicable law to do so.