BRITECHILD – PRIVACY POLICY

Quirky Kid Pty Ltd (ABN 60 606 832 606) (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our website and online psychology telehealth platform (Services) or when otherwise interacting with you.

This Privacy Policy takes into account the requirements of the Privacy Act 1988 (Cth), the Australian Privacy Principles as well the requirements of the New Zealand Privacy Act 2020 and the Information Privacy Principles. In addition to the Australian and New Zealand privacy laws, individuals located in the European Union or European Economic Area (EU) may also have rights under the General Data Protection Regulation 2016/679 and individuals located in the United Kingdom (UK) may have rights under the General Data Protection Regulation (EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (DPA 2018) (together, the GDPR).

Appendix 1 outlines the details of the additional rights of individuals located in the EU and UK as well as information on how we process the personal information of individuals located in the EU and UK.

The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

Identity Data including first name, last name, date of birth, gender and pronouns.
Contact Data including billing address, email address and telephone numbers.
Financial Data including bank account and payment card details (through our third party payment processor, Stripe).
Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.
Technical and Usage Data including internet protocol (IP) address, your login data, your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.
Profile Data including your username and password for the BriteChild platform, profile picture, purchases or orders you have made with us, support requests you have made, content you post, send receive and share through our platform, information you have shared with our social media platforms, your interests, preferences, feedback and survey responses.
Interaction Data including information you provide to us when you participate in any interactive features of our Services.
Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
Professional Data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.

We may collect the following personal information from:

you, if you are a staff member or student at a school which has an account with us, and you have a consultation booked with one of our psychologists; or
your child, if you are a parent or caregiver who has signed up your child to use our Services:

Identity Data including your child’s first name, last name, date of birth and gender.
Profile Data including content your child may send, receive and share through our platform and information they have shared with our Services including their interests, preferences, feedback and survey responses.
Technical and Usage Data including internet protocol (IP) address, your login data, your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.
Sensitive information is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. In the course of providing our Services, we may collect, or come across such sensitive information in different situations, including when we provide a consultation to your child. The types of sensitive information we may collect include detailed information about your child’s:

current medications; physical health; racial or ethnic origin; religious beliefs; philosophical beliefs; political beliefs or affiliations; sexual orientation or practice; and any other sensitive details you or your child chooses to share with us.

How we collect personal information

We collect personal information in a variety of ways, including:

Directly: We collect personal information which you directly provide to us by you or your child, including when you register for an account, through the ‘contact us’ form on our website or when you request our assistance via email, or over the telephone.
Indirectly: We may collect personal information which you or your child indirectly provide to us while interacting with us, such as when you or your child uses our Services, during a psychology telehealth consultation, when you use our website, in emails, over the telephone and in your online enquiries.
From third parties: We collect personal information from third parties, such as your referrals from health care professionals, details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.

Why we collect, hold, use and disclose personal information

We have set out below, in a table format, a description of the purposes for which we plan to collect, hold, use and disclose your personal information.

Purpose of use / disclosure	Type of Personal Information
To enable you and your child to access and use our software, including to provide you with a login.	Identity Data Contact Data Financial Data Transaction Data
To provide our Services to you, including to assess your application to become a member of the BriteChild platform and manage your consultation bookings.	Identity Data Contact Data Profile Data
To contact and communicate with you about our Services including in response to any support requests you lodge with us or other enquiries you make with us.	Identity Data Contact Data Profile Data
To contact and communicate with you about any enquiries you make with us via our website.	Identity Data Contact Data
For internal record keeping, administrative, invoicing and billing purposes.	Identity Data Contact Data Financial Data Transaction Data
For analytics, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms.	Profile Data Technical and Usage Data
For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.	Identity Data Contact Data Technical and Usage Data Profile Data Marketing and Communications Data
To run promotions, competitions and/or offer additional benefits to you.	Identity Data Contact Data Profile Data Interaction Data Marketing and Communications Data
If you have applied for employment with us; to consider your employment application.	Identity Data Contact Data Professional Data
To comply with our legal obligations or if otherwise required or authorised by law.	Any relevant Personal Information
Sensitive information: We only collect, hold, use and disclose sensitive information for the following purposes: any purposes you consent to; the primary purpose for which it is collected, such as to provide psychology services to your child, students or educators of your school; secondary purposes that are directly related to the primary purpose for which it was collected, including disclosure to the below listed third parties as reasonably necessary to provide our Services to you; to contact emergency services, or to speak with your family, partner or support person where we reasonably believe there is a serious risk to the life, health or safety of you or another person and it is impracticable for us to obtain your consent; and if otherwise required or authorised by law.	Sensitive Information

Our disclosures of personal information to third parties

We may disclose personal information to:

you, as the parent or caregiver of the child;
health care professionals as required for the purpose of providing health care services to you or your child;
our employees, contractors and/or related entities;
supervision service providers as necessary to meet professional obligations;
IT service providers, data storage, web-hosting and server providers such as Calendly;
marketing or advertising providers;
professional advisors, bankers, auditors, our insurers and insurance brokers;
payment systems operators such as Stripe;
our existing or potential agents or business partners;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Meta Pixel or other relevant analytics businesses; and
any other third parties as required or permitted by law, such as where we receive a subpoena.

Google Analytics: We may have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits and Google Display Network Impression reporting. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.

You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.

Overseas disclosure

New Zealand Residents

Where we disclose your personal information to third parties listed above, these third parties may store, transfer or access personal information outside of New Zealand, which may not have an equivalent level of data protection laws as those in New Zealand. Before disclosing any personal information to an overseas recipient, we will comply with Information Privacy Principle 12 and only disclose the information if:

you have authorised the disclosure after we expressly informed you that the overseas recipient may not be required to protect the personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020;
we believe the overseas recipient is subject to the Privacy Act 2020;
we believe that the overseas recipient is subject to privacy laws that, overall, provide comparable safeguards to those in the Privacy Act 2020;
we believe that the overseas recipient is a participant in a prescribed binding scheme;
we believe that the overseas recipient is subject to privacy laws in a prescribed country; or
we otherwise believe that the overseas recipient is required to protect your personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020 (for example pursuant to a data transfer agreement entered into between us and the overseas recipient).

Australian Residents

We take reasonable steps to use Australian based third-party service providers where practicable. However, occasionally these providers are located outside of Australia or need to transfer or access your information outside of Australia to assist us in providing our Services to you and some information is held on our servers, or service provider servers, that can be located in the USA.

By providing us with personal information, you understand we may need to disclose your information outside of Australia. You understand and acknowledge that where we disclose personal information to a third party outside of Australia, we will only use reputable third parties and we will only disclose the personal information necessary for the recipient to assist us in supplying our Services to you.

Your personal information will not be used, sold, rented or disclosed for any other purpose.

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your child and your and your child’s use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee will be payable for the provision of such information to reflect the cost of searching, accessing and providing you the information. We may, in our sole discretion, waive the administrative fee. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner or the Office of the New Zealand Privacy Commissioner.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure your personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. These procedures include:

securing any personal information we hold in an electronic format behind password logins (typically with multi factor authentication);
securing any personal information we hold in physical files in a locked cabinet;
encrypting data, using virus protection software, implementing firewalls; and
limiting internal access to the personal information we hold about you based on a need to know basis.

Although we take measures to safeguard against unauthorised disclosures of information, due to the inherent risks associated with the Internet, we cannot assure you that the personal information we collect and send over the Internet, will not be disclosed in a manner that is inconsistent with this Privacy Policy.

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our online Services. They include, for example, cookies that enable you to log into secure areas of our online Services, use a shopping cart or make use of online payment services.
Analytical/performance cookies. These are cookies that allow us to recognise and count the number of visitors to our online Services and to see how visitors move around our online Services when they are using them. This helps us to improve the way our online Services work, for example, by ensuring that users find what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our online Services. These cookies enable us to personalise our content for you and remember your preferences (for example, your choice of language or region).
Targeting and advertising cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Social media cookies. These cookies are used when you share information using a social media sharing button or “like” button on our websites or you link your account or engage with our content on or through a social media site. The social network will record that you have done this. This information may be linked to targeting/advertising activities.

You can find more information about the individual cookies we use, their category, and the purposes for which we use them in the table below:

Cookie	Category	Purpose
Currency	Functionality	This cookie stores the currency used for the online Services.
Language	Functionality	This cookie stores the language used for the online Services.
PHPSESSIONID	Analytical/performance	This cookie contains a unique ID to support functions (for example, last viewed pages) to improve user experience.
newsbcsub	Functionality	This cookie is stored once the user has completed or closed the register pop up, preventing it from re-appearing until after 7 days.
TLSCookiesEU	Strictly necessary	This cookie tracks when a user has accepted that the online Services use cookies preventing the popup from being displayed again during that session.
_ga / _gid / _gat	Analytical/performance	These cookies are used by our Google Analytics account to track customer traffic through the website to help us understand how our website is being used by our users.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Personal information from social network accounts

If you connect your account with us to a social network account, such as Facebook, LinkedIn or Google, we will collect your personal information from the social network. We will do this in accordance with the privacy settings you have chosen on that social network.

The personal information that we may receive includes your name, ID, user name, handle, profile picture, gender, age, language, list of friends or followers and any other personal information you choose to share.

We use the personal information we receive from the social network to create a profile for you on the BriteChild platform.

If you agree, we may also use your personal information to give you updates on the social network which might interest you. We will not post to your social network without your permission.

Where we have accessed your personal information through your Facebook account, you have the right to request the deletion of personal information that we have been provided by Facebook. To submit a request for the deletion of personal information we acquired from Facebook, please send us an email at the address at the end of this Privacy Policy and specify in your request which personal information you would like deleted. If we deny your request for the deletion of personal information, we will explain why.

Use of geo-localisation data

We collect your precise or approximate location via our mobile application for the following purposes:

for security and safety;
to prevent and detect fraud; and
as permitted by law.

We collect this information when our mobile application is open (whether on-screen or not). If you do not want us to use your location for the purposes above, you should turn off the location services in your account settings in the mobile application or in your mobile phone settings. If you do not provide location information to us, we may not be able to provide our Services to you.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact us at:

Quirky Kid Pty Ltd (ABN 60 606 832 606)

Email: info@quirkykid.com.au

Last update: 23 August 2023

APPENDIX 1: ADDITIONAL RIGHTS AND INFORMATION FOR INDIVIDUALS LOCATED IN THE EU OR UK

Under the GDPR individuals located in the EU and the UK have extra rights which apply to their personal information. Personal information under the GDPR is often referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual). This Appendix 1 sets out the additional rights we give to individuals located in the EU and UK, as well as information on how we process the personal information of individuals located in the EU and UK. Please read the Privacy Policy above and this Appendix carefully and contact us at the details at the end of the Privacy Policy if you have any questions.

What personal information is relevant?

This Appendix applies to the personal information set out in the Privacy Policy above. This includes any Sensitive Information also listed in the Privacy Policy above which is known as ‘special categories of data’ under the GDPR.

Purposes and legal bases for processing

We collect and process personal information about you only where we have legal bases for doing so under applicable laws. We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground, we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose of use / disclosure	Type of Data	Legal Basis for processing
To enable you and your child to access and use our software, including to provide you with a login.	Identity Data Contact Data Financial Data Transaction Data	Performance of a contract with you
To provide our Services to you, including to assess your application to become a member of the BriteChild platform and manage your consultation bookings.	Identity Data Contact Data Profile Data	Performance of a contract with you
To contact and communicate with you about our Services including in response to any support requests you lodge with us or other enquiries you make with us.	Identity Data Contact Data Profile Data	Performance of a contract with you Legitimate interests: to ensure we provide the best client experience we can offer by answering all of your questions.
To contact and communicate with you about any enquiries you make with us via our website.	Identity Data Contact Data	Legitimate interests: to ensure we provide the best client experience we can offer by answering all of your questions.
For internal record keeping, administrative, invoicing and billing purposes.	Identity Data Contact Data Financial Data Transaction Data	Performance of a contract with you To comply with a legal obligation Legitimate interests: to recover debts due to us and ensure we can notify you about changes to our terms and conditions and any other administrative points.
For analytics, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms.	Profile Data Technical and Usage Data	Legitimate interests: to keep our website updated and relevant, to develop our business, improve our Services and to inform our marketing strategy
For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.	Identity Data Contact Data Technical and Usage Data Profile Data Marketing and Communications Data	Legitimate interests: to develop our Services and grow our business
To run promotions, competitions and/or offer additional benefits to you.	Identity Data Contact Data Profile Data Interaction Data Marketing and Communications Data	Legitimate interests: to facilitate engagement with our business and grow our business
If you have applied for employment with us, to consider your employment application.	Identity Data Contact Data Professional Data	Legitimate interests: to consider your employment application
To comply with our legal obligations or if otherwise required or authorised by law.		To comply with a legal obligation

If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using our services. Further information about your rights is available below.

Data Transfers

The countries to which we send data for the purposes listed above may be less comprehensive that is what is offered in the country in which you initially provided the information. Where we transfer your personal information outside of the country where you are based, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal information in accordance with this Privacy Policy and Appendix 1. This includes:

only transferring your personal information to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal information; or
including standard contractual clauses in our agreements with third parties that are overseas.

Data retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Extra rights for EU and UK individuals

You may request details of the personal information that we hold about you and how we are process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal information rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to you or another organisation.

If you are not happy with how we are processing your personal information, you have the right to make a complaint at any time to the relevant Data Protection Authority based on where you live. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Authority, so please contact us in the first instance using the details set out above in our Privacy Policy above.