Privacy Policy

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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.

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The information we collect

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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.

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We may collect the following personal information from:

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1. 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
2. your child, if you are a parent or caregiver who has signed up your child to use our Services:
   a) Identity Data including your child’s first name, last name, date of birth and gender.
   
   b) 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.  
   
   c) 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.
   
   d) 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:
   
   e) 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.

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How we collect personal information

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

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• 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.

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Why we collect, hold, use and disclose personal information

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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.

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Purpose of use / disclosure

• To enable you and your child to access and use our software, including to provide you with a login. Such as: 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. Such as the following Type of Personal Information: 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. Such as the following Type of Personal Information: Identity Data, Contact Data, Profile Data.

• To contact and communicate with you about any enquiries you make with us via our website. Such as the following Type of Personal Information: Identity Data, Contact Data.

• For internal record keeping, administrative, invoicing and billing purposes. Such as the following date: Identity Data, Contact Data, Financial Data, Transaction Data

• For analytics including profiling on our website, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms. Such as 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. Such as 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. Such as Identity Data, Contact Data, Technical and Usage Data, Profile Data, Marketing and Communications Data.

• If you have applied for employment with us; to consider your employment application.
• To comply with our legal obligations or if otherwise required or authorised by law.
• 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.  

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Our disclosures of personal information to third parties
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We may disclose personal information to:

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• 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 Nylas;
• 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.

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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.

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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.

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Overseas disclosure

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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.

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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.

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Your rights and controlling your personal information

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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.

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

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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.

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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.

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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.

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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.

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Storage and security

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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:

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• 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.

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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.

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Cookies

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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 dorecognise 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.

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.

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Links to other websites

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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.

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Personal information from social network accounts

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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.

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

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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.

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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.

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Use of geo-localisation data

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

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

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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.

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Amendments

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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
Version 1: Last update on 22 November 2022

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