This policy explains how and why we collect, use, hold and disclose your personal information.
In this policy, “we”, “us” and “our” refers to Your Brain In Mind Pty Ltd ACN 652 812 005 and any related body corporates. “App” refers to our mobile app referred to as “BrainScan” (or any other name we give to it from time to time), together with any accompanying website produced by us.
You consent to us collecting, holding, using and disclosing your personal information in accordance with this policy.
1. Our commitment to your privacy
We recognise the importance of your privacy and understand your concerns about the security of the personal information provided to us or input into the App. We comply with the Australian Privacy Principles (APPs) as contained in the Privacy Act 1988 (Cth) (Privacy Act). The APPs detail how personal information may be collected, used, disclosed, stored and destroyed, and how an individual may gain access to or make complaints about the personal information held about them.
2. Personal information
When we refer to personal information in this policy we mean any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true.
3. What personal information do we collect and hold?
When you access and use the App, we collect personal information about you (see section 4 below about how we collect your personal information). The kinds of personal information we collect from you or about you depend on the services you have engaged us to provide to you.
The information we collect from you may include your email address. We may also collect sensitive information about you, such as information about your health, including your medical history and any medical conditions you may have, including psychological symptoms, medications you are on and your use of alcohol.
When you use the App we may also collect information about your location or activity including your IP address. Your IP address is logged when you visit our App to analyse the ways users use our App but cannot be used to identify a user personally. This App does not use these “cookies” explicitly (cookies are small text files that are commonly used as anonymous unique identifiers). However, the App may use third party code and libraries that use “cookies” to collect information and improve their services.
4. How do we collect your personal information?
We collect your personal information directly from you when you put the personal information into the App. We will not collect personal information from third parties unless authorised by you or unless the information is available through publicly available sources of information.
You can be anonymous or use a pseudonym when dealing with us, unless:
• the use of your true identity is a legal requirement; or
• it is impracticable for us to deal with you on such basis.
5. Why we collect your personal information
We collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us to carry out our services or to provide you with full use and enjoyment of the App. For example, we collect, hold and use your personal information so that we can:
• provide you with services that (amongst other things) are designed to assess your risks for cognitive dysfunction;
• engage, or enable you to engage, third party service providers to provide services to you and assist with your use the App;
• administer the App;
• comply with our legal obligations;
• improve our services and the App;
• tell you about services that we think may be of interest to you;
• undertake administrative, marketing (including direct marketing), survey, and research purposes; and/or
• update our records and keep your records up to date.
If you do not provide us with your personal information we may not be able to provide you with our services (including access to the App), communicate with you or respond to your enquiries.
6. Who do we disclose your personal information to and why?
We may disclose your personal information where:
• we are required or authorised by law to do so;
• you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
• we are otherwise permitted to disclose the information under the Privacy Act.
If the ownership or control of all or part of our organisation or App changes, we may transfer your personal information to the new owner.
7. Do we disclose your personal information to anyone outside Australia?
All information will be stored in servers operated by Amazon Web Services (AWS). Please visit the AWS site at https://aws.amazon.com/privacy/ to learn more about how they collect and use this information.
We may disclose your personal information to a recipient which is located outside Australia if required in order for us to fulfil any of the purposes identified above.
8. Direct marketing
We will use your personal information to offer services we believe may interest you, but we will not do so if you tell us not to. These products and services may be offered by us, our related companies, our other business partners or our service providers.
Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.
9. Access and correction to the personal information we hold about you
You have a right to access and correct the personal information we hold about you. You have complete control over the personal information we hold about you and can at any time change the personal information by accessing the App.
In the event that you can no longer access the App, you may request to access and/or correct your personal information. When requesting access to or correction of your personal information, please provide us with as much detail as you can about the particular information you wish to access or correct, in order to help us retrieve it.
We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date and complete.
10. Storage and security of your personal information
We take reasonable steps to protect your personal information by storing it in a secure environment. Your personal information is primarily stored by electronic means. We take all reasonable steps to protect all of the personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. Your personal information is otherwise stored in accordance with AWS’s security policies, as described in AWS’s privacy policy (accessible through the link above).
We will also take reasonable steps to de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.
11. Data breaches
If we suspect that a data breach has occurred, we will undertake an assessment into the circumstances of the suspected breach within 30 days after the suspected breach has occurred. Where it is ascertained that a breach has actually occurred and where required by law, we will notify the Privacy Commissioner and affected customers as soon as practicable after becoming aware that a data breach has occurred.
12. Third Party Sites
Our App may contain and we may provide links to third parties’ websites and services. These third party websites and services are not subject to our privacy policy. Please visit the websites of or contact these third parties to view a copy of their privacy policy.
13. Complaints and concerns
We have procedures in place for dealing with complaints and concerns about our practices in relation to the Privacy Act and the APPs. We will respond to your complaint in accordance with the relevant provisions of the APPs. For further information, please contact our Privacy Officer using the details below.
If you are not satisfied with our response to your complaint, or if you would like further information about privacy in Australia, then we suggest you contact the Office of the Australian Information Commissioner at www.oaic.gov.au.
14. Contact Us
If you have any other questions about this policy, you may contact us using the following details:
Privacy Officer
yourbraininminddkr@gmail.com
15. Changes to our Privacy Policy
We may change this policy from time to time or as the need arises. You should review this page periodically for any changes.
This policy was last updated on 25.08.21
