Privacy Policy

Introduction

In this Privacy Policy, ‘us’ ‘we’ or ‘our’ means Hautla Pty Ltd, ABN 29618515923 and trading as Wanngi (Wanngi). We are committed to respecting your privacy. Our Privacy Policy sets outs out how we collect, use, store and disclose your personal information. We are bound by the Australian Privacy Principles contained in the Privacy Act.

By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. You must be a registered member to access the services of Wanngi.

Wanngi (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal information is subject to the updated Privacy Policy.

Services

Wanngi is providing an online platform providing a health ecosystem for people to connect to their health and wellness Services. People use our Services to make their health experience their own by making meaningful connections between Wanngi applications that may already be familiar through APIs, eg Fitbit and Wanngi, and for Australians we are connecting to the My Health Record Service.

Connecting to the My Health Record Service

Wanngi is a Registered Portal Operator for the purposes of the My Health Records Act 2012. Wanngi will comply with all relevant legislation governing health records.  The My Health Records Act 2012 (My Health Records Act), My Health Records Rule 2016 and My Health Records Regulation 2012 create the legislative framework for the Australian Government’s My Health Record system.

The Wanngi app provides a service to connect to your My Health Record.  Wanngi is a View Only Portal which means an electronic interface that facilitates access to the My Health Record system and does not copy, record or store that data. Wanngi will allow you to view your My Health Record and take information to display to you in a variety of ways. This will let you see your information such as medications, allergies, Medicare benefit items, personal information and clinical documents through Wanngi in an informative and useful way, giving you full use of the application.

“View-only portal” apps provide a view only window into the user’s My Health Record data, but don’t allow for storing and manipulating separate saved copies of My Health Record data, nor do they allow users to modify or add to the data held in their My Health Record.

Wanngi provides a “view only Portal” of your health information directly from your My Health Record to your device. For more information about how the My Health Record system manages your data see the privacy and security policy at myhealthrecord.gov.au  and the Office of the Australian Information Commissioner.

Your personal information from your My Health Record is only accessed on your device while in use. As soon as you log out or the app is closed all information is cleared and Wanngi will reauthenticate to access your My Health Record when you next log in.

Data Controllers and Contracting Parties

Hautla Pty Ltd, ABN 29618515923 and trading as Wanngi will be the controller of your personal information provided to, or collected by or for, or processed in connection with, our Services.

As a Member, the collection, use and sharing of your personal information is subject to this Privacy Policy (which includes our Cookie Policy and other documents referenced in this Privacy Policy) and updates.

Information Wanngi Collects

Wanngi collects information about you, including information that directly or indirectly identifies you, if you choose to share it with Wanngi. We receive information in a few different ways, including when you track, complete or upload activities using the Services. Wanngi also collects information about how you use the Services. There are also several opportunities for you to share information about yourself and your activities with Wanngi. For example:

When you register and activate your account, we need you to consent to collect this information otherwise you will be unable to use the app.  You will provide us with personal information such as your name and email address. You must ensure that this information is accurate and current. We may also collect the following types of personal information:

  • name;
  • mailing or street address;
  • email address;
  • username and password;
  • telephone number and other contact details;
  • gender; age or date of birth;
  • photograph
  • personal characteristics, such as weight and height.

We collect information about your use of the Services and your fitness activities through our Apps and through the wearable devices or online services that you associate with our App and connect to your account e.g., Facebook, Twitter, Fitbit, Wanngi and Garmin.  Such information may include, for example:

  • Type, duration, and frequency of fitness activities (including certain background activities if you permit us to do so by turning on “Pocket Track” or similar features)
  • Distance, speed, pace, and step count
  • Heart rate
  • Calories burned
  • Steps taken
  • Nutritional information
  • Sleep activities
  • Training goals
  • Achievements
  • Health-related information that you provide to us
  • your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
  • details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
  • any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
  • information you provide to us through customer surveys; and
  • any other personal information that may be required in order to facilitate your dealings with us.

Cookies

We may collect personal information about you when you use and access our website.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser, but our websites may not work as intended for you if you do so.

We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in accordance with our Privacy Policy.

Log Files

The Services use log files. Stored information includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyze trends, administer, protect and secure the Services, track member movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc., may be linked to session IDs, athlete IDs and device identifiers.

Links

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy.  Wanngi does not endorse and is not responsible or liable for any content, advertising, products or other materials on or available from such sites or resources. You acknowledge and agree that Wanngi is not responsible for the availability of such external sites or resources.

How Wanngi uses Information

We may collect, hold, use and disclose your personal information for the following purposes:

  • to enable you to access and use our website, services or app;
  • to operate, protect, improve and optimise our website, services or app, 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 comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and

We also use your information to analyse, develop and improve the Services. To do this, Wanngi may use third party analytics providers to gain insights into how our Services are used and to help us improve the Services. We may also use your information to market the Services, credit or accept payments, provide support related to the Services, protect members and enforce our Terms of Service, promote safety, and communicate with you. Additionally, your information may be shared with third parties, as set forth below.

We use your information to communicate with you about the Services, send you marketing communications (where you have agreed to receive such messages), or let you know about new features or updates to our Terms of Service.  We also use your information to respond to you when you contact us. Wanngi will use your information to communicate with you, for example by sending you notifications.

How Information is shared

Service providers

We may share your information with third parties who provide services to Wanngi such as supporting and improving the Services, promoting the Services, processing payments, or fulfilling orders. These service providers will only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf so that we or they may promote Wanngi or display information that may be relevant to your interests on the Services or other websites or services.

Third Party Business via API or Other Integrations

When you choose to use third party apps, plug-ins, or websites that integrate with the Services, they may receive your information and content, including your personal information, photos, and your activity data (including private activities). Information collected by these third parties is subject to their terms and policies. Wanngi is not responsible for the terms or policies of third parties.

Legal Requirements, Affiliates and Acquirors of our Business or Assets

We may disclose personal information for the purposes described in this privacy policy to:

  • anyone to whom our assets or businesses (or any part of them) are transferred;
  • specific third parties authorised by you to receive information held by us; and/or
  • other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

How we protect information

We take several measures to safeguard the collection, transmission and storage of the data we collect. Although we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we do not guarantee or warrant the security of the information you share with us and we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content. No system is 100% secure. The Services uses industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information.

The Services are registered with site identification authorities so that your browser can confirm Wanngi’s identity before any personally identifiable information is sent. In addition, Wanngi’s secure servers protect this information using advanced firewall technology.

Our network and infrastructure are designed with security in mind and is hosted in Australian based data centres.

All data containing any personally identifiable or health information accessed or stored by Wanngi is always encrypted at rest and in transit.

Our security implementation includes strong cryptographic standards (such as encryption AES-256 encryption algorithm)

Our hosting service is certified has been certified for Unclassified DLM (UD) workloads by the Australian Signals Directorate (ASD) and is compliant to The Information Security Registered Assessors Program (IRAP) which enables Australian government customers to validate that appropriate controls are in place and determine the appropriate responsibility model for addressing the needs of the Australian Signals Directorate (ASD) Information Security Manual (ISM).

We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, we only allow access on a needs basis and we do not make copies of this information other than for the purposes of providing our products and services. However, no Internet or e-mail transmission is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us via e-mail or the Internet. However, we cannot guarantee the security of your personal information.

Managing your Settings

Accessing or correcting your personal information

You can access the personal information we hold about you by reviewing your account on Wanngi.com or by contacting us using the email addresses provided. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.

If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.

Updating Account Information

You may correct, amend or update profile or account information that is inaccurate at any time by adjusting that information in your account settings. If you need further assistance, please contact Wanngi at https://support.Wanngi.com. Wanngi will generally respond to your request within 7-10 business days.

Deleting Information and Accounts

You may request that your account is deleted by visiting your account settings or contacting Wanngi at https://support.Wanngi.com.  Once deleted, your data, including your account, cannot be reinstated.

Making a complaint

If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.

Contact Us

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:

 

Privacy Officer Wanngi

155 Queen Street, Brisbane Qld 4000 Australia

Privacyofficer@54.252.219.181

Effective: 16 May 2018