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    Village App Privacy Policy

    Village App Privacy Policy

    Last updated: August 2020

    The Village application (App) is owned and operated by [Starship Foundation]. The purpose of this Privacy Policy (Policy) is to outline the information we collect and how we use it.  This Policy applies only to information collected through the App. In this Policy any reference to 'we', 'us' and 'our' is a reference to [Starship Foundation].  Any reference to 'you' or 'your' is a reference to any person who accesses the App. All collection and use of health information through the App will be compliant with the Health Information Privacy Code.

    Conditional Use

    1. Your access to and use of the App is subject to the terms and conditions of this Policy, together with the terms of use that apply to the App (Terms of Use), any other documents referred to in those Term of Use and any applicable laws.  By accessing and using the App, you will be taken to have read and agreed to the terms of this Policy and the Terms of Use without any qualifications or limitations. This Policy may change from time to time.  While we will endeavour to provide you with advance notice of any material changes to the Policy via email or by highlighting the change on the App, you should check this Policy from time to time to review any changes. 

    Children under 16

    1. Our App is not designed for children under the age of 13.  If we discover that a child under the age of 13 has provided us with personal information, we will delete such information from our systems.

    What information do we collect?

    1. In order to provide and operate the App, we may collect, store and process the following information:

      1. Information that you voluntarily submit when you sign up to use the App, or when otherwise requested by us (for example, your name, phone number, email, username and password, [your Village members, another professional support person you engage with]);

      2. Information about your use of the App that is collected using automatic data collection technologies.  Automated data collection technologies (such as cookies and data scraping technologies) are used to collect information about your device and patterns of use in the App, such as:

        1. details about your usage of the App, such as date and time of use of the App, communication data, resources that you access and use on the App;

        2. any patterns of problematic language being used in the App's chat function (data scraping technology is used to identify when a user has a pattern of using language linked with suicidal thoughts (Problematic Language), this allows us to notify the user and their Village members through the App to reach out for professional help); and 

        3. technical information about your device, such as your IP address, operating system, and internet connection; and 

      4. Any other information that you submit to the App including information transmitted to other users of the App.

    3. If you do not to submit personal information to us, we may not be able to provide you with access to use the App.  Sometimes we may ask you to submit personal information about other people, for example, a professional support person you engage with.  If you submit this information, we rely on you to tell those other people that you are giving this information to us, to make them aware of this Policy and to ensure that such other people authorise the collection of the information.

    4. Any information you transmit to other users using the App, including any information shared in the App's chat function, are transmitted at your own risk.  Although we limit access to these functions and pages of the App and use good industry practice when it comes to security safeguards for the App, you should be aware that no security measures are impenetrable.  We also cannot control the actions of other users of the App with whom you choose to share personal information.  Therefore, we cannot and do not guarantee that your personal information will not be viewed by unauthorised persons.`

    Health Information

    1. Some information processed, collected and handled by us, such as information about any patterns of use of Problematic Language, may be 'health information' for the purposes of the Health Information Privacy Code.  We collect this information only to the extent necessary to allow us to identify when you might need professional help in relation to your mental health and to notify you and your Village to reach out for help.  

    How do we collect the information?

    1. The information specified in paragraph 1 above may be collected through various means, including:

      1. directly from you when you sign up to use the App or when you otherwise submit personal information to the App; 

      2. automatically in respect of usage information (including Problematic Language patterns) and IP information as described above, as you use the Application; and

      3. through email, text or other electronic messages between you and us in relation to your usage of the App.

    How do we use the information?

    1. The purpose for which information may be used by us (each a Purpose) include:

      1. in connection with your use of the App, such as creating your profile, transmitting information to other users in your Village, and making the App available to you;

      2. ensuring that content in the App is presented in the most effective manner for you and your device;

      3. providing you and your Village members with notifications when there is a pattern of using Problematic Language;

      4. researching, designing and launching other services or products including events and forums; 

      5. complying with laws and regulations applicable to us; and

      6. any purposes directly related or incidental to the above.

    3. By accessing and using the App, you agree that we can access, aggregate and use non-personally identifiable data that has been collected through the use of the App. This data will in no way identify you or any other individual.  We may use this aggregated non-personally identifiable data to:

      1. assist us to better understand how our users are using the App; and

      2. otherwise improve the App.

    Who do we disclose this information to?

    1. We will keep personal information collected in connection with the App confidential but may provide information to third parties where necessary or appropriate to facilitate the Purpose for which the information was collected pursuant to this Policy, including to notify members of your Village when there is a pattern of using Problematic Language.  Your personal information may also be disclosed to our service providers in connection with the provision of services to us, such as the maintenance of the App.

    2. We will not otherwise disclose your personal information to a third party unless you have provided your consent. However, you should be aware that we may be required to disclose your personal information without your consent in order to comply with any court orders, subpoenas, or other legal process or investigation if such disclosure is required by law.  Where possible and appropriate, we will notify you if we are required by law to disclose your personal information.

    3. We may disclose your personal information to third parties outside New Zealand in accordance with paragraph 14.

    4. We require all third parties to respect security of your personal information and to treat it in accordance with the law.  We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

    Where do we store the information?

    1. We may store your data on servers in New Zealand and Sydney, Australia.  We may also transfer your information to people or entities in accordance with paragraphs 8 and 9, who may be located outside New Zealand. 

    How long do we store your information?

    1. We only retain information or so long as it is necessary for the Purposes or which the information was collected or longer if required by applicable laws.

    2. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the Purposes for which we can process your personal information and whether we can achieve those Purposes through other means, and the applicable legal requirements.

    Links to websites

    1. Our App may contain links to websites of interest.  However, once you have used these links to leave the App, you should note that we do not have any control over that other website.  We cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Policy.  You should exercise caution and look at the Policy applicable to the website in question.

    Security and protection of information

    1. All information you provide to us is stored on secure servers hosted by a top tier hosting provider engaged by us. Where we have given you (or where you have chosen) a password which enables you to use the App, you are responsible for keeping this password confidential and secure. We ask you not to share a password with anyone.

    2. The Village app uses good industry practice when it comes to security safeguards to limit access to all information, functions and pages of the app, however, users should be aware that no security measures are impenetrable. We also cannot control the actions of other users of the App with whom you choose to share personal information. Therefore, we cannot and do not guarantee that your personal information will not be viewed by unauthorized persons.

    Cookies

    1. Similar to other apps, our App utilises a standard technology called 'cookies' to collect information about how the App is used.  A 'cookie' is a small piece of information sent from our App to your device to help us identify you quickly.  The information we collect allows us to monitor App traffic and to personalise content on the App for you.

    2. You do not need to accept cookies and may alter the configuration of your device to refuse cookies.  If you choose to have your device refuse cookies it is possible that some areas of the App will not function as effectively when viewed.

    3. To find out more about cookies, you can visit http://www.allaboutcookies.org/. 

    Your rights

    1. Under the New Zealand Privacy Act 1993, and other relevant law, you have the right:

        1. to check whether we hold personal information about you and to access such data;

        2. to request us to correct as soon as reasonably practicable any personal information relating to you that is inaccurate; and

        3. to ascertain our policies and practices in relation to personal information and the kind of personal information held by us.

    3. In accordance with the Privacy Act 1993, in some circumstances, we have the right to and may charge a reasonable fee for processing any information access request.

    Governing law and jurisdiction 

    1. Nothing in this Policy shall limit the rights of the information subject of personal information under the Privacy Act 1993. This Policy shall be governed by the laws of New Zealand. You agree to submit to the exclusive jurisdiction of the New Zealand courts.

    Contact Us

    1. If you have any comments or questions about the App or this Policy, please contact us here