This privacy policy sets out how Heart On My Sleeve Movement Limited ABN 55627697401 (HOMS, we, us and our) manages personal information including on our website at heartonmysleeve.org (Website).

Personal Information is any information or an opinion which identifies you or could reasonably identify you, whether true or not and whether recorded in a material form or not. We use this personal information to provide our products and services, including when providing services to other organisations and workplaces.  It does not include information that is de-identified (anonymous information).

We are committed to meeting the standards for privacy protection in the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) (Schedule 1, Privacy Act). We take the protection of your personal information seriously.

By providing personal information to us, you consent to us handling your personal information in accordance with this privacy policy.  You are not required to provide personal information to us.  However if you do not provide us with all the personal information we request, the services we provide to you may be affected.

What personal information we collect and why we collect it

The types of personal information we collect from you may include your name, address, email address, company, role, gender, age band/range, payment information, how you use our products and services, and your image including when  you are an employee, job application, volunteer, a certified/accredited ambassador in one of our programs, or you have shared your personal information with us. We may also collect sensitive information, such as information related to your health (including mental health), race, disability or sexual orientation.

We collect personal information for the purpose of:

• providing our products and services including merchandise, programs, workshops, elearning, webinars and training. This includes the REAL Mates and the REAL conversations training and accreditation programs, peer support training programs, and associated surveys, research and development;
• the general management, administration and conduct of HOMS;
• improving our products and services and the user experience, including via engagement surveys;
• marketing our products and services and offers;
• receiving donations;
• sending our newsletter;
• processing job applicant and volunteer applications;
• complying with our legal obligations; and
• related purposes that would reasonably be expected by you.

How we collect your personal information

We may collect personal information from you through our Website, when you communicate with us (either by email, telephone, in writing or in person), or when you order our products or services or set up an account with us to use one of our community platforms, forums, programs or services (including via your employer), or when you fill out a contact form on our Website.  We may also collect personal information about you from third parties, including your employer if they provide one of our programs to you in your workplace.

What happens when you leave a comment on our Website

When visitors leave comments on our community platforms or forums, or otherwise on our Website we may also collect the personal information shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.  An anonymised string created from your email address (also called a hash) may be provided to a third party service provider if you are using it. After approval of your comment, your profile picture may be visible to the public in the context of your comment. You should also be aware that any information you post in your comment may be accessed by other users.

What happens when you upload a picture to our Website

If you upload images to our Website (e.g. via an article, blog post or comment), we recommend that you avoid uploading images with embedded location information (EXIF GPS) included. Visitors to our Website may be able to download and extract any location information from images on the Website. You may request that pictures be removed from our Website, otherwise they remain publicly available for as long as your article, blog post or comment is published.

Cookies

If you leave a comment on our Website you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment.

If you have an account and you log in to our Website, we may set a temporary cookie to determine if your browser accepts cookies. This cookie does not contain any personal information and is discarded when you close your browser. When you log in, we may also set up several cookies to save your login information and your screen display choices.

If you edit or publish an article or blog post on our Website, an additional cookie will be saved in your browser. This cookie does not include personal information and simply indicates the post ID of the article you just edited. It expires after one day.

Embedded content from other Website

Our Website may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These other websites may collect information about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

How we use and disclose your personal information

We will not use or disclose your personal information for any purpose other than the purpose for which it was collected (or a related purpose), unless you have consented to that other purpose or we are permitted or required to do so by law.

We may disclose your personal information to third parties:

• who assist us in supplying our products or services, including corporate clients, trainers, facilitators and accreditation program educators;
• who also use HOMS products or services, including when they participate in HOMS programs or interact with the Website;
• for the purpose of research and development to improve our programs or services;
• who perform operational, administrative and other related functions on our behalf (including suppliers and operational, technology and business service providers, which may include Kajabi based in the United States (governed by the privacy policy at kajabi.com/policies/privacy), SurveyMonkey based in the United States (governed by the privacy policy at surveymonkey.com/mp/legal/privacy), Typeform based in Spain (governed by the privacy policy at admin.typeform.com/to/dwk6gt/) and Squarespace based in the United States (governed by the privacy policy at squarespace.com/privacy);
• in the event they are involved in the sale of any of our assets or part of our business; and
• where we are required or authorised to do so by law, or to comply with our legal obligations.

The people to whom we disclose your personal information may be located overseas. The countries in which the recipients are likely to be located include the USA and Spain.  It is not practicable to identify to identify the other countries in which recipients are likely to be located.

If you take part in a workplace program your name, email or user ID may be provided to your employer if you make a virtual pledge. No other personal information will be shared back to your employer or other third parties regarding your usage behavior, comments, or activity.  Aggregate information and trends will be shared anonymously.

Expression of interest and surveys

If you provide an expression of interest, or you take part in one of our program surveys provided  at different points of the program or service we will provide these via third party service providers, including SurveyMonkey and TypeForm, so that we can understand the impact our services are having on people's mental health.  Our surveys will primarily address how confident individuals are to speak about their mental health issues, before, during and after the program or services are utilised.

Contacting you

We may use your contact details to send you information via email about our programs or services, but only when we feel such information is important and relevant to the programs or services and we think it may be of interest to you.  You can opt out of these messages via the unsubscribe function on the email at any time.

How long we retain your personal information for

If we hold personal information about you that is no longer needed for any purpose for which it may be used or disclosed, we will take such steps as are reasonable in the circumstances to destroy or permanently de-identify that personal information.

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

If you register on our Website, we may also store the personal information you provide in your user profile for as long as is reasonably necessary. You can see, edit, or delete your personal information at any time (except you cannot change your username). The administrators of our Website can also see and edit this information.

Access to and correction of personal information

You can request access to and correction of any personal information we hold about you (subject to certain legal exceptions). If a legal exception applies and we are not able to provide you with access to or a correction of the personal information we hold about you, we will advise you of the reasons for our decision.

If you have an account on our website, or have left comments, you can request to receive an exported file of the personal information we hold about you, including any information you have provided to us. You can also request that we erase any personal information we hold about you. Subject to certain exceptions this does not include any personal information we are obliged to keep for administrative, legal, or security purposes.

Where we send your personal information

Visitor comments may also be checked through an automated spam detection service.

How we protect your personal information

We will take reasonable steps to ensure that the personal information we collect and hold is secure.

GDPR

If you are in the European Union (EU) (including the European Economic Area), the collection and processing of your personal information will be subject to the General Data Protection Regulation (2016/679) (GDPR). In providing our services to you, we may collect and process personal information as outlined in our privacy policy. Otherwise, including for individual users of our services, we will be a data controller for the purposes of the GDPR and this Privacy Policy includes information that must be provided to you when we collect your personal information.

Complaints

Please contact us if you have any concerns or complaints about our handling of your personal information. We will deal with all concerns and complaints through HOMS' complaints handling process.  However, if you feel that we have not adequately dealt with your concerns you may refer the matter to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

Changes to our privacy policy

We may from time to time, amend this privacy policy, in whole or in part. Any changes to this will be effective immediately upon the posting of the revised privacy policy on our Website.

Contact us

If you have any questions about our privacy policy or you wish to access or correct the personal information we hold about you or raise any privacy concerns you may have, please contact us at Heart on My Sleeve Limited at privacy@heartonmysleeve.org.

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Last Updated: August 2021