Privacy Policy

This privacy policy relates to how MiCBT Institute Pty Ltd ACN 134 536 806 (MiCBT Institute) collects and handles your personal information. In this policy, “we”, “our”, and “us” refer to the MiCBT Institute.  The website, located at app.mindfulness.net.au, and the associated application known as MiCBT App (Application) are owned and operated by MiCBT Institute.

For the purposes of this policy, “personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable.  The Privacy Act 1988 (Cth) (Act) defines certain types of personal information to be “sensitive information“.  Sensitive information includes health information and information or an opinion about an individual’s race, ethnicity or philosophical beliefs.

This Privacy Policy explains how we will treat the personal information that you provide to us in any way. We are committed to maintaining the confidentiality and security of your personal information and managing it in an open and transparent way.

We review our Privacy Policy regularly to ensure it is up-to-date so we encourage you to review it from time to time at https://app.mindfulness.net.au/privacy-policy/.

1.     Using a pseudonym or being anonymous

Wherever it is lawful and practical, you have the option of using a pseudonym or not identifying yourself when dealing with us. However, by doing so you acknowledge that it may affect our ability to provide our goods and services to you. 

2.     Collection of personal information

Types of information collected

In the process of conducting our operations and providing our services, we collect a range of personal information about our current and prospective users, suppliers, agents, service providers, other business associates and the people who run the businesses we deal with. This information can include such things as name, email address, date of birth, gender and information about an individual’s current state of well-being.

Collection of information via our Website and Application

We use analytics tracking in our Application and Website, “Cookies” on our Website and questions voluntarily answered in our Application by users. Cookies are small files that are transferred to your computer’s hard drive through your web browser and enable our site to recognise your browser and remember certain information. We use cookies and tracking software to compile aggregate data about site traffic, site interaction and usage of the Application and Website so that we can offer better experiences and tools in the future. You may be able to configure your computer so that it disables cookies or does not accept them. For example, some third-party vendors, including Google, use cookies to deliver advertisements based on your prior visits to their website. You have the option to opt out of Google’s use of cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html.

Ways we collect your personal information

Where possible we collect your personal information directly from you or through your use of the Application and Website. We may also collect your personal information through correspondence with you (whether by letter, fax, phone, forms or email).

We may also collect personal information about you from third parties in limited circumstances. For example, if you sign up for an Account through a third-party platform such as Facebook or Google, we will collect your personal information from that platform on sign-up. 

3.     Purposes for which we collect, use and disclose personal information

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

a)     providing our services to you; 

b)     improving and continuing to develop our services; 

c)     informing you of services which may be of interest to you; and 

d)     making personalised recommendations to you regarding the use of the Application and Website. 

De-identified information 

We may use de-identified well-being survey data, other survey data and data regarding the use of our Website and Application for purposes including research and analysis, case studies, marketing and improving and continuing to develop our services.  

4.     Disclosing your personal information

We may disclose personal information to our service providers who assist us in providing our services (including hosting and data storage providers such as DigitalOcean).  We may also disclose personal information to other entities where required or authorised to do so by law.  

5.     Direct marketing

With your consent (where required), we may use your personal information (including your sensitive information) to provide you with information regarding our services and identify and provide you with customised recommendations regarding the use of our Application or Website (either by email, SMS or through the Application or Website).

We will always provide a simple means for you to “opt out” from receiving direct marketing, which typically involves an “opt-out” or “unsubscribe” link on emails, a check box on the collection notice or through a pop-up on your screen when you provide personal information on our Website or via the Application.

We will not use or disclose your personal information for the purposes of direct marketing material if you have previously told us not to.

If at any time in the future you do not want us (or one of our service providers) to send you direct marketing material or you wish to cancel a previous consent, please inform us by contacting us at admin@mindfulness.net.au. We will affect the change in a reasonable time and without charge.

6.     Cross-border disclosure of personal information

We will always endeavour to store your information on an Australian server. However, in circumstances where this is not practical, we may disclose your personal information to an overseas entity.  We may also disclose your personal information to our service providers who are based overseas.  We may disclose your personal information to entities which are located overseas, including the United States of America. 

7.     Security and storage of personal information

We will store your personal information in hard copy and/or electronically. We will take such steps as are reasonable in the circumstances to protect your personal information:

a)     from misuse, interference and loss, and

b)     from unauthorised access, modification or disclosure.

When we no longer need your personal information for a permitted purpose and we are not required to keep it to comply with any laws, we will take such steps as are reasonable in the circumstances to destroy your personal information or to ensure that the information is de-identified.

You may delete your account at any time by emailing support@mindfulness.net.au, which will delete the information in the app.  However, we will continue to hold a secure copy of your information for a minimum of seven years after the closure of your account in order to comply with applicable laws.

8. Access to and correction of personal information

We will take such steps as are reasonable in the circumstances to ensure that the personal information we collect, use or disclose is accurate, up-to-date, complete and relevant.

You may request access to or correction of the personal information we hold about you at any time by making a request in writing to admin@mindfulness.net.au.  Subject to any applicable exemptions, we will provide you with access to your personal information or correct your personal information (as applicable) within a reasonable amount of time.  If we decide to refuse your request, we will provide you with a written notice that sets out:

a)     the reasons for the refusal; and

b)     the mechanisms available to complain about the refusal.

9. Making a Complaint

If you have a concern or complaint relating to our handling of your personal information or any breaches of the APPs, please notify us at admin@mindfulness.net.au by outlining the nature of the complaint. We will endeavour to respond to your complaint within 30 days of receipt. 

If we are unable to satisfactorily resolve your concerns about our handling of your personal information, you can contact the Office of the Australian Information Commissioner:

GPO Box 5218, Sydney NSW 2001

Email: enquiries@oaic.gov.au

Tel: 1300 363 992

This policy was last updated in January 2024.