1. INTRODUCTION

1.1 The LeapForward program (Program) is provided to you by Leapforward.ai Pty Ltd (ACN 633 082 238) (LeapForward), who are jointly referred to in this Privacy Policy as “we”, “us”, “our” and similar grammatical forms. The Program is being provided at the request of your employer (Employer) or insurer (Insurer).

1.2 By registering for an account with us, you are accepting the terms of this Privacy Policy, and you are consenting to our collection, use, disclosure, retention and protection of your personal and other information as described in this Privacy Policy.

1.3 The terms of this Privacy Policy should be read in conjunction with the Terms of Agreement to Use the Program, which can be found here: https://www.leapforward.ai/terms-and-conditions. Capitalised terms defined in the Terms of Agreement that are used in this Privacy Policy have the same meaning as defined in the Terms of Agreement.

1.4 We appreciate that your privacy is important to you, we will continue to protect the personal information you provide us and we will manage your personal information in compliance with the Privacy Act 1988 (Cth) (Privacy Policy) and the Australian Privacy Principles (APPs).

1.5 We will take all reasonable steps to ensure that all information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment.

2. WHAT INFORMATION DO WE COLLECT?

2.1 We collect four (4) categories of information when you use the Program:

(a) anonymous non-personal information about how you use the Program;

(b) “cookie” based information (see below) that makes your use of the Program easier by recording your preferences so that when you return to the Program the cookie re-loads that information into your web browser;

(c) the personal information you voluntarily provide us. For example, personal information such as your name, date of birth, contact details that you provide when you register to use the Program or fill out a form related to any customer service feature operating on the Program; and

(d) the sensitive information and/or health information (such as health or genetic information, biometric information, information about injury and/or illness) (Sensitive Information) that you voluntarily provide through the Program, for example information regarding your personal medical, physical, emotional or mental condition or status that you provide when you input the same into the Program,
(together Information)

3. PERSONAL AND SENSITIVE INFORMATION

3.1 You consent to the collection and use of your Information as specified below.

3.2 By deciding to provide the Information you agree to our methods of collections and use, as well to other terms and provisions of this Privacy Policy.

3.3 Collection

(a) To let us operate the Program and to let you use the Program effectively, including the Content, we collect your personally identifiable information (such as, but not limited to, your name, phone number and email address), profile information, log data (information such as your device, IP address, parts of the Program you use and the amount of time spent, actions you take and other statistics), information related to the Content or your need for the Content, and any information which is exchanged between you and the Program (collectively the Information).

(b) In some cases, some of the Information that you give to us is considered Sensitive Information.

(c) You may decide which Information, if any, you would like to share with us, but some functions of the Program or the Content may not be available to you without providing us the necessary Information. We do not sell or transfer sensitive information to third parties, unless you specifically and explicitly request or approve us to do so.

3.4 Use

(a) Protecting this Information is a top priority for us. We will never sell or rent any Information you input in the Program. Other than in the limited ways detailed in this Privacy Policy (including in order for you to use the Program), we will never use or disclose the Sensitive Information unless you specifically and explicitly requested or approved us to do so.

(b) The Information may be used for the following purposes:

(i) to create your account in respect of the Program and let you log in to your account and use the Program;

(ii) to enable and facilitate the Content;

(iii) to supervise, administer and monitor the Program;

(iv) to measure and improve the quality, the effectiveness and the delivery of the Content;

(v) to manage your account, provide you with customer support, and ensure you are receiving quality service;

(vi) to provide your Insurer with updates concerning your use of the Program and relevant Health Information;

(vii) to contact you or provide you with information, alerts and suggestions that are related to the Program;

(viii) to invoice your Insurer;

(ix) to reach out to you, either ourselves or using the appropriate authorities, if either we have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act; and

(x) to match you with a health services provider.

(c) Any Health Information will not be used by us or the Employer for any purpose other than the Health Purpose or a Permitted Secondary Purpose. For the avoidance of doubt, disclosure to the Employer’s insurer whose policy answers any claim by you, is a Permitted Secondary Purpose.

3.5 What other use could we make of your personal information?

(a) We may communicate with you in relation to the management of your account in relation to the Program which will include providing you with information about the Content.

(b) We may also release your personal information when we believe release is appropriate to comply with the law, enforce our subscription agreements, policies and terms & conditions, or protect ours or others’ rights, property, or safety.

3.6 Disclosure

Except as otherwise specifically provided, no information generated by your use of the Program will be disclosed by us or the Employer, to any third party, in a form whereby you can be personally identified.

4. COOKIES AND ANONYMOUS NON-PERSONAL INFORMATION

4.1 Use of cookies

(a) Like many online applications, we use cookies to collect information. A "cookie" is a small data file that is transferred to your computer's hard disk for record-keeping purposes. We use cookies to enable the technical operation of the Program, to administer your log-in to your account.

(b) The Program may also include the use of cookies of services owned or provided by third parties that are not covered by our Privacy Policy and we do not have access or control over these cookies. We may also use third party cookies for the purposes of web analytics, attribution and error management.

(c) The anonymous non-personal information that when collect and analyse is not personal information as described in the Privacy Act.

4.2 Refusing cookies

(a) You can change your browser's settings so it will stop accepting cookies or to prompt you before accepting a cookie. However, if you do not accept cookies you may not be able to use the Program or some of our services may not function properly.

4.3 Why we use cookies and other tracking technologies

(a)  When you access the Program, a small files containing a unique identification (ID) number may be downloaded by your web browser and stored in the cache of your device. The purpose of sending these files with a unique ID number is so that the Program can recognise your device when you next visit the Program. The cookies that are shared with your device can't be used to discover any personal information such as your name, address or email address, they merely identify your device to the Program when you use it.

(b) We can also log the internet protocol address (IP address) of users of the Program so that we can work out the countries in which the devices are located.

(c) We collect information using cookies and other tracking technologies for the following reasons:

(i) to help us monitor the performance of the Program so that we can improve the operation of the Program and the services we offer;

(ii) to provide personalised services to each user of the Program to make their navigation through the Program easier and more rewarding to the user; and

5. HOW WE PROTECT YOUR INFORMATION

5.1 Safeguards

We use different technologies and procedures to help protect personal information from unauthorized access, loss, alternation, disclosure or use. Some of the safeguards we use are physical access controls, information firewalls and access authorisation controls to where your personal information is held in data centres. We also use data encryption when personal information is transferred to and from our service providers. Our commitment to data security means:

(a) we have procedures to limit access to personal information within our organisation;

(b) we use security measures and technologies within our organisation to protect your personal information; and

(c) we use service providers that can establish that they have secure controls relating to software security, access security and network security, including where credit card information is being transferred.

5.2 Information Security

(a) The Program is hosted in Australia. All data generated by the Program (including all personal information) is kept on AWS servers in Sydney, Australia.

(b) Web traffic information we collect, such as data collected by Google Analytics may be stored overseas.

(c) Your information may be transferred to, and maintained on, computers located outside of your state. Regardless of where your data is stored, it will be maintained securely as outlined in this policy. Your consent to our Terms of Agreement to Use the Program followed by your submission of such information represents your agreement to such transfers.

6. PHISHING

Online identity theft and account hacking, including the practice currently known as "phishing", are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).

7. THIRD PARTY LINKS

The Program may contain links to websites, services or offers which are owned, operated or maintained by third parties. If you click on a third party link, you will be directed to that third website or service. The fact that we link to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third party websites and services and we do not have control over their privacy policies and terms of use. We have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of the Programs and welcome any comment about linked websites.

8. SECURITY MEASURES AND LIMITS

While using any Internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are all designed, built and maintained with your security and privacy in mind. We apply industry standards and best practices to prevent any unauthorized access, use, and disclosure. We comply with or exceed all applicable federal laws, state laws, and regulations regarding data privacy.

9. SERVICE PROVIDERS

We may employ third party companies and individuals to facilitate the Program, to perform certain tasks related to the Program, or to provide audit, legal, operational or other services for us. These tasks include, but not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and where necessary, only after entering into appropriate confidentiality agreements.

10. COMPLIANCE WITH LAWS AND LAW ENFORCEMENT

10.1 We cooperate with government and law enforcement officials to comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous.

10.2 We may be obliged to disclose information to law enforcement or other authorities to conform with professional and legal responsibilities, including where the law requires mental health professionals to disclose information and/or take action in the following cases:

(a) reported or suspected abuse of a child or vulnerable adult;

(b) serious suicidal potential;

(c) threatened harm to another person;

(d) court-ordered presentation of treatment.

11. YOUR RIGHTS

11.1 Access, use and correction of personal information

(a) We take all reasonable steps to ensure that the Information we collect about you is accurate, up to date and complete. Where we collect that Information from you directly, we rely on you to supply accurate information.

(b) You have the right to get access to the personal information we hold about you and to ask us to take reasonable steps to correct any personal information that is inaccurate, out of date, incomplete, irrelevant or misleading. If you would like to exercise any of these rights, please email or write to us using the contact details below.

(c) If you believe that your personal information has been misused, you can inform us of your complaint by writing to our address and we will attempt to resolve the matter.

11.2 Children's Privacy

We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to become our user. The Program is not directed and not intended to be used by children under the age of 13. If you're aware that we have collected Information from a child under age 13 please let us know by contacting us and we will delete that information.

12. CONTACT INFORMATION

12.1 We welcome your comments or questions regarding this Privacy Policy or privacy-related practices. You can contact our Support Officer at:

LeapForward
1300 911 690
admin@leapforward.ai

12.2 If you are not satisfied that we have resolved your query, concern or complaint, you may refer the matter to the Office of the Australian Information Commissioner (OAIC) at:

Telephone: 1300 363 992
Enquiries Form: Online Enquiry Form (https://forms.business.gov.au)
Office Address: Level 3, 175 Pitt Street, Sydney NSW 2000
Postal Address: GPO Box 5288, Sydney NSW 2001
Services: www.oaic.gov.au

 13. TERMS OF USE OF THE PROGRAM

Please also visit our Terms of Agreement to Use the Program (https://www.leapforward.ai/terms-and-conditions) which sets out the conditions of use and limitations of liability governing the use of the Program.

14. CHANGES TO THE PRIVACY POLICY

14.1 We may update this privacy statement at our sole discretion. The date of the last revision of this policy appears at the end of this page. We encourage you to periodically review this page for the latest information on our Privacy Policy and practices. Regardless of changes to our Privacy Policy, we will never use the information you submit under our current Privacy Policy in a new way without first notifying you and giving you the option to opt out.

14.2 This Privacy Policy was last modified on 09 February 2024 by Merton Lawyers of 713 Glenferrie Road, Hawthorn Vic 3122.