1.1 This policy explains how Mindrazor Pty Ltd ABN 38 605 775 095, trading as MindRazr (we, us or our), handles personal information.
1.2 We hold ourselves to the Privacy Act 1988 (Cth) and the Australian Privacy Principles, and to any additional privacy obligations in our contracts with the organisations we work with.
1.3 If we provide MindRazr to people in the European Union or the United Kingdom, we will also comply with the General Data Protection Regulation (GDPR) and the UK GDPR as they apply to that information, including the rights they give individuals.

(a) We collect only the information we reasonably need to provide the services described in our Terms of Service, and we keep it secure.
(b) Your organisation (your employer or any other organisation that has arranged your access to MindRazr) never sees your individual registration or activity. Reporting to your organisation is anonymous and aggregated only.
(c) Your account and activity information is stored in Australia.
(d) We never sell personal information, and we do not use app users' information for direct marketing.

3.1 We collect only the personal information we reasonably need to operate MindRazr and provide the services described in our Terms of Service. We collect it directly from you when you register and use MindRazr, and some technical information automatically when you sign in. Your organisation gives you an access code.
3.2 Your account. A name (which can be any name, including a nickname), an email address, your organisation's access code and a password, which we store only in secure, unreadable form. Your organisation may also ask some questions, such as your age range or gender. Answering them is optional. They are asked only in broad categories, so that reporting to your organisation cannot identify you or make you reasonably identifiable.
3.3 Optional information you enter. Anything else you enter in the app, such as answers to simple questions about how you are feeling or how you slept, is completely optional. Some of it may include information about your health or wellbeing; by choosing to enter it, you consent to us collecting and using that information as described in this policy. Check-ins are not assessments. Please do not enter medical records or information about another person.
3.4 How you use MindRazr, and technical information. The content and programs you use, and the technical information needed to run the app securely and send you reminders, such as your device type, time zone, sign-in IP address and crash reports. Our website and emails use standard analytics, such as cookies and email tracking.
3.5 Customer contacts. Business contact details for people at organisations that use, or may use, MindRazr.
3.6 Billing and payments. We only collect organisation details needed to invoice the organisations we work with. If we offer card or online payments, they will be processed by a payment provider that complies with the Payment Card Industry Data Security Standard (PCI DSS), and we will not store full card details.
3.7 We do not ask for your date of birth or collect information such as your precise location, biometric information or medical records.
3.8 We use this information only to operate MindRazr and improve your experience, to send you occasional emails about your account and the programs you have signed up for, and reminders you have opted into, to support you, to keep the platform secure, to improve our content, to produce the anonymous reports described below, and to meet our legal obligations. We do not use it for any other purpose without your consent, unless the law requires or permits it.

4.1 Your relationship with us about your own information is directly between you and MindRazr. We never give your organisation anything that identifies your registration or your activity, and your organisation has no access to our systems or to individual user data.
4.2 Your organisation receives only anonymous, aggregated information about how its users use MindRazr.

5.1 We never sell personal information. We only share it with the service providers we use to run and operate MindRazr, or where the law requires it.
5.2 We only work with reputable global cloud software providers for infrastructure hosting and customer relationship management (CRM), and they keep the personal information they hold for us in Australia. Other providers, specifically Apple and Google, which run the app stores our mobile apps are downloaded from and associated app features such as notifications, may process limited information outside Australia, including in the United States.
5.3 If we receive a court order or similar legal demand, we disclose only what the law requires.

6.1 Your account and activity information is stored securely in Australia, and access is restricted to authorised MindRazr personnel.
6.2 We take reasonable steps to protect personal information, using industry-standard safeguards.

7.1 We keep personal information only while it is needed, and then delete it or permanently de-identify it. We delete user information no later than 90 days after your organisation's subscription ends, unless a different period has been agreed in writing with your organisation.
7.2 To have your personal information deleted, email privacy@mindrazr.com and we will delete it within 30 days, unless the law requires us to keep it. Deactivating your account in the app stops it being used but does not delete it.

8.1 If a data breach is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) under the Notifiable Data Breaches scheme, and we will notify your organisation where our contract with it requires.

9.1 You can ask for a copy of the personal information we hold about you, ask us to correct it, or make a privacy complaint, by emailing privacy@mindrazr.com. There is no charge. We will respond within 30 days, and if we cannot agree to a request we will explain why.

10.1 We will publish any change on our website with its effective date.