1. WHO WE ARE
The HCF Healthful mobile software application ("App") is brought to you by The Hospitals Contribution Fund of Australia Ltd (HCF). In this privacy policy, the terms "we", "our", and "us" are used to refer to HCF.
We take your privacy very seriously. We ask that you read this privacy policy ("Policy") carefully as it contains important information about how we collect and use your personal (including health) information and how we meet our legal obligations under the Privacy Act 1988 (Cth) and State and Territory based health record laws (the "Privacy Laws").
This Policy applies to how we process personal information collected from your use of our HCF Healthful App. You can find out more about how HCF otherwise handles personal information from the HCF privacy policy.
2. WHAT PERSONAL INFORMATION DO WE COLLECT THROUGH THE APP AND HOW?
We collect personal information about you when you download and register to use the App on your mobile. This includes your name, email address, date of birth, height, weight, gender, and membership number.
We will also collect personal information when you use the App (for example by completing health assessments, challenges, creating goals entering competitions) which includes:
- information about your physical attributes (such as your height, weight and waist measurement), your physical health mental wellbeing and habits (such as your sleep score, daily step count, exercise level, and blood pressure)
- information about your generated health score in the App
- photos, if you choose to upload these in the App
- information about your use of the App (such as what challenges you are participating in, your goals, the in-app content you engage with, the links you click through, and your other interactions in the App)
- information about interests and preferences in relation to the App and the user segment you fall within
- information you share when you make an enquiry, give us feedback, report a problem or otherwise contact us through the App
- information about your mobile device (such type of device that you are using and its unique device identifier e.g. the IMEI number, the type of mobile browser that you are using, the mobile operating system that you are using, mobile network information, the time zone setting).
We will also collect personal information indirectly from third parties with your consent, or if you have enabled this collection, which includes:
- information about your activity collected from third party fitness wearables or activity trackers you connect to the App (such as Fitbit, Garmin and Apple devices) (their Privacy Policies will also apply to this information)
- information about your location to track your physical activity (such as to track a walk or run in the App)
- information about the location of your friends or family members who also use the App.
3. HOW WE USE YOUR PERSONAL INFORMATION
The main purpose we use your information for is to determine your eligibility, validate your HCF membership, and enable you to register and use the App, inform you about relevant health and wellbeing services and promotions through the App and provide App support. Ultimately, we hope this App will help you to improve your overall health and wellbeing. We will not use the personal information collected through the App to assess your policy entitlements or premiums.
We also use your personal data for the following purposes:
- De-identified and aggregated reporting –to produce de-identified and aggregated reports to allow us to monitor key App usage metrics overall such as total users, inactive users, user demographics.
- Personalised reporting (in limited circumstances) - to produce individualised reporting on certain features of the App such as tracked workouts, challenges you have participated in and your progress towards the goals you set in the App to allow us to provide you with support where required.
- Marketing –unless you tell us not to, to identify and promote HCF health and wellbeing products and programs and third-party products and programs we believe may be of interest to you, based on your eligibility criteria and your use of the App.
- Developing user segments –to define user segments based on your Health Score, geography, gender and age.
- General administration - to allow us to customise the App and its content to your particular preferences and notify you of any changes to the App or to our services that may affect you and to improve App performance.
- Compliance with legal obligations –to comply with our legal obligations and assist government and law enforcement agencies or regulators.
4. OUR DIRECT MARKETING AND OPTING OUT
We may, with your consent, use your personal information to contact you from time to time (by email, phone, push notifications or in App marketing) to tell you about new products or services and special offers that we believe may be of interest to you. They may be offered by us, our related companies or our business partners.
You can withdraw your consent (opt out) to receive direct marketing communications from us at any time by unsubscribing by clicking on the opt-out link in the marketing communication you receive, turning your push notifications off for HCF Healthful in your phone settings, changing your profile settings in the App or letting us know when we call. You can also contract us to opt out using the contact details in our HCF privacy policy.
The App may contain links to websites or other apps which we or our partners own, or websites or apps of our partners or third parties. If you follow any of these links, or you use third party fitness wearables or activity trackers, the websites, apps and services provided through them will have their own privacy policies and terms of use. We do not accept any responsibility or liability for these or their collection and use of any personal information as a result of your use of the App. Please review the relevant privacy policies and terms of use before providing any personal information, or using their websites, apps and services.
5. WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO AND WHY
We may disclose your personal information to:
- our third party service provider, Dacadoo AG, a Swiss based application developer who provides platform support for HCF Healthful which it helped us develop; and
- other companies within our group, but only for the purposes specified in this policy.
- or if we are required or authorised by applicable laws.
Dacadoo’s support staff, who may have access to your personal information are located in Australia, Switzerland, Spain and Canada.
6. STORAGE AND RETENTION OF PERSONAL INFORMATION
We store the information we collect through the App as digital records in servers on a segregated secure Dacadoo cloud database hosted by Microsoft Azure and in a HCF internal database in Australia. We have entered into a data processing agreement with Dacadoo to ensure that it is only able to process the personal information collected through the App in accordance with our instructions.
We take reasonable steps to implement appropriate technical and organisational controls to protect your personal information that we hold from unauthorised use, disclosure and access.
If you ask us to delete your account on the App, or you delete the App from your phone, we will deactivate your account for 30 days, after which all personal information we store for your account will be permanently deleted.
For more information about how we store and retain your personal information, please see our privacy policy.
7. ACCESS AND CORRECTION OF PERSONAL INFORMATION
Please refer to our privacy policy for information about how you can request access to, or correction of, your personal information.
8. COMPLAINTS AND CONTACT DETAILS
If you have a privacy enquiry or concern or you wish to complain about how we have handled your personal information, you can contact our Privacy Officer by emailing privacyofficer@hcf.com.au. Our privacy policy explains more about how we deal with privacy complaints.
9. CHANGES TO THIS POLICY
We may update this policy from time to time to reflect changes to how we handle personal information or to the types of personal information we collect and process or to meet our legal obligations.
Any changes to our policy will be notified to you through the App, and the latest version will be available at all times within the App.
This privacy policy was last updated: November 2024.
