OnTracka takes issues of privacy and the protection not only of personal health information, but all kinds of information about your private life very seriously.

 

As discussed below, we take great efforts to protect your information from disclosure while also using it to improve our capacity to provide services to you & others in a similar situation. If you don’t want OnTracka to collect and use this anonymized information, please consider how appropriate this platform is for you because our efforts to play a pivotal role in changing the future of approaches used in healthcare and mental health is through analysis and research of the anonymized and aggregated information that is collected through the technology.

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WE DO NOT SELL OR RENT YOUR PERSONAL DATA TO THIRD PARTIES AND WE DON’T SHARE, SELL OR RENT YOUR INFORMATION TO SOCIAL NETWORKS.

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We only disclose your information to you or as you authorize us to (although we may include certain elements of that information in our database on an anonymized basis). However, we wish to remind you that the kind of information OnTracka collects is significantly more sensitive than the information you may be providing to other application providers – and you should be extra careful before instructing us to share that information with anyone else. 

Please read this Privacy Policy carefully, it is a material part of the contractual agreement between you and Ontracka Australia Pty Ltd (“we”, “us”, or “our”). This Privacy Policy describes the ways we collect, protect, use and store your personal data. Please read this Privacy Policy carefully, and if you have any questions, feel free to contact us.

PARTICULARLY IMPORTANT INFORMATION

Who We are:

For the purpose of applicable data protection legislation, the data controller of your personal data is Ontracka Australia Pty Ltd. Our Representative is David Murray, reachable through david@ontracka.com. 
 
PURPOSES OF PROCESSING

We collect information about you in a range of forms, including personal data. As used in this Privacy Policy, “personal data” is as defined in the General Data Protection Regulation 2018 and any successor legislation, which includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name & email address, and in the case of OnTracka, includes “Sensitive Personal Data.”

We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the OnTracka app and any other of our products or services. If you created a profile/registered with us through a mobile device or through any other means, you have been asked to tick a box to agree to the use and disclosure of your personal data as outlined below. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to this Privacy Policy and our Terms of Use Agreement, do not use any our App or any of the Services.
 
 
WHAT WE COLLECT

Information You Give Us:
OnTracka gives you a number of options regarding what information you will give us:

 

When you register with OnTracka or any of our affiliated apps (see more about our affiliated apps below), you are provided with the option to use an email that you have access to. This option is created to give you the option of remaining anonymous when using OnTracka.
 

 

Also, during registration with OnTracka, you will submit a variety of personal data (such as gender, age, email, country and state) and as you use OnTracka you may submit a variety of information (such as goals, mental health scores, dosing information, medications, weight, hobbies, interests, state, etc.) which may also include sensitive personal data about personal health issues and/or information related to your past, present, or a future physical or mental health condition (“Sensitive Personal Data”). You may also choose to provide us with access to certain personal data stored by third parties health sites, such as Apple HealthKit and Google Fit. The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. You may (and may be required to) share information about or give us access to additional third-party websites or services.

User Generated Content

If you send or disclose any Sensitive Personal Data to us when you submit user generated content, you consent to our processing and use of such Sensitive Personal Data in accordance with this Policy. If you do not consent to our processing and use of such Sensitive Personal Data, you must not submit such user generated content to our application.”Finally, we may use information that you include in emails or other communication methods to us to assist us in providing the Service, and we may publish that information on an anonymous basis. 

Information We Automatically Collect:

If you visit our website, be advised that Company will maintain web logs to record data about all visitors and customers who use this website and interact with the services and we will store this information. All web logs are stored securely and are accessible to a very limited number of employees who are required to adhere to strict guidelines regarding user data security and privacy.

Finally, in order to provide the best possible service and to allow us to make certain internal reports and make recommendations, we collect aggregated information about the use of the Service, including information about users accessing this website or using the OnTracka app, such as Internet protocol addresses, browser type, browser language, referring / exit pages and URLs, other browser history, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, and the date and time (“Activity Information”).

When you access the OnTracka app, we may also store information based on your usage history. This includes, but is not limited to, details of your transactions, content you viewed, click stream information. We use various technologies to collect and store information which may include sending one or more cookies or anonymous identifiers to your device. Please refer to the section on cookies below.
 
Information We Collect From Other Sources:
 
Information from Health Sites. Our Services include interfaces that allow you to connect with health sites, such as Google Fit or Apple Fit. We may add this to information we get from our Services. Please refer to the section “Information Shared with Other Systems, Such As Healthkit or Google Fit” below for more information.
 
HOW WE USE/SHARE YOUR INFORMATION
We may use personal data to verify your identity, verify your address, or manage risk. We may also use personal data to perform and improve our Services, contact you, conduct research, and provide anonymous reporting for medical research. For example, we may use information to provide customer service and support, prevent illegal activities, customize the Services and recommendations, reduce risk to all parties involved in our transactions, and verify the accuracy of information.

WE DO NOT SELL OR RENT YOUR PERSONAL DATA TO THIRD PARTIES. WE DON’T SHARE, SELL OR RENT YOUR INFORMATION TO SOCIAL NETWORKS

 

However, in a de-identified and aggregate format, we may share your usage of the OnTracka App with third parties to improve the quality of services, your safety and for research. We may share your personal information as necessary for OnTracka to provide you Services, and possibly to tell you about products and services of interest to you (subject, in the case of EU residents, to your consent to receipt of such communications). 

 

We share your personal data with a limited group of employees, as well as certain vendors, partners and third parties as required to offer the Services. This includes, but is not limited to, maintaining your account, sending you information, being able to contact you in emergencies, responding to court orders and legal investigations, for litigation purposes, complying with audits or other investigations, and reporting to credit bureaus. We do not profit from your personal information and do not share your information with advertisers.

We may combine your personal data with information we collect from other companies and use it to improve and personalize the Services, content, and communications with you. We may also do so in order to improve our prediction methodologies and algorithms.

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Affiliated applications

Affiliated applications are not Users of OnTracka, but are hospitals, medical clinics & cannabis companies that work with OnTracka to use the capacities, user-generated and personal information to provide assistance to their patients and or customers. 

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Any affiliated applications will clearly be marked using the own logo and branding of the affiliated company. By connecting with an affiliated application, the User authorises OnTracka to provide the affiliated company with the Users Personal Information and User generated content to assist level of support provided to Users . 

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OnTracka is not responsible for any use of the users information made by an affiliate, or the affiliates compliance with privacy laws. The affiliates may have its own privacy policy which applies to the use of Personal Information received.  OnTracka recommends each User inspect the affiliates privacy policy before proceeding to use the affiliated applicaiton. 

Anonymous Data
We may combine your personal data with information we collect from other users in an aggregate and anonymous format and share this anonymous data with third parties.

 

When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party. We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us. We make personal data into anonymous data by excluding information (such as your name, username and email) that makes the data personally identifiable to you. We do this in order to improve the quality of the information we provide to you and to other users.

Marketing

We may use personal data to deliver products, or service update notices, and promotional offers. With your consent (either in response to an email request or in certain cases, pursuant to the preferences you’ve expressed in your profile), we may send you marketing e-mails about upcoming promotions, and other news, including information about products and services that may be of interest to you.

 

You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you.

 

We may combine your information (after it has been anonymized) with information we collect from other companies and use it to improve and personalize the Services, content and advertising. We may also do so in order to improve our prediction methodologies and algorithms.
 
Corporate Restructuring

In the event that all or a part of our business or assets are sold or transferred or we merge with another company your personal data may be transferred to the buyer/surviving party, but this privacy policy will continue to control that person’s use of your personal information.

Other Disclosures

We will share your information with any party when required by law or by a government request to do so or to combat fraud or criminal activity.

You understand and agree that we may access, preserve, and disclose any information we may have about you (including personal data and protected health information) and the contents of your account if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to avoid liability, to comply with legal process (for example, we may disclose your information as necessary to comply with an authorized civil, criminal or regulatory investigation), such as a search warrant, subpoena, statute, or court order, or to protect our rights and property, or that of our affiliates or the public.

 

OnTracka is not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that it receives. We reserve the right to release personal data or other information about users who we believe are engaged in illegal activities or are otherwise in violation of our Terms of Use Agreement or this Privacy Policy even without a subpoena, warrant or court order, if we believe, in our sole discretion, that such disclosure is necessary or appropriate to operate the OnTracka App, our Website or to protect our rights or property, or that of our affiliates, or our officers, directors, employees, agents, third-party content providers, suppliers, sponsors, or licensors. We also reserve the right to report to law enforcement agencies any activities we reasonably believe in our sole discretion to be unlawful. If we are legally compelled to disclose information about you to a third party, we will attempt to notify you by sending an email to the email address in our records unless doing so would violate the law or unless you have not provided your email address to us.

We also use anonymous data and certain technical information about your computer and/or smartphone and your access of the Services (including your Internet protocol address) in order to operate, maintain and manage the Services. OnTracka may disclose that kind of information to its partners in order to provide the Services, resolve service problems and correct errors in the Services, to communicate with you about the Services, and to enhance your experience on the Services. However, we do not give our partners an independent right to share this information. Due to our contractual obligations with these third parties and the need to share information to deliver and support the Services, however, we cannot provide you with the opportunity to opt-out of sharing such information (whether personal data or other information) with these third parties. OnTracka, certain of its partners, and each of their contractors and employees may view the content that you upload to the Services in order to provide the Services and otherwise perform the tasks set forth in this Privacy Policy.
 
You can terminate your account at any time, which will remove your profile and other personal data from view. OnTracka, however, may (but is not obligated to) keep information about you that is on its system following your termination. You may request complete deletion of your personal data by writing to David@ontracka.com. Subject to the provisions of your Services Agreement, if any, we will delete your data within 45 days of our receipt of that request.

 

Contact OnTracka to terminate your account or for any other questions about your personal data and/or forum posts. Unless you request the deletion of your personal information and subject to applicable law, OnTracka maintain copies of your content indefinitely, even after you terminate your account.

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INTERNATIONAL DATA TRANSFER

Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us outside the country in which you reside, including, but not limited to the Australia and United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using OnTracka you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

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SECURITY

We use reasonable organizational, technical and administrative measures to protect personal data within our organization. If you have any questions regarding which measures and techniques we use, feel free to contact us. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the Internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised, please immediately notify us of the problem by contacting us at david@ontracka.com.

In addition, we urge you to take precautionary measures in maintaining the integrity of your data. Please be responsible in making sure no one can see or has access to your personal accounts and log-in username and password information. If you use a public computer, such as one at a library or a university, or a shared device, always remember to log out of OnTracka. 

OnTracka is not responsible for your handling, sharing, re-sharing and/or distribution of your personal health information. Moreover, if you forward personal health information electronically to another person on or off any OnTracka App, we are not responsible for any harm or other consequences from third party use or re-sharing of your information.

RETENTION

We will only retain your personal data as long reasonably required for you to use the OnTracka app and/or to provide you with the Services unless a longer retention period is required or permitted by law (for example for regulatory purposes). You may request that we delete data you have provided by sending an email to david@ontracka.com. 

CHILDREN

We do not knowingly allow individual Users who are identified and under the age of 13 to create accounts that allow access to our secure site or that use OnTracka without them obtaining the prior consent of a parent or guardian.

YOUR RIGHTS

Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of Sensitive Personal Data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data from a server or business located in the European Economic Area to a server or business outside the European Economic Area.
 

Access. You may access the information we hold about you at any time via your profile/account or by contacting us directly.
 

Amend. You can also contact us to update or correct any inaccuracies in your personal data.

Move. Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.

Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

If you wish to exercise any of these rights, please contact us using the details set forth in the section titled “Additional Questions” below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

COMPLAINTS

We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your personal data, please contact us at: david@ontracka.com. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.

ADDITIONAL QUESTIONS

Again, feel free to contact us by sending an email to, any time, if you have further questions about OnTracka or this Privacy Policy.

HOW YOU CAN CONTACT US

If you have questions or concerns regarding this policy, you should contact us at david@ontracka.com