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.

 

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.

 

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 Karlo Colak, reachable through karlo@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

 

Clinical Research and Clinical Trials:

OnTracka upholds the highest standards of privacy and data protection for clinical research and clinical trials. Personal information is not included in any research data collected. Data is collected according to study protocols approved by Institutional Review Boards (IRB) or Ethics Committees in Australia, ensuring compliance with the highest ethical standards. This data collection is strictly regulated and only involves de-identified information to protect participant privacy.

 

Information You Give Us for General Use in the App:

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 free public access to OnTracka for your self-monitoring, 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.

 

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.

 

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 authorizes OnTracka to provide the affiliated company with the Users Personal Information and User-generated content to assist level of support provided to Users.

 

OnTracka is not responsible for any use of the user's information made by an affiliate, or the affiliate's 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 affiliate's privacy policy before proceeding to use the affiliated application.

 

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 using cookies. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you, and use it for our lawful business purposes.

 

Information Shared with Our Service Providers

 

We may engage third-party service providers to work with us to administer and provide the Services, for example we use Google Analytics and other third-party analytics providers to help us understand the use of our Services. These third-party service providers have access to your personal data only for the purpose of performing services on our behalf and are expressly obligated to secure your personal data and not to disclose or use your personal data for any other purpose.

 

Information Disclosed in Connection with Business Transactions

 

Information that we collect from our users, including personal data, is considered to be a business asset. Thus, in the event that we or our assets are acquired or we go out of business, enter bankruptcy, or go through some other change of control, your personal data may be one of the assets transferred to or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer of us or our assets may continue to use your personal data as set forth in this Privacy Policy.

 

HOW WE PROTECT YOUR INFORMATION

 

We store and process your information on our servers located globally, including in Australia, the USA, and Europe. We maintain industry-standard backup and archival systems to ensure the safety and availability of your data. By utilizing servers in multiple regions, we aim to provide a reliable and efficient service to users worldwide.

 

We maintain industry-standard technical, physical, and administrative security measures designed to provide reasonable protection for your data against loss, misuse, unauthorized access, disclosure, and alteration. These security measures include firewalls, data encryption, physical access controls to our data centers, and information access authorization controls. However, the Internet is not a 100% secure environment, and we cannot guarantee the security of the transmission or storage of your information.

 

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

 

Access and Update Your Information:

 

You may update your profile information by accessing the “Settings” feature of the app. If you have questions about your personal data we have on file, please contact us at karlo@ontracka.com.

 

Unsubscribe:

 

If you no longer wish to receive our newsletters, emails or other communications, you may unsubscribe at any time by using the unsubscribe feature in the email or contacting us at karlo@ontracka.com.

 

Your Privacy Rights:

 

You have the following rights regarding the personal data we process about you:

 

Access and Data Portability: You can request access to your personal data. You can also request that we provide certain information in a commonly used electronic format.

Rectify, Restrict, Limit, Delete: You can also rectify, restrict, limit, or delete much of your personal data.

Right to Object: Where we process your data based on our legitimate interests explained above or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your data unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.

To exercise any of these rights, please contact us at karlo@ontracka.com. Please be aware that in some cases we will be unable to comply with your request for specific legal reasons which will be notified to you, if applicable, at the time of your request.