Loop Plus Privacy Policy
This Privacy Policy explains how LOOP PLUS PTY LTD (ABN 73 623 047 601) (‘loop+’ or ‘us’) seeks to protect the personal information of individuals. We are committed to protecting the safety and security of the personal information of individuals whose information loop+ has access to (‘User’ or ‘you’).
The Privacy Policy has been developed in accordance with the Privacy Act 1988 (Cth) (‘Privacy Act’), which contains the Australian Privacy Principles.
Under the Act, ‘Personal Information’ is defined as: “Information or an opinion about an identified individual, or an individual who is reasonably identifiable:
whether the information or opinion is true or not; and
whether the information or opinion is recorded in a material form or not.’
Please read this Privacy Policy carefully in order to understand how your Personal Information is collected, held, used, or otherwise processed by us.
By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.
Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details.
About loop+
loop+ is a service that allows wheelchair users to monitor their in wheelchair activity on the loop+ mobile application (‘App’) using the loop+ sensor pad device (‘Device’). In delivering its services, loop+ provides a variety of offerings, including the App, the loop+ website and the Device (collectively, ‘loop+ Services’).
In providing the loop+ Services, we are sensitive to Users’ concerns about the safety of their Personal Information.
In essence, loop+ will typically only:
collect, use or share your Personal Information with your consent (unless it is not reasonable in the circumstances to obtain your consent and it is legally permissible for us to do so) or when required by a legal obligation; and
interact with your Personal Information in order to: (a) provide you with access to the loop+ Services, (b) help us improve and develop the loop+ Services, and (c) meet our obligations in respect of any agreement we have with you.
loop+ has developed our privacy framework to assist Users, and to comply with privacy legislation and regulations applicable to us and our management of your Personal Information.
How loop+ Collects your Personal Information
loop+ collects Personal Information from Users in one of three main ways:
Directly from Users, when they interact with loop+ or the loop+ Services (e.g. enter User account information and preferences, or provide us with feedback);
Passively from Users, when they interact with and use the loop+ Services; and
From third-parties in certain, specific circumstances.
The types of Personal Information collected in each situation is discussed further below.
Personal Information loop+ collects
Personal Information collected directly
We may collect the following types of Personal Information directly and consensually:
Basic User information, including your name, email address, telephone number and other contact details, age or date of birth;
Specific information related to your health and/or disability (‘Health Information’);
Details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
Any additional information relating to you that you provide to us directly through our website or App or indirectly through your use of our website or App or online presence or through other websites or accounts from which you permit us to collect information;
Information you provide to us through customer surveys; or
Any other personal information that may be required in order to facilitate your dealings with us.
Personal Information collected passively
As you interact with the loop+ Services, we may collect the following types of Personal Information about your usage:
Content that is posted about you by others over our social media accounts, and where applicable directly over the loop+ Services;
Background account information, such as your settings;
Your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from Apps and websites, advertising data, IP address and standard web log information; and
Cookies that may be used for creating a responsive website able to be viewed on a mobile or tablet device (however, cookies do not collect Personal Information).
Personal Information collected from third parties
In certain specific situations, loop+ may collect Personal Information about you from third parties. We may collect this information when you:
register on our website or App;
communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites; or
interact with our sites, services, content and advertising.
Why do we collect, use and disclose Personal Information?
Although loop+ collects Personal Information from Users in a number of circumstances, loop+ will only collect this information in order to provide you with access to the loop+ Services, improve and develop the loop+ Services, and to meet our obligations in respect of any agreement we have with you. Here are the main ways we use Personal Information to achieve these objectives:
To enable you to access and use our product, App and website;
to operate, protect, improve and optimise our product’s business and our Users’ experience, such as to perform analytics, conduct research and for marketing;
to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting. We will only use Personal Information for direct marketing directly related to the loop+ Services. loop+ will not share your details with any third parties not directly related to the loop+ Services;
to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
to enhance services provided by third parties for your benefit;
to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
to consider your employment application.
Together these types of Personal Information are used to provide us with an overview of how the loop+ Services is being used, any shortcomings it may have, and subsequently to highlight what will be the best means of improving the experience for all Users. loop+ will not collect or use your Health Information for direct marketing purposes unless you have given consent.
To whom do we disclose your Personal Information?
We may disclose Personal Information for the purposes described in this Privacy Policy to:
our employees;
third party suppliers and service providers (including providers for the operation of our App, websites and/or our business or in connection with providing our products and services to you) such as technology infrastructure providers;
specific third parties authorised by you to receive information held by us;
in the unlikely event that we or our assets may be acquired or considered for acquisition by a third party, that third party and its advisors; and
other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
We may also disclose deidentified Health Information and data insights for the purposes described in this Privacy Policy to partners, third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you).
Disclosure of Personal Information outside Australia
loop+ may disclose Personal Information outside of Australia to loop+ employees, suppliers and cloud providers, including without limitation The United States of America. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such Personal Information in a way that is consistent with the Australian Privacy Principles.
Treatment and Storage of Information
Our general approach
loop+ will keep your Personal Information confidential and not sell or knowingly divulge User information to any external third parties, unless:
The disclosure is made in accordance with an agreement with you, or to which you otherwise consented;
We believe, in good faith, that we are required to share the Personal Information with a third party in order to comply with legitimate legal obligations;
The disclosure is to a third-party processor of Personal Information that acts on our behalf and/or under our instruction in order to enable us to develop and deliver the loop+ Services (e.g. a cloud service provider);
Other entities acquire ownership or operation of loop+ or the loop+ Services; and/or
We need to protect the safety of Users, and the security of our loop+ Services.
Users can always refuse or revoke this consent, but sometimes this will affect loop+’s ability to provide them with the loop+ Services and other offerings. loop+ will advise Users if this is the case.
De-identification
De-identified information refers to information that cannot reasonably be used to identify a particular individual. Personal Information that has been de-identified is no longer Personal Information.
De-identified information that will never be able to personally identify particular individuals is referred to as anonymised information (e.g. statistics that show 90% of Users were happy with the loop+ Services). Additionally, de-identified information is information that can identify individuals only if it is combined with another, separate piece of information is referred to as pseudonymised information (e.g. ID numbers).
Where possible loop+ will aim to collect, store and use anonymised information as a first preference, and if not, then pseudonymised information.
However, sometimes it will be impractical for User information to be de-identified or treated in this way, and in this case, loop+ will continue to use and hold the information in a personally identifiable state. For example, if loop+ needs to reply to a User enquiry we will have to use the contact information provided.
Security
loop+ is committed to information security. We may hold your Personal Information in either electronic or hard copy form. We will use all reasonable endeavours to collect, hold and use your Personal Information in a secure environment and protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.
To this end we have implemented technical, organisational and physical security measures that are designed to protect Personal Information, and to respond appropriately if it is ever breached. For example:
We have guidelines in place to monitor internal staff access to Personal Information;
Access to the database holding personal data is protected by a user authenticated system; and
we have developed a Data Breach Response Plan which we use to prepare and respond to data breaches
However, we cannot guarantee the security of your Personal Information. Please notify us immediately if you become aware of any breach of security.
Our policies for children
We appreciate the importance of taking additional measures to protect children’s privacy.
loop+ allows parents to set up accounts for their children to use with the Loop+ Services (‘Children’s Account’). Persons under the age of 13 are not permitted to create accounts unless, if they are in Australia, their parent has consented in accordance with applicable law. If we learn that we have collected the personal information of a child under the relevant minimum age without parental consent, we will take steps to delete the information as soon as possible. Parents who believe that their child has submitted personal information to us and would like to have it deleted may contact us at info@loopplus.com.au.
Retention of Information
loop+ retains Personal Information until it is no longer needed to provide or develop the loop+ Services.
However, loop+ will retain:
Personal Information in circumstances where we have legal and regulatory obligations to do so (e.g. for law enforcement purposes, employment law, corporate or tax record keeping, or where the information is relevant to legitimate legal proceedings); and
anonymised information for analytic and service development purposes.
The information we retain will be handled in accordance with this Privacy Policy.
Managing your Personal Information
loop+ uses reasonable endeavours to ensure that the Personal Information we collect and hold is accurate, up to date and complete.
Users have a right to access and request the correction of any of Personal Information we hold about them at any time. Any such requests should be made by directly contacting us at the details set out below. loop+ will grant access to the extent required or authorised by the Act and applicable laws, and will take all reasonable steps to correct the relevant Personal Information where appropriate.
Contact Us
loop+ has appointed a Privacy Officer to be the first point of contact for all privacy related matters and to assist in ensuring our compliance with our privacy obligations. The contact details are:
Attn: Loop+ Privacy Officer
Email: info@loopplus.com.au
125/4 Cornwallis Street, Eveleigh NSW 2015
If you have any queries or wish to make a complaint about a breach of this Privacy Policy or the Privacy Act you can contact or lodge a complaint to our Privacy Officer using the contact details above. You will need to provide sufficient details regarding your complaint, your name, email address and/or telephone number as well as any supporting evidence and/or information.
The Privacy Officer will respond to your query or complaint within a reasonable period of time. loop+ will contact you if we require any additional information from you and will notify you in writing (which includes electronic communication via email) of the relevant determination. If you are not satisfied with the determination you can contact us to discuss your concerns or complain to the Australian Privacy Commissioner via www.oaic.gov.au.
For further information about our Privacy Policy or practices, or to access or correct your Personal Information, please contact us using the details set out below: info@loopplus.com.au.
This Privacy Policy was last updated on 26 April 2021.