Privacy Policy

 

The HeadUp Privacy Policy was last updated on December 4, 2018.

Your privacy is important to HeadUp, so we’ve developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your Personal Information. In addition to this Privacy Policy, we provide additional data and privacy information embedded in our Mobile Application for certain features that ask to use or collect your Personal Information.

Collection and Use of Personal Information

You may be asked to provide your Personal Information anytime you are in contact with HeadUp. HeadUp may use your Personal Information in accordance with this Privacy Policy. HeadUp may also combine it with other information to provide and improve our product and content. You are not required to provide the Personal Information that we have requested, but, if you choose not to do so, in many cases we will not be able to provide you with some elements of - or all of - our products and content or respond to any queries you may have.

We will only use and share your Personal Information when directed or requested by you, as necessary for us to operate our business and provide services to you, to comply with legal, regulatory or administrative requirements of governmental authorities, or as otherwise permitted or required by applicable law. We do not sell, disclose, or share your Personal Information with any Third Parties except as indicated in this Privacy Policy, or with your consent, or as required by law.


Sensitive Information

This refers to credit or debit card numbers, personal financial account information, governmental identification numbers, passport numbers, driver's licence numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.

Personal information we collect


When You Visit our Website

You are free to explore our Website without providing any personal information about yourself. When you visit our Website, we collect Navigational Information and when you register for our Mobile Application, we request that you provide Personal Information about yourself to create a Head Up Member Account and to populate your account. 

When You Use our Mobile Application

We use mobile analytics software to allow us to better understand the functionality of our Mobile Application on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. In addition to information we collect on our Website, when you use our Mobile Application we may also collect your city location, device model and version, device identifier (or “UDID”), OS version, and your HeadUp credentials and Member Account.

We send push notifications from time to time in order to update you about events or promotions. If you no longer wish to receive such communications, you may turn them off at the device level.

We may link information we store within the analytics software to Personal Information you submit within the Mobile Application. We do this to improve the product and content offering we provide and to improve our marketing, analytics and Mobile Application functionality.

Personal Information collected about you

In order for HeadUp to provide you with our services, We collect both anonymous and Personal Information about you. Personal Information constitutes data that can be used to identify or contact a single person. You are under no obligation to provide any Personal Information to HeadUp at any time.

Your HeadUp Member Account

The information added to your Member Account, either by your providing the information or when a Linked Service adds the information with your permission, is stored and managed on our Service Providers' servers. This information is then used to provide you with analysis of your data and  personalised insights and recommendations to facilitate greater understanding of your health. HeadUp provides the Member Account to our members for their own personal information needs, and we use it to meet HeadUp’s related needs. 

For the purposes of your use of the HeadUp Website or your Member Account, Personal Information includes, without being limited to, the following:

  • Your contact information, including your first name and last name, phone number, email address, and contact preferences

  • Information you provide about your health, fitness, mood, and related wellbeing activities  

  • Your gender, height, weight, age, and date of birth

  • Linked Service data, such as physical activity, sleep, and heart rate from an external wearable device you link to the HeadUp Mobile Application

  • Demographic data, such as your county, suburb, and city

  • Additional information you may provide in the course of submitting queries to HeadUp or responding to HeadUp Mobile Application surveys, questionnaires, or other product / market research surveys HeadUp may send you from time to time

  • Mobile Application tracking data, such as your device(s) identifiers and IP address

Linked Services

As a HeadUp Member, you are able to connect one or more smart devices or activity trackers to your Member Account. These devices track, among other things, your steps activity, sleep patterns, and heart rate, as well as self-entered data, such as your height, weight, and age, and calculated or inferred data such as BMI. From this information, HeadUp is able to calculate an overall wellbeing / health score for provided data points and analyse your sleep, activity, and heart rate patterns to provide you with insights into trends and comparisons against benchmarks.

We will not link your device data with the HeadUp Mobile Application without your explicit and informed consent to do so. You may withdraw your consent at any time by contacting HeadUp and providing notice that you wish to withdraw your consent to this Privacy Policy or you may revoke permissions for the HeadUp Mobile Application from within your device settings.

Depending on the smart device or activity tracker you use, the data we may collect may vary. Typically, the activity tracking and smart device manufacturers have their own specific privacy policies available, which outline what data the device collects. We urge you to review the corresponding privacy policy for your device to know what specific data points your activity tracking device collects about you.

You may be able to link your Member account to Social Media Sites (“SMS”) accounts such as your Facebook account when using HeadUp Services. By linking your SMS account with your HeadUp account, you permit us to access your information on that SMS. The information we collect from your SMS account may depend on your privacy settings with that SMS, which may enable you to control the information we collect via the SMS account by adjusting your privacy settings on that SMS. You can also de-link your SMS account from HeadUp at any time.

How we use your personal information

We may process your Personal Information for the purposes described in this Privacy Policy with your consent, for compliance with a legal obligation to which HeadUp is subject, or when we have assessed it is necessary for the purposes of the legitimate interests pursued by HeadUp or a third party to whom it may be necessary to disclose information.

Personal Information we collect will be used to provide you with Member Account access to our Mobile Application, including – but not limited to:

  • To identify you when you sign-in and protect the security of your Personal Information and HeadUp account

  • To administer and manage your Member Account, including the personalisation and enhancement of your experience while using the App

  • To track your activity and wellbeing metrics

  • To provide you with ongoing information about the HeadUp Mobile Application, its content and its features

  • To provide you with ongoing support and respond to your questions and requests, contact you for customer satisfaction surveys, and conduct market research

  • To maintain or support products or services you have requested or obtained from us or our affiliated Third Parties, to evaluate your eligibility for such products or services, and to process transactions you have requested or that are necessary for HeadUp to conduct and administer our business

  • We do not share Personal Information with unaffiliated Third Parties for their own marketing purposes, except that we may share Personal Information with select companies to jointly sponsor or offer products or services to you

The Personal Information we collect also allows us to keep you posted from time to time on HeadUp’s latest product announcements and Mobile Application updates. If you do not wish to be on our mailing list, you can opt out anytime by updating your preferences in the Mobile Application Settings. From time to time, we may also use your Personal Information to send important notices, such as changes to our Terms of Use and Privacy Policy. Because this information is important to your interaction with HeadUp, you may not opt out of receiving these communications.

We also use Personal Information to help us improve, develop, and support our Mobile Application and to inform potential new HeadUp product and service development and innovation, as well as for other internal purposes, such as research and data analysis.

We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to meet legal requirements. For example, we may use date of birth to determine the age of HeadUp Account Members.

We may also use your Personal Information to create Anonymous Data records by first de-identifying your Personal Information, which means removing any information that would allow the remaining data to be linked back to you. We may use Anonymous Data for internal purposes, such as analysing overall health and Mobile Application usage patterns and preferences to improve our product. Subject to applicable laws and regulations, HeadUp reserves the right to disclose Anonymous Data at its sole discretion.

HeadUp may also combine Non-Personal Information (data which cannot be linked back to you) with Personal Information. In the event of combining this data, the combined information will be treated as Personal Information for as long as it remains combined.

 

Cookies and Other Technologies

HeadUp’s Website, Mobile Application, email messages, and Service Providers may use "cookies" and other technologies such as pixel tags and web beacons. These technologies help HeadUp improve its understanding of Member Account behaviour and tell us which parts of our Website or Mobile Application people have visited and functionality that has been used and personalise and customise content, so that your settings are ‘remembered’ when you log in (for example, knowing your name enables HeadUp to personalise content to you). To the extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Information by local law, we treat these as Personal Information. As is true of most internet services, we also track some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, language settings, browser type Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.

If you wish to find out more about cookies and find out how to disable them, you can visit www.aboutcookies.org.uk/.

In some of our email messages, we use pixel tags to inform us whether an email has been opened or not. We may use this information to optimise or reduce future messages sent to customers.

 

Data Storage and Security of your Personal Information

We use a variety of security technologies and procedures to help protect your Personal Information from unauthorised access, use or disclosure and preserve the confidentiality, integrity and availability of your Personal Information. This includes the encryption of your Personal Information in transit via Transport Layer Security (TLS) and at rest, salting and hashing of all passwords, and a range of information security and data privacy policies and procedures within the HeadUp organisation which all relevant staff and contractors must follow. To ensure your Personal Information is secure, we communicate our privacy and security guidelines to all HeadUp employees and contractors and strictly enforce information security and privacy safeguards within the organisation.

We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. When your personal data is stored by HeadUp, we use secure third party computer systems with limited access housed in facilities using physical security measures.

 

Disclosure to Third Parties

With your permission, HeadUp may make certain Personal Information available to Third Parties to enable us to provide you with the Mobile Application or to provide ongoing support or to help HeadUp market to customers or for research purposes. Where HeadUp needs to share your Personal Information with a Third Party, the information we disclose will be limited to the minimum amount necessary to ensure the quality and provision of the services HeadUp provides you. We do not sell or rent your Personal Information to Third Parties.

 

Service Providers

HeadUp shares Personal Information with designated Third Parties that provide services such as managing Member data, providing customer service, conducting product, research or satisfaction surveys, and sending email to you. These companies are required to protect your Personal Information and may be located wherever HeadUp operates.

Government entities, Agents / Contractors, and Others

It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for HeadUp to disclose your Personal Information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.

We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganisation, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

In some instances, HeadUp may disclose your Personal Information with agents or contractors that work on HeadUp’s behalf to assist HeadUp in providing and supporting the services offered. This may include analysing your data or helping HeadUp to communicate important information to you.

 

Automated Decision-Making and Profiling

HeadUp does not take any decisions involving the use of algorithms or profiling that significantly affects you.

Retention of your Personal Information

HeadUp retains your Personal Information only for the period necessary to fulfil those purposes set out in this Privacy Policy. When assessing the retention periods for any Personal Information we collect, we review our need to collect Personal Information at all and, subject to establishing a relevant need, only retain Personal Information for the shortest period possible to realise the purpose of collection, unless a longer retention period is required by law.

Access to, and deletion of, your Personal Information

For any Personal Information we hold, we will provide you upon request with access to your Personal Information in a standard format for any purpose, except where identified by local laws. HeadUp provides the ability for Members to access and correct data via the Mobile Application itself or via submitting a request to support@headuplabs.com where the Mobile Application functionality is not available. You can also submit a deletion request to support@headuplabs.com to request the deletion of your data from our system, which will result in the permanent and irreversible de-identification of your Personal Information. We will respond to your request within a reasonable timeframe.

Correction and updating of your Personal Information

You have the right to be able to update or correct any Personal Information HeadUp holds. You can correct or update the information HeadUp holds by modifying it directly within Mobile Application. If you are unable to directly correct or update the information in the Mobile Application, you may contact support@headuplabs.com to request HeadUp to update or correct the information for you. We will respond to your request within a reasonable timeframe.

Protecting Children

HeadUp does not permit individuals under the age of 18 to create a Member Account or to use the HeadUp Mobile Application.

In the event that we learn of collecting the Personal Information of anyone under the age of 18, HeadUp will take steps to delete their information as soon as possible.

 

Addressing your Privacy Questions

If you have any questions or concerns regarding HeadUp’s Privacy Policy or how we handle or process your Personal Information, please contact us at privacy@headuplabs.com or in writing at:

The Data Protection Officer
HeadUp Labs Pty Ltd

11/320 Carlisle Street,
Balaclava, Victoria, Australia, 3183

HeadUp may update its Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy.