Plain English Version
This is the plain English version of Dala’s (Toucan Health Pty Ltd) privacy policy and is not legally binding. If you want to view our legalise document (which is legally binding), please click the toggle button above.
This privacy policy outlines how Dala (Toucan Health Pty Ltd) will collect, use and store your data. It was last updated on August 4, 2021.
If you have any questions, need to contact Dala (Toucan Health Pty Ltd) about this policy or would like to report a bug, email us at romeo@wearespur.com or call us on +61 481 099 873.
About Dala (Toucan Health Pty Ltd)
Dala (Toucan Health Pty Ltd) is a strategy, design and venture studio focused on positively affecting human actions and measuring the outcome.
What information about you do we collect?
Dala (Toucan Health Pty Ltd) only collects the information necessary to conduct its business. We commonly collect self-reported data from you for the purpose of helping you understand your own wellbeing better. This will include data such as age, gender, ethnicity, sexual identity, work role, and your wellbeing data based on Dala’s (Toucan Health Pty Ltd) framework of six core emotions. We’ll also collect your location on occasion, for the purposes of identifying how location affects your mood.
How and why do we collect and use your personal information?
We typically collect information from you when you access our websites, use our apps, access our social media sites or call or email us. We need to collect your personal information to provide our products and services to you. This is usually to:
send you emails;
provide you with our products or services;
analyse your browsing behaviours through the use of cookies to better personalise your website viewing experience;
analyse data provided by you (all of the analysis we conduct uses anonymous data).
Who do we disclose your personal information to?
We never explicitly share your data (i.e. in a list) with anyone. However, we may share data with other companies to complement our products and services. If we ever share your data with a third party, we try to ensure they take reasonable steps to protect your information.
Do we disclose personal information to overseas recipients?
Your information might be transferred to countries that have similar data protection laws as Australia (such as the USA).
Do we use or disclose your personal information for direct marketing?
We only disclose your personal information for marketing purposes if you explicitly consent (i.e. you agree to be added to our mailing list).
How do we hold, store and secure your personal information?
We store data either via paper, electronic or third-party storage. We take steps to ensure that your data is protected and safe.
What should you do if you have a complaint about the handling of your personal information?
If you have a complaint, contact our Privacy Officer at romeo@wearespur.com. We take all privacy complaints very seriously and will respond as soon as possible.
Legal version
SPUR LABS PTY LTD ACN 619 512 015, its subsidiaries, affiliates and related entities in Australia and overseas (together as “Dala (Toucan Health Pty Ltd)”, “we” or “us”) are committed to protecting and managing personal information in accordance with the Australian Privacy Principles (APPs) established under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws.
The APPs provide a privacy protection framework that supports the rights and obligations of collecting, holding, using, accessing and correcting personal information. The APPs consist of 13 principle-based laws and apply equally to paper-based and digital environments.
This document is referred to as our Privacy Policy. It sets out our policies for managing your personal information, including how we collect, use, hold, store and disclose the information. In this Privacy Policy, “you”, “your” or “client” refers to any individual about whom we collect personal information.
Broadly speaking, when we are referring to personal information, we are referring to information or an opinion about you, or information that is reasonably recognisable as you. It includes information or an opinion that may or may not be accurate and recorded in a hardcopy or electronic form.
When we refer to sensitive information, we are referring to certain personal information that is more sensitive and may include health information and, in particular, mental health or details of memberships of professional associations. Under the APPs, sensitive information is afforded a higher level of privacy protection and requires us to obtain your consent before collecting this type of information.
This Privacy Policy applies to your personal information regardless of how we collect it from you. When you submit information to us, access or use our websites, mobile applications or social media platforms, you are providing your consent to us collecting and managing your personal information according to this Privacy Policy.
About Dala (Toucan Health Pty Ltd)
Dala (Toucan Health Pty Ltd) is a strategy, design and venture studio focused on positively affecting human actions and measuring the outcome.Dala (Toucan Health Pty Ltd) works with organisations and communities to create a fairer and more sustainable world.
As part of Dala’s (Toucan Health Pty Ltd) commitment to giving back to the community, a portion of Dala’s (Toucan Health Pty Ltd) income and 20% of employee time is donated to Dala (Toucan Health Pty Ltd)’s sister company Dala (Toucan Health Pty Ltd)org.
Dala (Toucan Health Pty Ltd) offers its products and services through its websites (Websites), mobile applications downloadable through third-party platform providers (Apps) and related social media channels. Dala (Toucan Health Pty Ltd) may also conduct research and development initiatives and provide access to other service providers and applications.
Dala (Toucan Health Pty Ltd) has a particular focus on mental health projects and campaigns to reduce the number of suicides worldwide. However, Dala (Toucan Health Pty Ltd), it’s Apps and Websites are not designed to provide medical advice or a mental or physical health diagnosis. The information provided or displayed by Dala (Toucan Health Pty Ltd) on our Websites, Apps or related social media channels does not consider your unique situation and needs. Please refer to our disclaimer for further information, which is accessible here.
Please contact us for a full list of the companies and businesses that comprise Dala (Toucan Health Pty Ltd) and that are subject to this Privacy Policy.
This policy is effective as of August 4, 2021. From time to time, we may need to change this Privacy Policy and will post the updated version on our website. Any such amendments will take effect immediately after such posting. Please check this Privacy Policy regularly for any updates.
What information do we collect about you?
When you enquire about our products and services or become a client of Dala (Toucan Health Pty Ltd), a record is made that includes your personal information.
The types of information that we collect will vary depending on the circumstances of collection and the kind of product and/or service that you request from us, and may likely include:
Contact Information & Personal Data: your name, date of birth, age, gender, address, email address, and telephone details.
Sensitive Information: Dala (Toucan Health Pty Ltd) may collect information that is considered sensitive information. For example, mental or physical health information and sexual orientation.
Payment Details: your credit card, bank account details, and billing information to complete purchases.
Financial Details: your financial details and occupation, which may include budget information, wages/salary information, and general expenditure.
Identification Documents: your driver's licence, passport or other photographic identification documents.
Photographs & Videos: any pictures, videos, sound recordings and other audio-visual recordings that you provide to us or authorise us to take of you.
Social Media Accounts & Handles: your social media accounts, handles, and other personal websites and profiles.
Geo-Location & Locality Information: when you interact with us, we may collect your current or last known location used to determine your locality from other individuals. We may achieve this through various methods, including collecting your Wi-fi, Guidance Positioning System (GPS), Cellular or other technology in your electronic device or web browser.
Cookies & Other Browser or Device Information: your session cookies and persistent cookies when you visit our Websites, your device type, browser type, Internet Protocol (IP) address, your URL information, the date and time (including time zone) of your visit, the pages you have accessed on our Websites and third party websites, your software and hardware information concerning your mobile device or computer. Cookies that we place may be removed by following instructions that are provided by your browser.
Interaction & Behavioural Information: your interactions, use, habits, behaviours when dealing with us, our Websites and other applications.
Employment Information: We collect personal information when recruiting personnel, such as your name, contact details, qualifications and work history. Generally, we will collect this information directly from you. We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions (for example, positions that involve working with children).
Other information: any other administrative and additional information that you provide to us, or authorise us to collect, as a part of your interaction with Dala (Toucan Health Pty Ltd).Dala (Toucan Health Pty Ltd) may collect personal information about other individuals who are not clients of Dala (Toucan Health Pty Ltd). This includes customers and members of the public who participate in events we are involved with, individual service providers and contractors to Dala (Toucan Health Pty Ltd), and other individuals who interact with us on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with Dala (Toucan Health Pty Ltd).
Generally, it would include your name, contact details, and information regarding our interactions and transactions with you.
If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.
You can always decline to give us your personal information, but that may mean that we cannot provide you with some or all of your requested products and services.
How and why do we collect and use your personal information?
Dala (Toucan Health Pty Ltd) collects personal information reasonably necessary to carry out our business, assess and manage our clients’ needs, and provide our products and services. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you or third parties and managing client relationships.
Dala (Toucan Health Pty Ltd) generally collects personal information directly from you. We may collect your personal information over the phone, by email, through our Websites or mobile sites, over the internet or when you visit one of our social media sites (such as Facebook, Twitter or Instagram), through our mobile applications or when you visit our office in person.
We may also collect personal information about you from other sources, for example:
an authorised person acting on your behalf;
our affiliated and related entities;third-party agents, suppliers and contractors who assist us in operating our business;
recruitment service providers and any referees provided on employment applications; and
your family and friends through any marketing or promotional activity that we conduct.
We may receive information about you that we have taken no active step to collect. If this does occur, we recommend contacting us and asking for the personal information to be de-identified or destroyed.
The purposes for which Dala (Toucan Health Pty Ltd) usually collects and uses personal information depends on the nature of your interaction with us, but may include:
communicating with you confirming your identity;
responding to requests for information, complaints and enquiries;
administrative, management and operational purposes;
informing you about our business offerings, news, updates, direct marketing material, activities, facilities, services and events;
managing, planning, advertising and administering programs, events, competitions and performances;
researching, developing and expanding our facilities, products and services;
recruitment processes (including for volunteers, internships and work experience);
taking photographs, videos or other audio-visual recordings of you for testimonial, marketing or other promotional purposes;
market research purposes and to improve our business offerings;
via mobile device applications, widgets and other interactive features used, operated or owned by us;
through surveillance and security cameras that capture your image;
processing your purchases, orders, transactions or sales, including the processing of payments, arranging shipping and providing you with tax invoices or order confirmations;
for any other purposes (including secondary purposes) that you would reasonably expect;
and to enable us to comply with our obligations under the law.
Who do we disclose your personal information to?
During the conduct of our business, we may use and disclose your personal information to the following parties:
our affiliated and related entities;
our engaged contractors, agents, suppliers who assist us in operating our business;
commercial partners under an agreed information sharing arrangement;
our marketing research service providers and digital marketing agents;
our professional advisors, such as our lawyers, accountants and financial advisors;
relevant courts, tribunals or regulatory authorities and law enforcement bodies;
anyone else to whom you authorise us to disclose your information or that would be reasonably expected; and
other companies or individuals as necessary to enable us to provide you with our products and services.
Dala (Toucan Health Pty Ltd) takes reasonable steps to ensure that the third parties we engage take reasonable steps to protect your personal information following the APPs and in a similar manner with this Privacy Policy. Our third-party service providers are required only to use the personal information disclosed to them by us for the purpose that it was provided to them. Additionally, the third parties to who we have disclosed your personal information may contact you directly to let you know they have collected your personal information and give you information about their privacy policies.
Dala (Toucan Health Pty Ltd) may also use Google Analytics to help us understand how our customers and clients use our platforms, products and services. You can read more about how Google uses your personal information here. You may also opt-out of Google Analytics here.
Do we disclose personal information to overseas recipients?
Your personal information may be transferred to recipients located in countries with data protection laws that protect personal information in a way that is at least substantially similar to the APPs. Accordingly, there may be mechanisms available to you to enforce the protection of your personal information under that overseas law. In the circumstances, we do not require the overseas recipients to comply with the APPs, and we will not be liable for a breach of the APPs if your personal information is mishandled. We also disclaim responsibility to the extent permitted by law and note that you may not have a remedy under Australian law.
How do we hold, store and secure your personal information?
Dala (Toucan Health Pty Ltd) takes reasonable steps to protect your personal information from misuse, interference and loss, and unauthorised access, modification, or disclosure. For example, we may maintain computer and network security, use firewalls and other security methods and other security systems such as user identifiers and passwords to control access to our computer systems.
Please be aware that there is no transmission method over the internet or through electronic storage that is fully secure and safe. We cannot guarantee the security of your personal information that we hold, but we do take reasonable steps to protect your information. If we are required by law to inform you of any misuse, interference, loss or unauthorised of your personal information, then we will notify you electronically, in writing or by telephone.
Our Websites, Apps or email systems may not use encryption or other technologies to ensure the secure transmission and receipt of information via the internet. Anyone using our Websites or receiving an email from us is encouraged to exercise care in sending personal information or depositing money via the internet. We recommend that you refrain from clicking any unsecured links or opening unknown attachments.
If you hold any concerns or become suspicious of any misuse, interference, loss or unauthorised access to our Websites, our email systems or to our business more generally, we ask that you contact us immediately to verify your concern or suspicion.
Dala (Toucan Health Pty Ltd) hold and store your personal information in paper-based files, other electronic record-keeping methods in secure databases (including trusted third party storage providers based in Australia and overseas), which may include cloud-based storage providers.
Paper-based Storage: Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed).
Electronic Storage: Your personal information is usually collected in electronic form.
Third-Party Storage: Your personal information may be collected in electronic form for use or storage with a third-party storage provider that we engage.We cannot ensure that your personal information is or will remain secure. This is due to us not having control over the third-party provider’s policies and procedures concerning the handling and storing your personal information.
What are the choices that you can make about your personal information?
At any time, you can request us to:
delete or destroy your personal information;
de-identify your personal information;
access or correct your personal information;
provide you with a copy of your personal information.
Please understand that we may not be able to entertain your request if it is unlawful to do so or is otherwise impractical or unreasonable to do so at our discretion.
Delete or destroy your personal information: Until you request for it to be deleted or destroyed, your personal information is kept by us for as long as necessary to provide our products and services to you and for legitimate and essential business purposes, such as complying with our legal obligations or settling disputes. This means that your personal information can be held for some time.
Remaining Anonymous & De-Identification: Dala (Toucan Health Pty Ltd) may require you to provide specific details and information to enable us to provide our products and services to you. We try to allow you to stay anonymous or use a pseudonym in your dealings with us where it is lawful and practicable to do so. For example, when making a general and nonspecific enquiry. Typically, it is not possible for us to deal with you anonymously or pseudonymously on an ongoing basis. If we do not collect your personal information, you may not be able to utilise our products and services, deal with us or participate in our events, programs or activities we manage or deliver.
Accessing or correcting your personal informationYou are entitled to access or request a copy of your personal information held by us by sending us a request. You will not be charged for requests to access or copy your personal information, but you may be charged for the reasonable time and expense incurred in compiling the information. Yo
u are responsible for ensuring that your personal information with us is accurate and up to date. We take steps to ensure that the personal information we collect, use or disclose is accurate and up to date. You can help us do this by letting us know if you notice errors, inaccuracies or discrepancies in the information we hold about you and letting us know if your details change.
We may decline your request to access or correct your personal information in accordance with the APPs. If we refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
Does the European Union General Data Protection Regulation apply to us?
The European Union (EU) General Data Protection Regulation (GDPR) contains new data protection requirements and is effective as of 25 May 2018. GDPR replaces national privacy and security laws that previously existed within the EU with a single, comprehensive EU-wide law that governs the use, sharing, transferring and processing of any personal data that originates from the EU. The GDPR applies to the data processing activities of businesses, regardless of size, that are data processors or controllers with an establishment in the EU.
Consequently, Australian businesses of any shape and size may need to comply if they have an establishment in the EU, if they offer goods and services in the EU, or if they monitor the behaviour of individuals in the EU. There are also some notable differences, including certain rights of individuals (such as the ‘right to be forgotten’) which do not have an equivalent right under the APPs and the Privacy Act.
Currently, the GDPR does not apply to our business as Dala (Toucan Health Pty Ltd) does not currently offer our products and services to individuals located in Europe, our Websites does not explicitly target customers located in the EU nor do we monitor the behaviour of individuals in the EU.
What should you do if you have a complaint about the handling of your personal information?
You may contact us at any time if you have any questions or concerns about this Privacy Policy or about how your personal information has been handled. You may make a complaint to our privacy officer using the contact details set out below.
Complaint handling process:
Our Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps that can be taken to resolve the complaint. We will contact you within thirty (30) days of the date we receive the written details of your complaint to acknowledge that we have received it. We may ask you to provide further information about your complaint and the outcome you are seeking.
Our privacy officer will review the way we dealt with your personal information, conduct an internal investigation (if necessary) into the complaint and will likely respond to you within thirty (30) days of the date we acknowledged receipt of your complaint. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, we will investigate and respond to a complaint within sixty (60) days of receipt of the complaint. If the matter is more complex or our investigation takes longer than anticipated, we will let you know.
If you are not satisfied with our response to your complaint, or you consider that Dala (Toucan Health Pty Ltd) may have breached the APPs or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.
Our contact information
We welcome any comments or questions about our Privacy Policy.
All enquiries should be directed to Dala’s (Toucan Health Pty Ltd) Privacy Officer at the following contact details:
Attention: Privacy Officer
Telephone: +61 481 099 873
Email: romeo@wearespur.com
This Privacy Policy was last updated on 4 August 2021