THIS POLICY DESCRIBES HOW E-HUB HEALTH MAY USE AND DISCLOSE THE PERSONAL INFORMATION THAT YOU PROVIDE IN CONNECTION WITH YOUR USE OF THE E-COUCH WEBSITE. PLEASE REVIEW IT CAREFULLY.
e-hub Health recognises the importance of ensuring your personal information is kept secure and we understand that we have a legal obligation to protect your personal information. This page sets out the policy which e-hub Health Pty Limited (PO Box 331, Goulburn NSW 2580 Australia) will use when managing personal information collected through the e-couch program.
When this policy uses 'I', 'we', 'us', 'our', 'e-hub Health' or 'e-hub' it means e-hub Health Pty Limited. 'e-couch' means the website provided at https://www.ecouch.com.au/
If you do not wish to provide your consent to the collection, use and disclosure of your personal information as described in this Privacy Statement, you will not be able to register and use the e-couch program.
In order to ensure privacy was considered when developing this website, a privacy impact assessment was undertaken.
Who does this policy apply to?
What is collected?
The type of information we may collect and hold through the e-couch program includes personal information about users of the e-couch program. If your subscription to e-couch requires payment of a fee, we may use Paddle or other payment providers to facilitate the subscription process.
In general, the personal information we may collect and hold relating to the e-couch program consists of:
collectively referred to as User Data.
We do not store your credit card details in any form.
How do we collect and hold personal information?
The e-couch program is hosted on servers located within Australia, and data, including any personal information, is stored on these servers located in Australia. The servers are provided by an Infrastructure as a Service (IaaS) provider, and the servers and program software are managed by e-hub Health and Dialogue Health Technologies, e-hub Health’s parent company who have a corporate headquarter in Canada. Dialogue Health Technologies assists us in providing our services.
We collect personal information from you directly when you provide your information to us by entering data in the e-couch program or from you indirectly through emails and forms.
In order to use the e-couch program you are required to register and log in using an email address. If you wish to remain anonymous, you are welcome to create a new email address or use an email alias if your email provider supports this, to protect your anonymity. The email address you supply will be used only to send a welcome email, for retrieval of your login details should you forget your password, and in extreme circumstances, to notify you if you have been affected by a data breach. When we share aggregated reports with other parties detailed in the ‘Who do we disclose your personal information to?’ section, we ensure email addresses are not shared so that de-identified data cannot be re-identified by any party.
Protection of user privacy is a high priority for e-hub Health and we take reasonable steps to protect the security of personal information. Our personnel are required to respect the confidentiality of personal information and the privacy of individuals. We take reasonable steps to protect personal information held from misuse and loss and from unauthorised access, modification or disclosure, for example by use of physical security and restricted access to electronic records. Despite these measures, there is always some risk that an unauthorized third party will find a way to penetrate e-hub Health’s security or that personal information transmitted over the internet will be intercepted.
Why do we collect, hold, use and disclose personal information?
In general, we may collect, hold, use and disclose your personal information collected through the e-couch program for the following purposes:
Where your access to e-couch has been made available to you by your employer or another organisation, your personal information may be used to generate aggregated reports for your employer or the organisation that provided you with access for the purpose of managing and recording the progress and completion of the e-couch program modules. User Data is excluded from reports to your employer or the other organisation that provided you with access.
Where your access to e-couch has been made available to you by a research institution that is conducting a research trial (the RO), your personal information, including User Data, may be used to facilitate the research and generate research reports for the RO. These reports may contain your registration data, your quiz scores and information about your progress through the site and may be used by the RO to undertake that research trial.
You grant e-hub Health and all other persons or entities involved in the operation of the e-couch website the right to transmit, retrieve, store, use and monitor the information you enter so that they may operate the website and make the information available as described above.
Who do we disclose your personal information to?
We may disclose your personal information:
- where we are required to do so by law;
- with your prior written consent;
- where your access to the website has been made available to you by your employer or other entity, to this employer or entity, but only in the form of aggregated reports for user analysis (which include no identifying information);
- where your access to the website has been made available by a research organisation that is conducting a research trial, to this research institution;
- where you purchase access to the website via an individual subscription, to Paddle (but only your email address so that Paddle can communicate with you about your purchase);
- to staff from Dialogue Health Technologies in Canada who are seconded to e-hub Health to assist us in providing our services; and
- to our Service Providers that enable our platform to provide the services to you such as, backup and servers hosting solution providers, data security, data analytics providers and/ or software and IT maintenance providers, service providers who assist with the authentication of individuals and payment processing.
In addition, we may release your personal information (1) in response to a court order, search warrant, subpoena or other legal action, (2) to protect persons or property or to defend or assert legal rights or (3) in connection with a transaction or proceeding resulting in the transfer of e-hub Health assets or an e-hub Health business operation that includes or uses such information.
Are we likely to disclose your personal information outside of Australia?
We may disclose your personal information to the following overseas recipients:
- to anyone described above under “Who do we disclose your personal information to?”
- e-hub Health strives to limit storage of personal information to within Australia where possible. Our Service Providers may access or store Personal Information in Canada, United Kingdom, European Union, United States.
- Dialogue Health Technologies Inc is a global company who have personnel in Canada, United Kingdom and the European Union and therefore may process personal information wherever Dialogue Health Technologies has personnel.
Whenever we transfer your personal data to a third country or to an international organization, we ensure that an adequate level of protection is afforded to it by ensuring that adequate safeguards are implemented.
How can you access and correct your personal information?
Subject to the exceptions set out in the Australian Privacy Act, you may seek access to, correction of and deletion of the personal information which we hold about you by contacting us at firstname.lastname@example.org. We will require you to verify your identity and to specify what information you require. If a fee is charged for providing access, you will be advised of the likely cost in advance.
How can you make a privacy related complaint?
If you have any questions about privacy-related issues or wish to complain about a breach of the Australian Privacy Principles or the handling of your personal information by us, please contact our Privacy Officer at email@example.com. We may ask you to lodge your complaint in writing.
If we are unable to satisfactorily resolve your concerns about our handling of your personal information, you can contact the Office of the Australian Information Commissioner:
GPO Box 5218
Sydney NSW 2001
Tel: 1300 363 992
The e-couch website is not intended for use by children under the age of 14 or for children under the age of 18 in the USA. We do not knowingly collect information from any person under the age of 14 or from any person under the age of 18 in the USA, and you should not submit such information to us.
Additional information: processing of personal data which is applicable under the GDPR (Europe)
In accordance with Art. 15 GDPR you can request information about your personal data processed by us. In particular, you may request information on the purposes of processing, the categories of personal data, the categories of recipients to whom your data have been or will be disclosed, the planned storage period, the existence of a right to rectification, deletion, restriction of processing or opposition, the existence of a right of appeal, the origin of your data, if not collected by us, about a transfer to third countries or international organisations and the existence of automated decision-making including profiling and, if applicable, meaningful information on their details.
In accordance with Art. 16 GDPR you can immediately demand the correction of incorrect personal data or the completion of your personal data.
Pursuant to Art. 17 GDPR, you may request the deletion of your personal data stored by us, provided that the processing is not necessary to exercise the right to freedom of expression and information, to fulfil a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims.
In accordance with Art. 18 GDPR, you can request the restriction of the processing of your personal data if you dispute the accuracy of the data, if the processing is unlawful, if we no longer need the data and if you refuse their deletion because you need them to assert, exercise or defend legal claims. You are also entitled to the right under Art. 18 GDPR if you have filed an objection to the processing pursuant to Art. 21 GDPR.
Pursuant to Art. 20 GDPR, you may request that the personal data you have provided us with be received in a structured, current and machine-readable format or you may request that it be transmitted to another person responsible.
In accordance with Art. 7 (3) GDPR you can withdraw your consent at any time. As a consequence, we are no longer allowed to continue the data processing based on this consent for the future.
You can exercise your rights by contacting us at firstname.lastname@example.org. We will ask you to verify your identity and indicate what information you wish to receive.
The e-couch program uses 'transient cookies'. Cookies are pieces of information that a website transfers to your computer's hard disk when you open the website. Cookies by themselves do not identify you but they do identify your web browser.
When you access the e-couch program our server makes a record of your visit and logs the following information: your browser's internet address; the date and time of your visit to the site; the pages you've accessed and documents downloaded; the type of browser you are using; the last viewed date; and the time of your visit.
The information collected by the e-couch program is used for statistical purposes and system administration tasks to maintain this service.
Because the e-couch program uses 'transient cookies' your computer does not retain the information delivered in the cookies once you leave the e-couch program website. When you close your browser, the transient cookie set up by e-couch program is destroyed and no information is retained which could identify you or your browser next time you log onto the e-couch program.
Adwords tracking (Australia)
The e-couch website uses Google Adwords Conversion Tracking which helps us to track how many users from Australia who click on our Google Ads end up registering on e-couch. This sets a tracking cookie on your browser only when you click on a Google Ad. These cookies expire within 30 days and do not contain information that can identify you personally. You can read more at the Google Advertising Privacy Notice including information about how to opt out.
Please be aware that any changes in the privacy practices of your employer or other organisation through which you received access to the website will not be posted on the e-couch website.
Last updated: 15 January 2024Back