- how Personal Information is collected and held;
- the purposes for which your Personal Information is collected and held;
- how Mable may use that Personal Information, and whether Mable may disclose the Personal Information to third parties;
- how you can gain access to your Personal Information and seek its correction;
- how you may complain or inquire about our collection, handling, use or disclosure of your Personal Information and how that complaint or inquiry will be handled; and
- whether we are likely to disclose your Personal Information to any overseas participants.
1.3 Protecting your privacy is very important to Mable, and the organisation is committed to maintaining the security of Personal Information provided to Mable by persons who use this Site and register to become Members
- “Corporations Act” means the Corporations Act 2001 (Cth) as amended from time to time;
- “Members” means Users who register on the Site to obtain services offered by Mable;
- “Privacy Act” means the Privacy Act (Cth) 1988, as amended from time to time;
- “Site” means the website located at www.mable.com.au
- “User Agreement” means the agreement between Mable and each User of the Site which sets out the terms and conditions in respect to the Site, and is located at mable.com.au/terms-of-use
- “Users” means any person who logs onto the Site; and
- “Visitors” means Users who log on to the Site but do not create an account;
2.2 Unless the context provides otherwise
- a references in this Policy to “you” includes references to Visitors and Members; and
- capitalised terms not defined in this Policy have the meanings given in our User Agreement located atmable.com.au/terms-of-use
3. Who does Mable collect Personal Information from?
3.1 We may collect Personal Information from:
- Users when they visit our Site; and
- Members which includes Customers and Care workers and other third parties who register as Members.
4. User consent
4.1. By submitting Personal Information through our Site or Services, you agree to the terms of this Policy, and you expressly consent to the collection, use and disclosure of your Personal Information in accordance with this Policy.
5. A note about children
5.1 We do not intentionally gather Personal Information from Visitors who are under the age of 18.
6. Types of data we collect
6.1 The information Mable collects about you depends on how and why you access our Site. If you visit the Site to read, browse or download information, our computer system will record information about the visit.
6.2 For the purposes of this Policy
- (a)”Personal Information” means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion, including, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.
- “Anonymous Data” means data that is not associated with or linked to your Personal Information. Anonymous Data does not, by itself, permit the identification of individual persons.
6.3 We collect Personal Information and Anonymous Data, as described below.
- Information You Provide to Us
- If you are a Care worker, when you create an account to log in to our Site, we may collect Personal Information from you, such as your first and last name, birth date, drivers license number, criminal history, ethnicity, gender, religion, email and mailing address, phone number, work experience, salary/income, professional license numbers, education, interests, hobbies, professional and personal references, profile picture and video, professional skills and abilities, life style information, schedule availability, music preferences and bank information to facilitate direct deposit of earnings.
- If you are a Customer, when you create an account to log into our Site, we may collect Personal Information from you, such as your first and last name, birth date, gender, religion, email and mailing address, phone number, family or emergency contacts, care services needed, care plan, health conditions, activities, profile picture, interests, music preferences, household information and credit card information to facilitate payment processing.
- If you are a Member other than a Care worker or Customer, such as a family member or government Approved Provider, when you create an account to log in to our Site, we may collect Personal Information from you, similar to the information outlined in paragraphs 6.3(a)(i) and (ii) above.
- Sensitive Information
- We may collect sensitive information from Customers and Care workers when they chose to provide information about themselves, and their care requirements, through the Site. Individuals must provide their consent for Mable to collect sensitive information. Consent will be sought from the Customer
- Sensitive information is personal or health information regarding an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or a trade association, membership of a trade union, sexual preferences or practices or criminal record.
- How we retain Personal Information
- We retain information on your behalf, such as files and messages that you store using Your Account.
- If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
- When you post messages or upload content within our Site, the information contained in your posting will be stored on our servers, and other users to whom you provide access, will be able to see such messages and content.
- We also collect other types of Personal Information that you provide to us voluntarily, such as your operating system and version, and other requested information if you contact us via e-mail regarding support for the Services.
- We may also collect Personal Information, at such other points in our Site that state that Personal Information is being collected. Please note that you can choose not to provide us with certain information, but this may limit the features of the Site or Services you are able to use.
- Information Collected via Technology
- To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
- We may also use:
- third party tracking services to track and analyse Anonymous Data from users of our Site and Services; and
- location-enabled services for Care workers as a means to facilitate time card data.
- If in future you use the location-enabled services, Mable may receive information about your actual location (such as GPS signals sent by a mobile device or via your web browser when on the Site).
- Information Collected from You About Others
- Care workers, Customers and Visitors to our Site can invite other people to become Mable Members by sending invitation emails via our Site.
- We store the email addresses that are provided to us and, if they are provided by a Mable Member, we will associate those email addresses with such Member’s account.
- We do not currently sell these email addresses or use them to send any other communication besides invitations (unless the email address is used in registration by a new Member) but we may do so in the future.
- Participants of invitations may unsubscribe by contacting us at email@example.com request that we refrain from sending them emails or to have us delete their information in accordance with this Policy.
- Information Collected from Others About You
- Other Members may provide us Personal Information and/or Anonymous Data about you through our Site or the Services. Examples include when a Customer posts feedback regarding a Care worker or when another Member (including a Customer’s Approved Provider) submits health information or care plan information to our Site.
- Information Collected from Third Party Companies
- We may receive Personal Information and/or Anonymous Data about you from companies that assist Mable in providing the Services, such as service providers who assist with identifying you or companies that offer their products and/or services on our Site.
- These third party companies may supply us with your Personal Information. We may add this information to the information we have already collected from you via our Site in order to provide and improve the Services.
- Unsolicited Information
Where we collect unsolicited information (being information without having sought the information) we will only hold, use and or disclose that information if we could otherwise do so had we collected it by normal means. If that unsolicited information could not have been collected by normal means then we will destroy, permanently delete or de-identify the information as appropriate.
7. Use of Your Personal Information
7.1 General Use.
In general, Personal Information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Information in the following ways:
- to facilitate the creation of and secure Your Account on our network;
- to identify you as a User in our system;
- to run a background check;
- to verify your credentials (if you are a Care worker);
- to provide improved administration of our Site and Services;
- to provide the Services you request;
- to improve the quality of experience when you interact with our Site and Services;
- to tailor the features, performance and support of the Site or Services to you;
- to send you a welcome e-mail to verify ownership of the e-mail address provided when Your Account was created;
- to send you administrative e-mail notifications, such as security or support and maintenance advisories;
- to respond to your inquiries or requests and/or troubleshoot problems;
- to make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback;
- to send newsletters, surveys, offers, and other promotional materials related to our Services and for other Mable marketing purposes;
- to customise the advertising you may see on the Site or through the Services;
- to collect and/or distribute money; and
- to verify your compliance with your obligations in our User Agreement or other Mable policies.
7.2 Creation of Anonymous Data
We may create Anonymous Data records from Personal Information by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyse request and usage patterns so that we may enhance the content of our Services and improve Site navigation. Mable reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in its sole discretion.
8. Disclosure of Your Personal Information
8.1 We may disclose your Personal Information as described below and as described elsewhere in this Policy.
8.2 Other Mable Members
- We may share your Personal Information with third parties to whom you ask us to send Personal Information, including other Members. Unless you direct us to provide access to your Personal Information via your “Privacy Settings” or otherwise, we do not disclose the Personal Information of any Customer or Care worker to any another Member. We do, however, provide other Members with the opportunity to communicate with you through an anonymous in-browser message box.
- Care workers and Customers are described on the Site by their first name only. When a Customer and a Care worker wish to make contact with each other for the purposes of Home Care Services, Mable will release Personal Information about each person to the other person (this will include the persons full name and contact details, and may include Sensitive Information that a Customer has submitted through the Site).
- If requested, we may provide a copy of your Police Check, Working With Children Check, references, qualifications or other profile documents to clients or providers who engage you on Mable.
8.3 Third Party Service Providers.
- We may share your Personal Information with third party service providers to:
- provide you with the Services that we offer you through our Site;
- to conduct quality assurance testing;
- to facilitate creation of accounts; and
- to provide technical support.
- These third party service providers are required not to use your Personal Information other than to provide the services requested by Mable. Examples of such third party service providers include: companies that administer background checks of Care workers and companies that process payments from both Care workers and Customers. These third party service providers are required not to use your Personal Information other than to provide the services requested by Mable.
8.4 Direct Marketing
- Where information (other than sensitive information) is collected by Mable directly from an individual, that information may only be used by Mable (or disclosed by Mable to a third party) for direct marketing purposes if:
- the individual has consent to Mable using or disclosing that information for that purpose, or the individual would reasonably expect Mable to use or disclose the information for that purpose; and
- Mable (or the third party) provides a simple means by which the individual may easily request not to receive direct marketing communications; and.
- the individual has not made a request not to receive direct marketing communications from Mable (of the third party).
8.5 Affiliates and Acquisitions
- We may share some or all of your Personal Information with our Related Bodies Corporate (as defined in the Corporations Act), joint ventures, or other companies under a common control (” Affiliates“), in which case we will require our Affiliates to honour this Policy.
- If another company acquires the shares in Mable, the business, or our assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Policy.
8.6 Overseas Participants
We use systems located within Australia, and do not send to, or store health information or bank account details with overseas organisations. Your basic contact details (name, phone number and/or email address) may be shared with third party providers located outside Australia.
8.7 Other Disclosures
Regardless of any choices you make regarding your Personal Information (as described below), Mable may disclose Personal Information if it believes in good faith that such disclosure is necessary:
- in connection with any legal investigation;
- to comply with relevant laws, or to respond to subpoenas or warrants served on us;
- to lessen or prevent a serious threat to the life, health or safety of an individual or to public safety;
- to investigate or assist in preventing any violation or potential violation of the law;
- where another permitted general situation (as defined in the Privacy Act 1988) applies; and/or
- where disclosure is reasonably necessary for a law enforcement related activity.
9. Third party data collection
9.1 Third Party Websites
- The Site may contain links to other websites that are not owned or controlled by us. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other websites. When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Information or Anonymous Data from you.
- We have no control over, do not review, and cannot be responsible for, these outside websites or their content.
- Please be aware that the terms of this Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.
9.2 Information Collected by Ad Networks
We may use third-party advertising companies to serve ads when you visit our Site. These companies may collect and use information (not including your name, address, email address, or telephone number) about your visits to the Site and other websites in order to provide advertisements about goods and services to you.
9.3 Information Collected by Other Third Parties
- This Policy addresses only our use and disclosure of Personal Information we collect from and/or about you. If you disclose information to others, including to other Members, the use and disclosure restrictions contained in this Policy will not apply to any third party.
- We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. In addition, information made available through the Service by Members may be protected by applicable privacy laws.
10. Your choices regarding your personal data
10.1 Unless you become a Member, Mable does not collect information that identifies you personally.
- We offer you choices regarding the collection, use, and sharing of your Personal Information.
- We will periodically send you free newsletters and e-mails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive, or by contacting us directly (please see contact information below). Our electronic marketing activities will comply with the requirements of the Spam Act 2003 (Cth)
- Despite your indicated e-mail preferences, we may send you service related communication, including notices of any updates to our User Agreement or Policy.
10.3 Changes to Personal Information
You may update, change or clear any Personal Information or other information we hold in Your Account by editing your Profile, by logging in to the ‘Profile’ area of the Site.
10.4 Deletion of Personal Information
- You may request deletion of your Personal Information by us, but please note that we may be required to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements).
- If we no longer need Personal Information for any purpose for which we may use or disclose the information (e.g. if the primary purpose for collection is no longer relevant), and the information is not otherwise required to be kept under an Australian law or court order, we will take reasonable steps to destroy or permanently de-identify the information.
- When we delete any information, it will be deleted from the active database, but may remain in our archives. We may retain your information for fraud or similar purposes if this is permitted pursuant to an Australian law or court order.
- However, if we have already disclosed some of your Personal Information to third parties, we cannot access that Personal Information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.
11. Security of your personal data
11.1 Mable is committed to protecting the security of your Personal Information. We use a variety of industry-standard security technologies and procedures to help protect your Personal Information from unauthorised access, use, or disclosure.
11.2 Any information which we hold for you is stored on secure servers that are protected in controlled facilities. We also require you to enter a password to access Your Account information. Please do not disclose Your Account password to unauthorised people.
11.3 Please notify us immediately if there is any unauthorised use of Your Account or any breach of security relating to Your Account.
11.4 No method of transmission over the Internet, or method of electronic storage, is 100% secure, however, while Mable uses reasonable efforts to protect your Personal Information, Mable cannot guarantee its absolute security.
11.5 In addition, our employees and contractors who provide services related to our information systems are obliged to respect the confidentiality and privacy of any Personal Information held by Mable. However, Mable will not be held responsible for events arising from unauthorised access of your Personal Information.
12. Requests for access to Personal Information, Complaints and Feedback
12.1 Mable welcomes ideas and feedback about all aspects of the Site. Mable stores feedback that users send to us. This feedback will be used to administer and refine the service and may be shared with Mable partners either in aggregate form or with specific identifying characteristics removed.
12.2 You can request access to the Personal Information we hold about you, or request that we change and/or update the Personal Information we hold, by sending a formal request by contacting us using any of the methods detailed in the “Contact Information” paragraph below.
12.3 Upon request, we will give you access to the information held about you, unless specific limitations apply (for example, if the request is frivolous or vexatious, or providing access would be unlawful). We reserve the right to charge reasonable costs incurred in providing access to you.
12.4 We will respond to a request for access to Personal Information within a reasonable period after the request is made, and give access to the information in the manner requested by the individual, if it is reasonable and practicable to do so.
12.5 If we do not agree to provide you with access, or to amend your Personal Information as requested, you will be notified accordingly. Where appropriate we will provide you with the reason/s for our decision, and the mechanisms available to complain about the refusal. If the rejection relates to a request to change your Personal Information you may make a statement about the requested change and we will attach this to your record.
12.6 If you have any complaints about our dealings with your Personal Information including any breaches by us of any Australian Privacy Principles you are able to submit that complaint by contacting us using any of the methods detailed in the “Contact Information” paragraph below.
12.7 Any complaints received by us will be referred for prompt investigation by our compliance team and a written response will be provided to you within a reasonable time (usually no longer than 30 days). We may seek further information from you in order to provide you with a full and complete response.
12.8 Your complaint may also be taken to the Office of the Australian Information Commissioner. You may contact the Australian Information Commissioner by calling them on 1300 363 992, contacting them online atwww.oaic.gov.au,or by writing to the Office of the Australian Information Commissioner at GPO Box 5218 Sydney NSW 2001.
13. Contact information
13.1 Mable welcomes your comments or questions regarding this Policy.
13.3 Please contact us using the following details.
1300 73 65 73
Better Caring Pty Limited trading as Mable Suite 810, 46-56 Kippax Street,
Surry Hills NSW 2010
14.1 This Policy is subject to occasional revision from time to time. Please check our Policy on our Site regularly for any updates and amendments
14.2 If we make any material changes in the way we use your Personal Information, we will notify you by sending you an e-mail to the last e-mail address you provided to us, and/or by posting notice of the changes on our Site.
14.3 Any changes to this Policy will be effective upon the earlier of:
- thirty (30) calendar days following our dispatch of an e-mail notice to you; or
- thirty (30) calendar days following our posting of notice of the changes on our Site.
14.4 These changes will be effective immediately for new Members.
14.5 Please note that at all times you are responsible for updating your Personal Information to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice.
14.6 In any event, changes to this Policy may affect our use of Personal Information that you have provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Information, you must notify us prior to the effective date of the changes that you wish to deactivate Your Account with us.
14.7 Continued use of our Site or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
15. Provision of Copy of Privacy Statement
15.1 If you require a hard copy of this Privacy Statement or a copy in some other format to suit your particular needs please contact us using any of the methods detailed in the “Contact Us” paragraph above, and we will arrange for a suitable copy to be provided to you.
16. More Information About Privacy
16.1 For more information about privacy issues in Australia and protecting your privacy, visit the Australian Information Commissioner by calling them on 1300 363 992 or contacting them online atwww.oaic.gov.au