1. Purpose of this Policy
- how Mable collects and holds Personal Information;
- the purposes for which we collect and hold Personal Information;
- how we may use that Personal Information, and to whom we may disclose it;
- our disclosures of Personal Information to entities overseas;
- how you can gain access to your Personal Information and seek its correction; and
- how you may inquire or make a complaint about our collection, handling, use or disclosure of your Personal Information, and how that inquiry or complaint will be handled.
1.3 “Personal Information” is, broadly speaking, any information or opinion about a person, or otherwise relating to a person, where that person is identified or could be identified. “Sensitive information” is a special subset of Personal Information, and includes information about a person’s physical and mental health (including any injuries or disabilities they may have) and other information about things like their racial or ethnic background, religious beliefs, membership of a professional or trade association or a trade union, sexual orientation, and criminal record. In this Policy, references to “Personal Information” include sensitive information.
1.4 Protecting your privacy is very important to Mable. We are committed to maintaining the security of Personal Information provided to Mable by individuals and organisations who use this Site, including by registering themselves or another person to become a Member.
- “Account” means your membership account with Mable;
- “Corporations Act” means the Corporations Act 2001 (Cth), as amended from time to time;
- “Members” means Users who establish an Account with Mable;
- “Privacy Act” means the Privacy Act (Cth) 1988, as amended from time to time;
- “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 Members and Visitors; and
- “Visitors” means individuals who visit and browse the Site but do not create an Account.
2.2 Unless the context provides otherwise, capitalised terms not defined in paragraph 2.1 or elsewhere in this Policy have the meanings given in our User Agreement located at mable.com.au/terms-of-use
3. Who does Mable collect Personal Information from?
3.1 We may collect Personal Information from:
- Visitors when they visit our Site; and
- Members, which includes Customers and Support Workers as well as other third parties who register as Members (including Approved Providers (or their employees), and case managers and support co-ordinators, who assist with the management and co-ordination of an individual’s Care Services).
4. User consent
By submitting Personal Information through our Site or Services (including when you register yourself or another person as a Member), you agree to the terms of this Policy on your own behalf or on behalf of the person whose information you are submitting, and you expressly consent to the collection, use and disclosure of that Personal Information in accordance with this Policy.
5. Types of data we collect
5.1 The information Mable collects about you depends on how and why you access our Site and use our Services.
5.2 We collect Personal Information and anonymous data, as described below.
- Information you provide to us
- If you are a Support Worker, when you create an Account, we will collect Personal Information from you, such as your first and last name, birth date, driver’s licence number, other information by which we can identify you or verify your identity (such as passport details), your certification to work with children or with vulnerable people, the results of any applicable screening checks, your 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 and you require Care Services yourself, when you create an Account, we will collect Personal Information from you, such as your first and last name, birth date, driver’s licence number, other information by which we can identify you or verify your identity (such as passport details), your criminal history, 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 those described in paragraphs 22.214.171.124 and 126.96.36.199 above, such as a family member, government Approved Provider or other case manager or support co-ordinator, when you create an Account, we will collect Personal Information from you, similar to the information outlined in paragraphs 188.8.131.52 and 184.108.40.206 above.
- Sensitive Information
- We may collect sensitive information (including health information) from Customers and Support Workers when they choose to provide information about themselves or someone else on whose behalf they are authorised to act, and (in the case of Customers) their care requirements, through the Site.
- Other ways we may collect Personal Information
- We collect and 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 message, in order to send you a reply or otherwise action your feedback.
- When you post messages or upload content within our Site, the information contained in your posting will be stored on our servers, and other Members 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, domain name, and/or a date/time stamp for your visit.
- We may also use or enable:
- third party analytics services to track and analyse anonymous data from Users of our Site and Services; and
- location-enabled services for Support Workers as a means to facilitate time card data (location-enabled services are not currently available, but they may be available in the future).
- 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).
- Invitation emails
- Members and Visitors to our Site can invite other people to become Mable Members by requesting us to send invitation emails to them.
- 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 will only send one invitation and will not use the email address for any other communication unless the person becomes a member of Mable.
- We do not currently sell these email addresses or use them for any other purpose, but we may do so in the future.
- Where you provide someone else’s email address to us for the purposes of sending them an invitation email, you must first obtain the person’s consent and ensure they agree to receive an invitation email from us.
- Information collected from others about you
- Other Members may provide us Personal Information about you through our Site or the Services. Examples include when a Customer posts feedback regarding a Support Worker, when a Support Worker uploads notes or other information regarding a Customer to our Site, or when another Member (including a Customer’s Approved Provider or other case manager or support co-ordinator) submits health information or care plan information to our Site.
- Information collected from third parties
- 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 verifying information provided by you (eg. your police check), or companies that offer their products and/or services on our Site.
- Unsolicited Information
- Where we collect unsolicited information (being information provided to us without us having sought the information), we will only hold, use and disclose that information if we could otherwise do so had we collected it by the means described above. If that unsolicited information could not have been collected by the means described above, then we will destroy, permanently delete or de-identify the information as appropriate.
6. Use of Your Personal Information
6.1 General use
In general, we use the Personal Information we collect either to provide the Services to you, to respond to requests that you make, or to aid us in serving you better, including in the following ways:
- to facilitate the creation of, and secure, your Account on our network;
to send you a welcome e-mail and to verify ownership of the e-mail address provided when Your Account was created;
- to identify you as a User in our system;
- to prompt you to set up your profile after you have created your Account (if you do not do so at the same time as creating your Account);
- to run or verify background checks, including police, reference and other screening checks;
- to verify your credentials;
- 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 administrative e-mail notifications, such as security or support and maintenance advisories, or to inform you when our User Agreement or any of our policies (including this Policy) have been updated;
- 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.
6.2 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 may use anonymous data for any purpose and may disclose anonymous data to third parties as it sees fit.
7. Disclosure of Your Personal Information
7.1 We may disclose your Personal Information as described below and as described elsewhere in this Policy.
7.2 Disclosure to other Users
- We may share your Personal Information with third parties to whom you ask us to send (or otherwise make available) that information, including other Members. Except:
- for those Members to whom you direct us to provide access to your Personal Information (via your “Privacy Settings” or otherwise);
- and as described in this paragraph 7.2,
we do not disclose the Personal Information of any Member to any other Member. We do, however, provide other Members with the opportunity to communicate with you through an anonymous in-browser message box.
- If you are a Support Worker, we will display your photograph, your first name and the first initial of your surname, and the first few words of your profile description, in a results listing if a Visitor or a Member has searched for Support Workers in or near your suburb. However, your full profile can only be viewed by Members who have signed in to their Account, not by Visitors.
- Support Workers and Customers are described on the Site by their first name and first initial of their surname only. When a Customer and a Support Worker wish to make contact with each other for the purposes of Care Services, Mable will release Personal Information about each person to the other person (this will include each person’s full name and contact details, and may include health information and other sensitive information collected by us in accordance with this Policy).
- In addition, Approved Providers and other case managers and support co-ordinators may access the Personal Information of the individuals they assist, and of the Support Workers engaged by or for those individuals, and vice versa.
- If you are a Support Worker, we may provide a copy of your police check, working with children check, any other applicable screening checks and certifications, references, qualifications or other profile documents to Customers who engage you on Mable.
7.3 External service providers and other third parties
- We may share your Personal Information with our third party service providers to:
- provide you with the Services that we offer you through our Site;
- conduct quality assurance testing;
- facilitate creation of accounts; and
- provide technical support.
- Examples of such third party service providers include companies that administer and verify background checks, and companies that process payments from both Support Workers and Customers.
- We may also disclose your Personal Information to our external service providers and advisers who have been engaged to provide us with legal, administrative, financial, accounting, auditing, insurance, research, marketing, business consulting, technology, support or other services.
- In addition, we may disclose your Personal Information to:
- other external service providers, consultants, or business partners of ours who may work with us to improve or develop our Site and Services, operate or develop our business, conduct surveys or seek feedback from you, conduct market and other research, or facilitate or collaborate with us in relation to promotions; and
- without limiting paragraph 220.127.116.11 above, providers of consumer review websites or platforms, to enable those providers to send you an invitation to leave a review of our Services.
- If you are a Customer and you indicate that you (or an individual on whose behalf you are acting) have some form of government funding, we may share your Personal Information (or the Personal Information of the relevant individual) with third parties, including the relevant funding provider or funding manager, in order to verify the funding.
- We take reasonable steps to ensure these third party service providers, advisers, etc do not use your Personal Information other than for the purpose for which it was provided to them by Mable.
7.4 Direct Marketing
- As indicated above, Mable may use information collected from or about you for the purpose of sending you marketing and promotional information and materials.
- If you wish to opt out of receiving direct marketing communications from Mable, please use the “unsubscribe” option (in the case of e-mail communications) or contact us directly using the details below. If you wish to opt-out of receiving direct marketing communications from third party organisations to whom we have disclosed your Personal Information, you may make a separate request to that organisation.
7.5 Marketing on third party sites
We may disclose your Personal Information, such as your email address and telephone number, to the operators of other websites, social media platforms and search engines, so that we may deliver tailored advertisements to you via those websites, platforms and search engines.
7.6 Affiliates and acquisitions
- 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.
7.7 Disclosure of Personal Information to overseas entities
We may transfer or otherwise disclose your Personal Information to third parties located outside Australia, including to third parties who provide information technology and other services to us. Those third parties may be located in the United States or other countries. By providing Personal Information to us, you consent to the transfer of that Personal Information to entities located outside Australia.
7.8 Other disclosures
Regardless of any choices you make regarding your Personal Information (as described in section 9 below), Mable may disclose Personal Information to third parties 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” or “permitted health situation” (as defined in the Privacy Act) applies; and/or
where disclosure is reasonably necessary for a law enforcement related activity.
If you are a Customer requiring Care Services for yourself, you acknowledge that a Support Worker may use Personal Information about your emergency contact to get in touch with that person if necessary.
8. Data collection
8.1 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 that are tailored to your interests. This information is collected using cookies. As indicated above, you can disable cookies by changing your browser settings, but if you do, some parts of our Site may not function properly.
8.2 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, those persons or organisations will not be bound to act in accordance with this Policy. We do not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable.
9. Your choices regarding your personal data
9.1 Unless you become a Member, Mable does not collect information that identifies you personally.
9.2 Choices about marketing
- We offer you choices regarding the collection, use, and sharing of your Personal Information.
- We will periodically send you free newsletters and e-mails, SMSs or other marketing communications that directly promote the use of our Site or Services (unless you have previously requested not to receive such communications from us). As we indicated in section 7.4 above, 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).
9.3 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 your Personal Information for any purpose for which it may be used or disclosed under the Privacy Act, 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 protection or similar purposes if this is permitted pursuant to an Australian law or court order.
- If we have already disclosed some of your Personal Information to third parties, we cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.
10. Security of your Personal Information
- 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, and disclosure.
- Any information which we hold about 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 anyone who you do not wish to access your Account. We will assume all activity taking place on your Account is either being conducted by you or is authorised by you.
- Please notify us immediately if you become aware of any actual or suspected unauthorised use of your Account, or any breach of security relating to your Account.
- No method of transmission over the Internet, or method of electronic storage, is 100% secure, so while Mable uses reasonable efforts to protect your Personal Information, we cannot guarantee its absolute security.
- 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.
11. Access to your Personal Information
- You can request access to the Personal Information we hold about you by contacting us using the details below.
- We will generally allow you to access the Personal Information we hold about you if you request it, but we may refuse access if we are permitted or required by law to do so.
- We will process requests for access to Personal Information within a reasonable time, and we may charge you reasonable costs associated with providing access (for example, to cover the costs of verifying the request and retrieving the information).
- If we refuse to provide you with access to your Personal Information, we will generally provide reasons for the refusal.
12. Correction of your Personal Information
- We take reasonable steps to ensure the Personal Information we hold about you is accurate, complete and up to date.
- Please let us know if you think any of the information we hold about you is incorrect, incomplete or out of date. You may also change or update your Personal Information by logging into your Account and editing your Profile.
- If you ask us to correct your Personal Information, we will take reasonable steps to validate and correct the information, or we will provide reasons for not doing so. If we do not correct your Personal Information, you may make a statement about the requested change and we will take reasonable steps to attach this to the Personal Information in question.
- 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 the details below. You will need to provide sufficient details regarding your complaint as well as any supporting evidence and information.
- Complaints will be referred for investigation by our Privacy Officer and a 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.
- If you are not satisfied with the outcome of our investigation, you can contact us to raise your concerns, or you may wish to contact the Office of the Australian Information Commissioner (www.oaic.gov.au) by telephone on 1300 363 992, by email to email@example.com, or by post addressed to GPO Box 5218, Sydney NSW 2001.
- We may update this Policy from time to time. We will post the updated Policy on our Site, so please check regularly for any updates. The updated Policy will take effect from the date of posting.
- Your continued use of our Site or Services, or provision of further Personal Information to us after this Policy has been updated, will constitute your acceptance of the amended Policy.
15. Contact Information
- Mable welcomes your comments or questions regarding the Site, our Services, or this Policy.
- Please contact us using the following details. Email: firstname.lastname@example.org Telephone: 1300 73 65 73 Post: Level 12, 255 Pitt Street, SYDNEY NSW 2000