Groov Privacy Policy

Important!

Our Programme is intended to help people and organisations understand issues relating to mental wellbeing, and to help people and organisations put strategies in place to improve wellness and daily mental wellbeing. It is for informational purposes only, it is not intended as a substitute for medical or other professional advice, and the use of our Programme does not create a doctor/patient or healthcare professional/client relationship of any kind.  Our Programme is aimed at people 18 years of age and older – it may not be suitable or optimal for minors. We make no warranties or representations about the accuracy, usefulness, or effectiveness of our Programme and we will not have any responsibility or liability for any consequences arising directly or indirectly from any action or inaction taken based on our Programme.

1. What our privacy policy covers

Groov Limited (Groov or our, us or we) takes the privacy of personal information seriously, and we comply with the Privacy Act 2020 (the NZ Privacy Act), Health Information Privacy Code (Code) and the Privacy Act 1988 (Cth) (AU Privacy Act), which incorporates the Australian Privacy Principles (APPs). If you wish to seek further information on the NZ Privacy Act or Code, see www.privacy.org.nz.

“personal information” means any information relating to a particular individual that can identify that person, either directly or indirectly (i.e. by reference to other information we have access to).

“health information” includes information or an opinion about the health of an individual that is also personal information.

“Programme” means the operation of the Groov website, mobile app and other Groov offerings to facilitate the sharing of wellbeing resources.

Our privacy policy tells you what personal information we collect, why we collect it, the steps we take to protect it, the circumstances in which we may share it, and how you can contact us if you have any questions or concerns.

2. Information we collect and hold

The personal information we may collect and hold about you depends on the nature of your interaction with us.

(a) Personal information you provide to us:

• We collect your email address and may collect your name (this is voluntary) when you create an account and log-in to your account or when you subscribe to our newsletter on our website.  

• Each time you log-in to your account to use the Programme we collect your email address and password.

• When you subscribe to our newsletter via our website, we collect your email address. You can opt out anytime by clicking on the unsubscribe button provided in the email.

• When you email us, we collect your email address and any information you provide in such email.

• When you fill in the “find out more” form on our website, we collect your first name, last name, email address, phone number, company name, job title, and any additional information you provide.

• When you respond to Groov surveys, we may collect your name, email address and any personal information you volunteer to us through your survey response (e.g. gender or ethnicity).

• When you contact us for technical support, we collect your email address (if provided) and information you share with us via online chats or telephone calls. We may also record your support call to assist us in improving our service.

• We collect personal information that you input into the Programme. As you are able to provide details about your mental wellbeing (e.g. using the mood tracker, worry map tools or in conversation with a digital human), the personal information you provide to us may include sensitive information such as health information. You do not have to provide us with such health information in order to use the Programme or access content we provide via the Programme, but if you do provide the information you will get a more customised experience and potentially, more benefit from the Programme.

(b) Technical information we may automatically collect:

Each time you use the Programme we automatically collect information on our server logs from your browser or device app, including your IP address or unique device identifier, geolocation, browser type, browser language, information about your device type, operating systems and type of operating system (e.g. iOS or Android), cookies (for web), userID (for app) and the pages or screens you request. App data can also include time spent in a session on the app or particular feature in the app.

(c) Organisation information

When an organisation signs-up with us to provide the Programme to its staff, we will ask for information about the organisation that we need to provide those services, this information may include contact details of the organisation representative and billing information.  The organisation may also provide us with some or all of their personnel’s email addresses, for us to send welcome emails inviting participation in the Programme.

3. How and why we use your personal information

(a) We collect, hold, use and disclose personal information you provide to us (which may include sensitive information such as health information) for the following primary purposes:

• You have come to the Programme to find information on improving your mental wellbeing. From time to time we will send you information on this.

• To identify you and grant you access to your account.

• To provide you with the Programme.

• To provide you with customised information and content.

• To let you know about our policies and terms and changes to the Programme.

• To provide you with technical support.

• To respond to your questions or concerns and other customer care related activities.

(b) We use technical information we collect about you (as described above) to:

• To facilitate the provision of the Programme.

•  To enable us to diagnose and prevent service or technology problems reported by our users or engineers that are associated with the IP addresses controlled by a specific web company or ISP.

•  To help us determine which users have access privileges to certain content, services or resources that we offer.

•  To monitor and prevent fraud and abuse.

(c) We use location information (geo-location and IP address) to estimate the total number of users using the Programme from specific geographical regions to enable use to us improve the Programme.

4. Aggregated and de-identified information 

We may also use aggregated or otherwise de-identified information for the purposes of research and to develop the Programme.

Aggregated information (such as statistical information) or de-identified information is derived from your personal information, but once the information is aggregated or de-identified is it no longer “personal information” as you cannot be identified.

We may share aggregated or de-identified information with our research partners for the purpose of collaborating on research projects or with third parties. We may publish the results of our research, however, any personal information that could identify you will be removed or changed before publishing.

Where your employer/organisation has gifted you access to the Programme, we may use aggregated or de-identified information to report on the overall wellbeing status of the organisation to them and to provide statistical information such as email open rates, registration rates, average user session length, etc. We do not share your personal information with your employer.

You may be able to deal with us without identifying yourself (i.e. anonymously or by using a pseudonym) in certain circumstances, such as when you make a general enquiry about the Programme or use the website. If you wish to remain anonymous in your dealings with us, please contact us to find out if this is practicable in your circumstances.

5. How we may share your personal information 

We do NOT sell, rent or trade your personal information with third parties for their promotional purposes.

We may share your personal information with third parties in the following circumstances:

• Risk to public health or public safety or an individual’s life or health. We may disclose your personal information where we consider that disclosure is necessary to prevent or lessen a serious threat to public health or public safety or your life or health or that of another individual.

• Third-party service providers. To businesses that support our Programme, including any person that hosts or maintains any underlying IT system or data centre that we use to provide the Programme, and any person we engage to help provide user support. Our business operates in Australia and New Zealand but a business that supports our Programme may be located outside New Zealand or Australia. This may mean your personal information is held and processed outside New Zealand or Australia (and also transferred between Australia and New Zealand). Groov surveys are managed by Survey Monkey, which stores survey responses and email addresses in Europe. Survey Monkey may share your personal information with employees or service providers in the United States or other countries. You can find Survey Monkey’s Privacy Notice here.

• Legal purposes. Where it is legally required by a third party, government agency or law enforcement authority in any jurisdiction (in which case we will generally require a production order or similar court order unless necessary to prevent or lessen a serious threat to public health or public safety or the life or health of someone else).

• To enforce our rights and prevent fraud. To protect and defend our rights, property or safety or that of third-parties, to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person. 

• Related companies and business sale. We may share your personal information with related companies. As we continue to develop our business, we may also sell all or part of our business. In such transactions, personally identifiable information you have shared with us is generally one of the business assets that will be transferred.

Where your employer/organisation has gifted you access to the Programme, we may report certain statistical information to your employer/organisation, such as email open rates, registration rates, average user session length, etc. We do not share your personal information with your employer.

We may also disclose your personal information with your consent.

6. Communications with you

You may opt out of communications you receive from us by emailing unsubscribe@groov.com.

7. Links to other sites 

Our Programme may include links to other sites and resources. However, it does not mean that we think that you must visit the other sites or use those resources. If you decide to provide personal information to any of those sites or the providers of those resources, what they do with your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

8. Social media websites

Please be aware that if you share any of your personal information on a third party social media website or app (e.g. Facebook, Twitter, Instagram), your personal information may be collected or used by the third-party website or app and/or the users of these sites, and could result in you receiving unsolicited messages. We encourage you to review the privacy policies and settings of the social media websites and apps you interact with.

9. How long do we keep your personal information for? 

We will retain your personal information:

• for as long as you have an account; or

• for so long as it is needed to be able to provide the Programme,

and in any event for no longer than is required for the purposes for which the information may lawfully be used.

If your account is terminated we will delete your personal information, unless it is necessary or required to meet legal or regulatory requirements, resolve disputes, or to prevent fraud or abuse.

10. Security

The security of your personal information is important to us. We use physical, electronic, and procedural safeguards to protect your personal information.

No data transmissions over the internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your transmission, we make efforts to ensure security on our systems.

In certain areas, we use industry-standard encryption to protect data transmissions. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.

You are also responsible for helping to protect the security of your personal information. For instance, never give out your password, and safeguard your user name and password when you are using the Programme. You are responsible for maintaining the security of any device on which you access the Programme.

11. Access to and correction of your personal information and complaints

You can access or correct any personal information you have entered directly through the app yourself, or otherwise, you can contact us at the addresses set out below to access and seek corrections to any of the personal information that we hold about you. Users of the mobile app can also use the ‘Your Data’ feature in the ‘Account’ tab of the app to access and erase their personal information.

If you want to complain about an interference with your privacy, we encourage you to lodge the complaint with us in writing (using the contact details set out below). We will respond to the complaint within a reasonable time and within any applicable timing requirements prescribed by law, to try and work with you to resolve the issue.

12. Changes to our privacy policy 

We may revise, modify or update this policy. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account or by placing a prominent notice on our site or app prior to the change becoming effective.

13. Contacting us

If you have any queries about our privacy policy, please email us at admin@groovnow.com or write to us at Groov Limited, C/o Lowndes Jordan, PO Box 5966, Auckland 1141.

Privacy Policy effective date: 13 May 2020

Last updated: 20 October 2022