This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
Interpretation and Definitions
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
- Account means a unique account created for You to access our Service or parts of our Service.
- Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- Application refers to GLAUC-STRAT Calc, the software program provided by the Company.
- Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to GLAUC-STRAT Calc.
- Country refers to: Queensland, Australia
- Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
- Personal Data is any information that relates to an identified or identifiable individual.
- Service refers to the Application.
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Date of birth and sex
- Ethnicity
- For clinicians: occupation and professional registration number
- Usage Data
Health Information
When an assessment is saved, We store the clinical details entered for it, such as visual field mean deviation, glaucoma type, risk factors and the resulting GLAUC-STRAT-FAST category. Patients can see their own assessment history in the Application. Health information is sensitive information, and We only collect it to provide the Service and, where You agree, for research.
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Information Collected while Using the Application
While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:
- Your approximate location, rounded to about one kilometre and added to an assessment only when research data collection is on
- Camera access, used only to scan patient QR codes. Images are processed on Your device and are not stored or uploaded.
Location is used for research on where assessments take place. It is not used for advertising and is not shared.
Research Data Collection
Research data collection is optional and off unless You turn it on, either when You register or later in Settings, Data Collection. When it is on, assessments are saved to the patient's record so their progress can be followed, and may be used in de-identified form for glaucoma research approved by the RANZCO Human Research Ethics Committee (reference 207.25). Research results are only reported in aggregate and never identify You. When it is off, results are worked out on Your device and are not saved. You can change this setting at any time.
You can enable or disable access to this information at any time, through Your Device settings.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
- For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
- With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
- For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
- With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
- With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
- With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
- With Your consent: We may disclose Your personal information for any other purpose with Your consent.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed and stored exclusively on our private, dedicated servers. Unlike services that rely on third-party cloud providers, your data remains under our direct control at all times.
Your data is stored on Our own servers in Australia. We do not sell Your Personal Data or share it with advertisers or other third parties.
For disaster recovery, an encrypted copy of the database is made each night and kept for 14 days. A copy of that encrypted backup is stored in Microsoft OneDrive. It is encrypted before it leaves Our server, and the keys are held only by Us, so Microsoft cannot read it.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to our data handling practices. The Company maintains strict security protocols and will never transfer Your Personal Data to any organization or jurisdiction without adequate controls in place to ensure the security of Your data.
Delete Your Personal Data
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.
Our Service may give You the ability to delete certain information about You from within the Service.
You may update Your information at any time in Settings. You can delete Your Account in the Application under Settings, Delete Account, or by emailing Us. Step-by-step instructions are on Our Delete Your Account page.
When You delete Your Account, We delete Your login and profile. Assessments You agreed to share for research are kept without anything that identifies You; otherwise they are deleted. If a clinician deletes their Account, assessments they recorded stay in their patients' histories without the clinician's identity. Deleted data drops out of Our backups within 14 days.
You may also contact Us to request access to, or correction of, any personal information that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is of paramount importance to Us. We employ industry-leading security measures to protect your information:
- Private Infrastructure: All data is stored on our own private, dedicated server in Australia, not on third-party cloud platforms. Off-site backups are encrypted before they leave the server.
- Encryption: All data transmitted between your device and our servers is encrypted using TLS. Data at rest is stored on an encrypted disk.
- Secure Authentication: We use JWT (JSON Web Tokens) with cryptographically secure keys for authentication. Passwords are hashed using bcrypt with salt, making them unreadable even to our administrators.
- Access Controls: Strict role-based access controls ensure that only authorized personnel can access system infrastructure, and all access is logged and audited.
- No Third-Party Data Sharing: Your clinical data is never shared with, sold to, or accessible by third-party services, advertisers, or external entities.
- Regular Security Audits: Our infrastructure undergoes regular security assessments to identify and address potential vulnerabilities.
While no method of transmission over the Internet or electronic storage is 100% secure, we are committed to implementing the highest standards of data protection to safeguard your Personal Data.
Children's Privacy
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, You can contact us:
By email: support@glaucstrat.com