Privacy

Asklé is committed to respecting your privacy. This Privacy Policy describes our privacy practices when you use our website (www.askle.co, our “Site”), mobile application (our “App”), and related products or services (together, our “Services”).

In this Privacy Policy:

• "Askle”, "Asklé", “we”, or “us” is a reference to Slater X Pty Ltd (ACN 665 878 491) trading as Asklé.
• “you” refers to any individual about whom we collect Personal Information.

We ask that you read through this Privacy Policy before accessing or using our Services.

‍PRIVACY LAWS THAT APPLY TO OUR BUSINESS

We seek to comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) when collecting, using, disclosing, handling and accessing your Personal Information.

We also seek to comply with all other Australian laws regulating the protection of Personal Information including the Telecommunications Act 1997 (Cth), Spam Act 2010 (Cth), Do Not Call Register Act 2006 (Cth), data retention laws and state legislation relating to health records to the extent applicable to Asklé.

PERSONAL INFORMATION

In this Privacy Policy, ‘Personal Information’ has the meaning set out in the Privacy Act. Specifically, information that relates to an identified or identifiable individual (“Personal Information”). In general terms, Personal Information is information (whether fact or opinion) about an individual who is identified or reasonably identifiable. Some types of Personal Information are designated as ‘sensitive information’, which are subject to additional protection under the Privacy Act. For example, these can include information about your political affiliation, memberships with trade associations, health records or criminal records.

PERSONAL INFORMATION WE COLLECT

When you create an Asklé account, connect to our Services, request appointments, purchase products, or otherwise interact with Asklé, we may collect the following categories of Personal Information from or about you:

• Identifiers, such as your name, home and work address, phone number, email address, username and password, policy or plan number, IP address.
• Member records, that include information related to you or your dependents’ wellness background, weight, height, lifestyle, medical history, healthcare providers, your reason for visiting a healthcare provider, date of visit, images or videos, diagnoses, treatment plans, laboratory results, payment data, insurance information, claims data, and profile or user information associated with your social media account.
• Protected class and demographic information, such as age, date of birth, sex, gender, national origin, citizenship, race, marital status, sexual orientation, medical condition, genetic information, and information about your health and/or disability status, including pregnancy information.
• Commercial information, such as information about Services purchased or obtained, Service history and tendencies.
• Device information, consisting of information from devices you use to connect to the Services, including your mobile device. The information we receive from these devices may include browsing IP address, unique device identifiers such as MAC address, usage information, crash data, device performance characteristics and hardware information, battery status, and WiFi network information.
• Internet or other electronic network activity information, such as browsing history, search history, clickstream patterns, session information, browser and operating system type, navigation paths, date/time stamps, cookie identifiers, language preferences, and other information about how you interact with our Site.
• Geolocation data, such as physical location or device location, including postcode and Global Position System (“GPS”) data.
• Professional or employment-related information, such as employer details and contact information, job title, office location, and company details.
• Biometric information, such as physiological, biological, and behavioural characterises, and genetic and health information.
• Audio, electronic, visual, or other sensory information, such as audio records, videos, images, and photographs.

Inferences drawn from the information we collect about you to create a profile about you reflecting your preferences, behaviours, and characteristics.

Some of the data we collect may be considered sensitive personal information, including your log-in name and password that you use to access your user account on the Services, precise geolocation, racial or ethnic origin, and health and genetic data.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect Personal Information from you and other sources through registration forms, eligibility files, account creation, provider/coaching visits, communications or interactions with Asklé representatives, community posts and/or comments that are collected through your voluntary public postings and engagement on social platforms. Depending on how you use our Service, we may collect Personal Information about you in the following ways:

• Directly from you. We may collect information from you directly through your use of the Services, completion of registration forms, account creation, provider/coaching visits, communications with Asklé representatives, community posts and/or comments, or other direct interactions with us, such as emails, messaging, community fora, public social media postings, or video conferencing.
• Through automated data collection technologies. We may collect your Personal Information using automated data collection technologies as described in the Cookies and Similar Technologies section below. For example, we may collect the IP (Internet protocol) address of the device you use to access our Site and other browsing information, such as page requests, browser type, operating system, and average time spent on our Site.
• From third parties. We may obtain your Personal Information through third-party sources, such as from eligibility files and claims data that we receive from your employer or your insurance company, and from family members and personal representatives who are registered with or interact with Asklé. If you are interacting with our Site as a potential business customer of Asklé, such as our “Contact Us” page, we may supplement your personal information with information we receive from marketing partners and social media companies. We may combine this information with the information we collect about you to help us tailor our communications and improve our Services.

HOW WE USE YOUR INFORMATION

We may use your Personal Information at the time of collection or otherwise as outlined below:

• Provide the Services. We may use your Personal Information to provide the Services, connect you with our service providers and coaches, refer you to clinic partners, process any fees, reimbursements, and claims, communicate with your insurer or payor to verify eligibility for our Services, provide customer services, create, and maintain business records, respond to your questions and comments, and send you communications about the Services.
• Build and maintain our relationship with you. We may use your Personal Information to improve your experience with our Services, send you marketing messages about the Services that may be of interest to you, send you educational materials, and obtain and respond to your feedback, questions, and comments. We may also draw inferences from the Personal Information we receive about you, such as information about your preferences, characteristics, and interest in our Services.
• Improve the Services. We may use your Personal Information to facilitate and improve the operation of the Services, the Site, perform market research and analysis, analyse how the Services are being used and accessed, improve the functionality of the Services and your user experience, conduct quality assurance activities, perform internal business reviews, and develop new Services.
• Maintain the Security of the Services. We may use your Personal Information to maintain the security and integrity of the Site, detect security incidents, protect the Site against fraudulent and illegal activity, and enforce our terms of use.
• For research and development purposes. We may de-identify, pseudonymise, or anonymise your Personal Information by removing data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through other means. We do this so that we can conduct research and develop our products and services.
• Comply with legal obligations and respond to legal proceedings. We may use and disclose your Personal Information to comply with our legal obligations, including maintaining records of our compliance with federal and state law requirements. We may also use your Personal Information to establish, exercise, or defend legal claims.

We may use and share aggregated and de-identified data and information derived from your Personal Information with other entities for the purpose of performing activities that may help us provide and improve our Services. Where we aggregate or de-identify data, we take reasonable steps to ensure the information is not re-identified except as required by or pursuant to applicant law.‍

We may also use your information for other purposes consistent with the context of the collection of your Personal Information, as otherwise disclosed to you at the time your Personal Information is collected, or with your consent.

CHOOSING NOT TO DISCLOSE PERSONAL INFORMATION

If you contact us to make a general enquiry about us or our business, you do not have to identify yourself or provide Personal Information. Alternatively, you can also notify us that you wish to deal with us using a pseudonym.

However, if we are not able to collect Personal Information about you, we may not be able to provide you with the information or assistance you require or provide you with our Services.  For example, we will not be able to send you information you have requested if you have not provided us with a valid email address or telephone number.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies, pixels, and similar tracking technologies as part of our Services to help us understand how you interact with our Services, to keep our Services secure, and to provide advertisements that are relevant to you. These technologies may also share data with third parties (including social media and AdTech companies) to help us track conversions, build custom audiences, and tailor our marketing campaigns. For example:‍

• Google Analytics. We use Google Analytics to track website activity, such as session duration, pages per session, and the bounce rate of individuals using the site, along with the information on the traffic source. More information available here. To opt out of Google Analytics, you may disable cookies on your browser or install the Google Analytics Opt-Out Browser Ad-On.
• Google Adwords. Google Adwords provides conversion tracking analytics with key insights into users' actions after viewing or clicking an ad. Adwords let us see which keywords, ads, ad groups, and campaigns are best at driving valuable customer activity to learn how customers may be interacting with ads on one device or browser.
• Meta Pixel. We use Meta pixel to collect data that helps our marketing teams track conversions from Meta ads, optimise ads, build targeted audiences for future ads, and build personalised remarketing strategies for users who have already taken action on our website, such as downloading a guide or visiting a page. More information available here. To opt out of Meta Ads, you can manage your Ad Choices.
• LinkedIn Insight Tag. We use the LinkedIn Insight Tag, also known as LinkedIn Pixel, to gain insights into how ads lead to practical actions on the website, including content downloads, sign- ups, purchases, and more. More information available here.

While we deploy third party cookies on our Site, we limit the use of third party tracking technologies behind authenticated webpages (including after you’ve logged into your account) and on our App.

Please note, the online advertising industry provides tools that permit you to opt out of certain interest-based advertising based on cookies. For more information about these programs and tools, you can visit www.allaboutcookies.org.

HOW WE DISCLOSE THE INFORMATION WE COLLECT

The Privacy Act and APPs also allow us to use and disclose Personal Information if required or authorised under an Australian law or a court or tribunal order, if a permitted general or health situation exists as defined in the Privacy Act or we believe the use or disclosure of the Personal Information is reasonably necessary for activities conducted by a law enforcement agency. In these instances we do not need consent to disclose Personal Information.

Generally, we may disclose your Personal Information in the following circumstances:

• Service providers. We may disclose your Personal Information with our service providers for the purposes described in Section 1 above, including organisations that provide services related to: maintaining, operating, hosting, and improving the Services; payment processing; customer service; sending emails; fulfilling orders; technical support; data analytics; and marketing and advertising. It is our policy to limit our service providers’ use of your Personal Information to that which is necessary to perform their services for us.
• Practitioners. We may disclose your Personal Information to wellness professionals and facilities offering their services via the Services (the “Practitioners”), with your consent, so that they may provide virtual consultations to you as part of the Service. In addition, when you communicate with us or submit information through the Services, we may share that information with Practitioners to enable them to communicate with you and provide the Service.
• In Connection with a Business Transaction. We may disclose your Personal Information in the event of a bankruptcy, merger, acquisition, sale of all or part of our business, or other change or ownership or control (whether in whole or in part), subject to compliance with applicable legal requirements.
• Law Enforcement. Personal Information may also be disclosed: to law enforcement, courts, and regulatory authorities in connection with a legally binding request; to detect and protect against security incidents and unlawful conduct; and/or as otherwise required or permitted by applicable law. We may also share certain deidentified, aggregated, and statistical information with clearinghouse entities, program administrators, and academic and institutional review boards.

If we disclose your Personal Information to third parties we will use reasonable commercial efforts to ensure that such third parties only use and disclose Personal Information as reasonably required for the purpose of disclosure and in a manner consistent with applicable laws, for example (where commercially practical) by including suitable privacy and confidentiality clauses in our agreement with a third party service provider to which we disclose your Personal Information.

OPTING OUT OF MARKETING AND GEOLOCATION TRACKING

If you would like to stop receiving newsletters or other marketing or promotional messages, notifications, or updates, you may do so by following the unsubscribe instructions that appear in these e-mail communications, or you may contact us to opt-out of direct marketing. Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us, including legal notices.

If you use our App, we may obtain precise information about the location of your device with your express consent. Once you have consented to the collection of the precise location of your device, you may revoke this consent by managing your location services preferences through the settings of your device.

DO-NOT-TRACK

Do-Not-Track is a public-private initiative that has developed a “flag” or signal that an Internet user may activate in the user’s browser software to notify websites that the user does not wish to be “tracked” by third parties as defined by the initiative. Please note that Asklé, like many digital service operators, does not recognise or respond to “Do Not Track” signals.

LINKS TO OTHER WEBSITES

Our Site or App may contain links or otherwise provide access to another website, mobile application, or Internet location (collectively “Third-Party Sites”). For example, when you choose to contact a medical professional in response to your request for a recommendation, you are providing information (including Personal Information) directly to third parties outside of Asklé. Please note that we have no control over and are not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Policy does not apply to Third-Party Sites. We encourage you to review the Notice of Privacy Practices of each Practitioner who provides you with services and the privacy policies of any website or application with which you interact.

HOW WE TRANSFER, STORE AND SECURE YOUR PERSONAL INFORMATION

Please note the following about how we transfer, store, and secure your Personal Information:

• Transfer of Data to Australia. When you are using the Services from outside of Australia, your information will be transferred to, stored, and/or processed in Australia. The data protection and other laws of Australia and other countries might not be as comprehensive as those in your country. If you are located outside of Australia, the transfer of Personal Information may be necessary to provide you with the requested information and Service and/or to perform any requested transaction. By using any portion of the Services, you acknowledge and consent to the transfer of your information to our facilities in Australia. Where applicable, we have implemented appropriate cross-border data transfer mechanisms when transferring your Personal Information to a country outside of your home jurisdiction.
• Security of Information. We implement and maintain reasonable technical, physical, administrative, managerial, and organisational security measures designed to safeguard your Personal Information. Please note, however, we cannot fully eliminate security risks associated with the storage and transmission of Personal Information. You also must keep your password secure and your account confidential. If you have reason to believe that the security of your account has been compromised, please notify us immediately.
• Data Retention. We store your Personal Information by electronic record keeping methods in secure databases (including trusted third-party cloud storage providers). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure. We will also retain your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the purposes for processing your Personal Information and associated legal bases; (iii) the existence of a legal obligation as to the retention period; and (iv) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations). From time to time, we take steps to destroy or de-identify information that we no longer require.

PERSONAL INFORMATION LEAVING AUSTRALIA

We store Personal Information on servers located in Australia. However, we may disclose your Personal Information to overseas recipients, such as to our Practitioners, affiliates, or agents located outside Australia, in order to provide our products and services.

PROTECTING YOUR PERSONAL INFORMATION

We will take reasonable steps to ensure that your Personal Information is protected from misuse, loss and from unauthorised access, modification or disclosure.

Our staff are trained to treat Personal Information with the utmost confidentiality. Our service providers, contractors, suppliers, affiliates or agents have contractual arrangements in place with us that require them to comply with applicable privacy laws and our policies. If a service provider, contractor, supplier, affiliate or agent is based outside Australia, our contractual arrangements also oblige them to treat Personal Information transferred to them with the same level of protection as would apply to the information in Australia.

For Personal Information that is stored in hardcopy or electronically, we have processes in place to ensure that our information systems and files are kept secure from unauthorised access and interference.

However, as the Internet is inherently insecure, we cannot guarantee the security of transmission of Personal Information you disclose to us online.  Accordingly, you transmit your Personal Information to us online at your own risk.

Please notify us immediately if you become aware of any breach of security.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

You may request access to any Personal Information we hold about you at any time. We will provide access to that information in accordance with the Privacy Act, subject to any exemptions that may apply.  You will not be charged for making a request to access your Personal Information, but you may be charged for the reasonable time and expense incurred in compiling information in response to your request. For example, if we are required to provide the information which is archived or is of significant size and it will take time to locate the information and provide it to you in an appropriate form.

We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

If you believe that Personal Information we hold about you is incorrect, incomplete or inaccurate then you may request us to amend it by contacting us. After receiving a request from you, we will take reasonable steps to correct your information.

COMPLAINING ABOUT A BREACH

If you have any questions, concerns or complaints about our collection, use, disclosure or management of your Personal Information, please contact us in writing using the contact details below.

We will make inquiries and complaints will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner.

If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and try to resolve a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.

If you are not satisfied with our response to your complaint, or you consider that Head of Customer Experience may have breached the Australian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.

LOCAL EXEMPTIONS AND INCONSISTENCY WITH LAW

Where laws allow for an exemption to compliance with certain legal obligations (for example, the employee records exemption), we may rely on such an exemption.

This Privacy Policy will not apply to the extent that it is inconsistent with any applicable law.

HOW TO CONTACT US

If you have any questions about Asklé’s Privacy Policy, would like to exercise one of your data protection rights, or would like to submit a concern or complaint, please contact us at:

Head of Customer Experience
Email: [email protected]
Telephone: 1300 1 ASKLE (27553)

CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We encourage you to review this Privacy Policy often to stay informed of how we may process your information. If we have the ability to do so (e.g., if you have an active account, or we have contact information for you), we will attempt to notify you of any material changes to our Privacy Policy that impact your Personal Information. Please note that if you object to any changes to the Privacy Policy, you may request to close your account.

This Privacy Policy was last updated in October 2024.