2. Personal Information
Personal information is any information or opinions about an identified individual or an individual who is reasonably identifiable, whether the information is true or not and whether the information is recorded in a material form or not.
Sensitive information is any personal information about racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health, genetics, biometrics or biometric templates.
We generally do not collect sensitive information of Foxo users (medical and allied health professionals and their administrative and support staff). If we do, we collect, use or disclose it only as allowed by law, for example where we have received your consent to do so or the collection is required by law.
3. What personal information do we collect from Foxo users?
We provide Foxo to (and collect personal information from):
- users who set up a free account to use Foxo (Free Users);
- employees who access Foxo through their employer’s “Enterprise” subscription (Enterprise Users); and
- individuals who access Foxo through a live link made available by an Enterprise User (Guest Users).
Free Users and Enterprise Users
When a Free User or Enterprise User signs up to use Foxo, we collect the following personal information:
- full name;
- work email;
- your position and the place where you work;
- location(s) of practice;
- (if they are a medical practitioner) AHPRA number;
- (if they are a medical practitioner) Medicare provider number;
- mobile number (if provided); and
- profile picture (if provided).
We also collect any other information provided by the user, which may include qualifications and degrees, research interests and languages spoken.
When a Guest User accesses and uses Foxo via a live link , we collect the following personal information:
- full name;
- email; and
- mobile number.
We also hold personal information submitted by Foxo users through their use of Foxo (such as patients’ personal information). We only hold this information for the purpose of providing Foxo to Foxo users and we do not use it for any other purpose.
4. How do we collect your personal information?
We collect personal information that is necessary for our business activities and in order to provide and develop our services (including Foxo). We may collect this information in a number of ways, including:
- directly from you, when you provide it to us;
- by analysing your use of Foxo;
- from other Foxo users (for example, if you are a Guest User, we may collect your personal information from an Enterprise User that sends you a live link to use Foxo); or
- from publicly available sources.
We also collect information using passive information collection technologies such as cookies as you navigate through our websites (foxo.com).
We may use and combine such passively collected anonymous information to provide better services to Foxo users and website visitors, customise our website based on your preferences, compile and analyse statistics and trends and otherwise administer and improve Foxo and the website for your use. Such information is not combined with personal information collected elsewhere through Foxo or on the websites unless you have consented.
5. Why do we collect your personal information?
If we are not provided with the personal information that we request, we may not be able to meet your request or provide our products or services to you.
The personal information you provide us may be used for a number of purposes connected with our business operations, which include to:
- verify your identity;
- provide Foxo and related products and services;
- contact you with information about our activities and to promote our products and services; and
- develop and improve the quality and scope of the products and services we provide, and seek your feedback.
Your personal information may be used so that we can provide you with information about our products and services, such as by way of email, or to request your feedback for promotional purposes. You always have the right to opt-out of receiving such information. You may exercise that right by contacting us as set out below.
We will not use your information for purposes other than those described above unless we have your consent or as permitted by law (including for law enforcement or public health and safety reasons).
6. Sharing your personal information
We will share your information through Foxo with other Foxo users.
We also may disclose your personal information to:
- others in accordance with a request made by you;
- our related companies and business partners; and
- in confidence, to persons engaged in providing us with professional, business, technology and corporate services, when reasonably required.
Unless you consent, we otherwise will not disclose your personal information to third parties.
7. Does my personal information leave Australia?
In the course of our ordinary business operations, we hold all personal information in Australia.
We will only send your personal information outside Australia:
- if we are authorised to do so by law;
- if you have consented to us doing so.
8. Access and correction
You may request access to any of the personal information we hold about you by contacting us as specified below. We reserve the right to charge a reasonable fee for the costs of retrieval and supply of any requested information.
We will take all reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up to date. To ensure your personal information is accurate, please notify us of any errors or changes to your personal information and we will take appropriate steps to update or correct such information in our possession.
9. Storage and security
We will take all reasonable precautions to safeguard your information from loss, misuse, unauthorised access, modification, disclosure or destruction. We implement a range of physical and electronic security measures to protect the personal information that we hold, including:
- restricted access to personal information;
- using industry-standard firewalls and security practices to protect personal information;
- using technology products to prevent unauthorised computer access to our network and databases; and
- internal policies in relation to the use of our computers and management of personal information.
You should keep in mind that no Internet transmission is ever completely secure or error-free.
10. Notifiable data breaches scheme
In the event of any loss or unauthorised access or disclosure of your personal information that is likely to result in serious harm to you, we will investigate and notify you and the Australian Information Commissioner, in accordance with the Privacy Act.
We take every privacy complaint seriously and will aim to resolve any such complaint in a timely and efficient manner, and our target response time is 30 days.
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a formal written complaint to the Officer of the Australian Information Commissioner (which is the regulator responsible for privacy in Australia):
Office of the Australian Information Commissioner (OAIC)
GPO Box 5218
Sydney NSW 2001
12. How to contact us
13. Links to other websites
14. Personal information of non-users
When a Foxo user submits and shares the personal information of a non-Foxo user (i.e. a patient) to or via Foxo, that information is only used by us to provide Foxo to other Foxo users.