Global Mind Screen (NZ) Limited, trading as Loffty (Loffty) delivers a mental health and wellbeing website and platform that enables people to gain insights on their mental health and wellbeing. People complete a Loffty self-assessment and immediately receive a personalised Loffty report and recommendations. They can then choose to share their Loffty report with a nominated GP or mental health specialist. Loffty also acts as a software as a service provider for mental health professionals by delivering its provider directory, decision support tool, treatment plan and patient management system through the Loffty Platform. Loffty is a self-assessment tool, it is NOT a diagnostic tool. By using the Loffty Platform, you understand the Loffty Clinical assessment does not provide a final diagnosis and that any final diagnosis remains the responsibility of your practitioner. Practitioners use Loffty to assist them to arrive at a diagnosis or they can choose not to formally diagnose but instead use the information collected through Loffty to support them in making treatment decisions. The Loffty Platform helps people get better faster and supports practitioners to help more people more quickly.
1 PURPOSE
The primary purpose of the Privacy Policy is to describe the ways in which Loffty’s employees and contractors (staff) will manage all aspects of our customers’ privacy. This document is available to all Loffty’s customers and is used by staff as the basis on which management decisions regarding privacy policy are made.
Loffty views New Zealand and Australian privacy legislation as the cornerstone of its business. Loffty staff are required to demonstrate at all times that they understand the privacy of individuals and their Personal Information and Health Information is of paramount importance.
Loffty understands that confidential information is valuable, can be highly sensitive and is protected by law. The intention of the law is to ensure that confidential information remains confidential; in essence that is, it will only be used as and when necessary to accomplish the resolution of the purpose for which it was obtained.
This Privacy Policy explains what information we collect, why we collect it, how we protect it, who we can share it with, and under what circumstances and how you can contact us if you have any questions or concerns.
2 INTRODUCTION
Global Mind Screen (NZ) Ltd trading as Loffty (we, us, our) maintains a policy of strict confidence concerning your (you, your) Personal Information and Health Information (Privacy Policy). The Privacy Policy has been developed in accordance with the New Zealand Privacy Act 1993 (the Act), The Health Information Privacy Code 2004 (NZ) and the Privacy Act 1988 (Cth) and any replacement or subordinate legislation (Privacy Law). The Privacy Policy applies to the collection, storage, protection, usage and disclosure by us of your Personal Information. Personal Information is information that can either directly or indirectly (by reference to other information we have access to) identify an individual (a natural person). Health Information includes information about the health of an individual.
This Privacy Policy applies to information provided to us whether via this Website or any other means and demonstrates how we will comply with the applicable Privacy Law in your country. In addition, where we collect and hold information about you in accordance with a contract with a third party, we will also endeavour to comply with any additional rules as advised by that contracting party.
This policy does not limit or exclude any of your rights under the Act. If you wish to seek further information on the Act, see www.privacy.org.nz. If you have any further questions or if you wish to receive more information on our information practices and Privacy Policy, please contact our Privacy Officer at kiaora@loffty.com.
By accessing this website www.Loffty.com (Website) you accept the terms of this Privacy Policy.
3 HOW WE COLLECT YOUR PERSONAL INFORMATION
To improve our customer service and allow you to make use of certain services that may be provided through the website, we may need to collect Personal Information about you. We may collect Personal Information from you in a variety of ways, including but not limited to:
• when you register via our Website to apply to be an Accredited Loffty Practitioner we collect your email address, your name, phone number, practice name, license or provider number.
• when you register as a consumer wanting to use the Loffty Clinical Platform, we collect your email address, your name, postcode, your date of birth and your gender.
• each time you use our services by logging-in to your account to use the Loffty Platform or complete a Loffty Clinical assessment 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), time spent on the Website or on the Loffty Clinical assessment application, cookies (for web), login details (for app) and the pages or screens you request.
• we collect Personal Information and Health Information that you input into the Loffty Clinical self-assessment so we are able to offer a customised Loffty Platform experience designed to help you improve your mental health and wellbeing.
• when you register for our Mental Health Summit, we collect your name, email address and physical address. You can opt-out of summit related emails anytime by clicking on the unsubscribe button provided in our emails.
• when you subscribe to our newsletter or get content from us via our website, we collect your name and email address. You can opt-out anytime by clicking on the unsubscribe button provided in our emails.
• when you contact us for technical support, we collect your email address and any information you share with us via online Tawk.to chats or telephone calls. We may also record your support call to assist us in improving our service.
• when you email us, we collect your email address and any information you provide in such email.
• when you fill in the “Book a Call” form on our website, we collect your first name, last name, email address, phone number, company name, number of employees and any additional comments you provide.
If possible, we will collect Personal Information from you directly but occasionally we will collect Personal Information about you from third parties where you have authorised this or the information is publicly available including:
• when you follow Loffty or share Loffty content on Facebook, Twitter, LinkedIn, Instagram or other social media sites, we may receive information from those social networks including your profile information, picture, User ID associated with your social media account, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services.
• when an organisation registers with Loffty to deliver its Loffty Workplace Platform, we will ask for information about the organisation that we need to know to deliver the Loffty Workplace Platform, this information will include some or all of the organisation’s employees’ email address so we can invite them to participate.
4 HOW WE USE YOUR PERSONAL INFORMATION
All Personal Information we collect, which may include Health Information, is reasonably necessary for the primary purpose of providing our services. Those purposes include:
• verifying your identity and granting you access to your personal self-assessment or practitioner secure area.
• providing our services to support End Users and mental health practitioners. Where we provide our services to Accredited Loffty Practitioners and they collect health and other information, we hold that information on their behalf pursuant to a contract. In such cases we comply with the terms of our contractual arrangements with the clients.
• recommending appropriate mental health practitioners to you based on your specific needs.
• recommending mental health resources and solution providers to you based on your specific needs
• responding to communications from you or communicating directly with you about questions or concerns you may have or other customer care related activities, including via email messages and push notifications.
• communicating information about new developments, products, services and special offers.
• providing you with technical support by sending you emails or messages, for example, relating to account verification, change or updates to features of the service, technical support and security notices). You are able to control your communication preferences.
• improving the features and functionality of the Loffty Clinical Platform including personalisation and customisation of content (product development).
• improving the quality, functionality and design of the Loffty Website.
• tracking your use of the Loffty Platform and generating statistics regarding usage of the Loffty Platform to help us better understand Loffty users and to help us
• diagnosing and preventing service or technology problems reported by our users or engineers that are associated with new browser releases or the IP addresses controlled by a specific web company or IP.
• authorising and processing payment including credit card transactions.
• conducting general mental health and wellbeing research and statistical analysis (on an anonymised basis) to advance knowledge in the field of mental health and wellbeing including getting a better understanding of the efficacy of various mental health and interventions.
• conducting mental health and wellbeing research with third-parties for the advancement of public good academic research in the fields of mental health and wellbeing and the future of work. We, and/or our third-party research collaboration partners may publish the results of the research, but when we do no Personal Information that could identify you will included.
• Generating mental health and wellbeing insights that can be acted upon in a workplace, industry or nationwide context. These actionable insights that can be used to improve the mental health of your workplace, industry or country are drawn from large amounts of aggregated and anonymised information. Your Personal Information is no longer Personal Information because you cannot be identified. Loffty will never share your Personal Information with your employer without your permission.
• letting you know about changes to our Privacy Policy and Terms of Use and other changes to the Loffty Platform.
for any other purpose authorised by you or the Act.
5 DISCLOSING YOUR PERSONAL INFORMATION
We may disclose your Personal Information to third-parties in the following circumstances:
• any business that supports our services and products, including any person that hosts or maintains any underlying IT system or data centre that we use to provide the Website and Loffty Platform. Any information shared with these parties will remain confidential unless required by law. All data we collect and which is uploaded onto the Website and Loffty Platform is stored with Amazon Web Services (AWS) Australia which means for New Zealand-based Loffty customers your Personal Information is held and processed outside New Zealand. We consider AWS to be bound to legislation similar to the Privacy Laws and we have a contractual mechanism with them to enforce your rights. The AWS hosting service fully complies with the New Zealand Ministry of Health guidelines.
• other third parties for aggregated non-personally identifiable statistical information only and the purpose of maintaining, operating, providing or improving the Loffty Platform, including by sending you non-marketing, administrative or customer service e-mail messages.
• to protect and defend our legal rights and interests, property or safety or that of third-parties, to defend any claim or to investigate, prevent, or take action regarding suspected fraud or situations involving threats to the physical safety of any person.
• As a part of a business sale. We may sell all or part of Loffty. In such a transaction, Personal Information you may have shared with us is generally one of the business assets that will be transferred.
• a person who can require us to supply your Personal Information (e.g. a regulatory authority)
• for legal purposes where a person authorised by the Act or another law (e.g. a law enforcement authority) requests information to prevent or lessen a serious threat to public health or public safety or the life or death of someone else.
• if you authorise such disclosure.
We reserve the right to notify public health authorities, law enforcement, or other persons capable of addressing the situation if we believe that such information (by itself or when coupled with information contained in any of your posts) indicates potential harm to yourself or others.
We do not disclose to any third-party any personally identifiable information (including any identifiable Health Information, emails, etc.) provided by you as a registered End User that you do not make publicly available on the Loffty Platform without your authorisation, unless required by law.
We do NOT sell, rent or trade your Personal Information with third parties for their promotional purposes.
6 HOW WE PROTECT YOUR PERSONAL INFORMATION
Maintaining your trust and privacy is extremely important to us. Below are the steps we have taken to keep your Personal Information safe from loss, unauthorised activity, or other misuse.
• Your data is yours and we do not sell any identifiable data to third parties.
• Your data is encrypted using 256-bit Advanced Encryption Standard (AES-256).
• To protect your data as it travels over the Internet, we use Transport Layer Security (HTTPS) for all communications.
• Our platform is also hosted in Amazon Web Services (AWS) data centres based in Sydney and have stringent security policies regarding access and are recommended by the New Zealand Ministry of Health.
• We ensure regular security audits will occur.
• We are a New Zealand company and we follow and abide by the New Zealand Privacy Act 1993 and the Health Information Privacy Code 1994 and the Australian Privacy Act (1988).
You are also responsible for helping protect the security of your Personal Information. Never share your login details and maintain the security on any device on which you access the Loffty Platform.
The Loffty Platform is provided under the best commercially reasonable data security practices, in order to prevent unauthorised access, disclosure, alteration, or deletion of any and all information stored in our systems. You acknowledge, however, that no such effort can completely guarantee the security of the stored data, that breaches of security are still a possibility both regarding our systems and that a data security breach resulting in unauthorised access to your information can occur in third-party systems (for example, ISP’s and hosting services providers). As a result, we do not warrant or ensure the integrity and security of the data stored in its systems, including without limitation your information.
The above security measures are designed to ensure your Personal Information is not subject to unauthorised access, loss, or misuse. If you reasonably believe that there has been unauthorised use or disclosure of your Personal Information please contact us at kiaora@loffty.com.
7 ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
Subject to certain grounds for refusal set out in the Act, you have the right to access your readily retrievable Personal Information that we hold and to request a correction to your Personal Information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the Personal Information relates.
In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the Personal Information, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the Personal Information that you requested the correction.
If you want to exercise either of the above rights, email us at kiaora@loffty.com. Your email should provide evidence of who you are and set out the details of your request (e.g. the Personal Information, or the correction, that you are requesting).
We may charge you our reasonable costs of providing to you copies of your Personal Information or correcting that information.
8 CONTROL OVER YOUR PERSONAL INFORMATION
We take all reasonable steps to ensure that your Personal Information held by us is accurate, up-to-date, complete, relevant and not misleading. If you believe that any of your Personal Information is not accurate, up-to-date, complete, relevant or is misleading, please contact us on the email below and we will take all reasonable steps to correct it within a reasonable time.
As an Accredited Loffty Practitioner you may update any Personal Information you have entered directly through your practitioner secure area including the information that displays on your Loffty Provider Profile such as your name, photo, qualifications, specialty areas, provider number, contact details, and more. End-Users can change the content of their Loffty report in consultation with their practitioner.
You can stop receiving email communications from us by clicking on the unsubscribe link provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt-out of service-related communications including account verification, transactional communications, changes/updates to features of the Loffty Platform, or technical and security notices.
If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our website or publicly displayed content you can contact us at kiaora@loffty.com.
9 HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We will retain your Personal Information:
• for as long as you remain registered as an Accredited Loffty Practitioner or End User.
• for as long as it is required in accordance with Section 4 relating to research purposes and after the research has been completed it will be retained in an anonymised form.
If we no longer need your Personal Information, or if your registration is terminated, unless we are required under the relevant Privacy Law or a court or tribunal order to retain it or it is required to resolve a dispute or prevent fraud or abuse, we will take reasonable steps to destroy or de-identify your Personal Information.
10 INTERNET USE
While we take reasonable steps to maintain secure internet connections, if you provide us with Personal Information over the internet, the provision of that information is at your own risk.
If you post your Personal Information on the Loffty Website’s online community forum or various Loffty online properties on third-party social media websites or apps such as LinkedIn, Facebook, Twitter, Instagram, etc., your information will be collected or used by these sites or apps and/or their users which 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.
If you follow links on our Website to other websites, the owners of those sites will have their own privacy policies relating to your Personal Information and you acknowledge that linked websites are not operated by us and that we are not responsible for the content or practices of the linked websites nor their privacy policies regarding the collection, storage, use and disclosure of your Personal Information. If you decide to provide Personal Information to any site linked to the Loffty Website, we suggest you review that site’s privacy policy before you provide your Personal Information.
When you visit the Loffty Website the server may attach a “cookie” to your computer’s memory. A “cookie” (an alphanumeric identifier that we transfer to your computer’s hard drive so that we can recognise your browser) helps us to store information on how you use the Loffty Website including which pages are of most interest. This information is not linked to any Personal Information that you may provide and cannot be used to identify you. We may use cookies to help provide you with personalised service, and to help make our website, applications, and services better for you. You may disable cookies by changing the settings on your browser, although this may mean that you cannot use all of the features of the website.
Currently we are using Google Analytics to analyse the audience of the website and improve our content and better understand our audience and improve the site to meet its needs. No Personal Information is collected from Google Analytics. For further information on the privacy policy concerning Google Analytics, please visit http://www.google.com/intl/en/analytics/privacyoverview.html.
11 JURISDICTION
This Privacy Policy is governed by New Zealand law and you submit to the jurisdiction of the New Zealand courts.
12 CHANGES TO THIS POLICY
Loffty’s Privacy Policy is regularly reviewed and updated as required to ensure it remains relevant to all applicable international standards, laws and legislation, Loffty’s business aims and objectives, and in the event of the introduction of new or upgraded products or technology. We may vary the terms of this Privacy Policy at any time. You should check this Privacy Policy regularly so you are aware of any variations made to this Privacy Policy. change this policy by uploading a revised policy onto the website. The change will apply from the date that we upload the revised policy and you will be deemed to have consented to such variations by your continued use of the Website following such changes being made.
This Privacy Policy was last updated on 27 October 2021.
© Global Mind Screen (NZ) Limited 2021
