PRIVACY
1. PRIVACY POLICY
This Privacy Policy was last updated on [June 2018]
SpecialT (Pty) Ltd (“us”, “we”, or “our”) takes your privacy very seriously.
This Privacy Policy explains how and why we collect personal information from you, how we use it, the conditions under which we may disclose it to others, how we keep it safe and secure and your rights in relation to your personal information in using the SpecialT App (the “App”).
Please read through it carefully and let us know if you have any questions.
This Privacy Policy forms a part of and is to be read together with the Terms of Us
1. Definition
The following terms shall have the following meanings unless indicated otherwise:
Guardians – shall include those authorised in writing to act as guardians on the App by parents in writing, such as grandparents, au pairs and even teachers, where applicable.
HPCSA – the Health Professions Council of South Africa
Parents – a child’s mother or father, or both
Personal Information – any information that could identify any individual, including: names, email address, device identity, billing information, and so on.
Practice Owners – the owners of the occupational therapy practices
Terms – these Terms of Use
Therapists – qualified occupational therapist practitioners
Users – Parents, Guardians, Therapists and Practice Owners, and referred to as “Users”, “they”, “their”, “theirs”
Each of these definitions include use of the words defined in the singular.
2. WHAT INFORMATION WE COLLECT ON THE APP
Information may be collected from Users directly, or through use of the App.
2.1 Personal Information
2.1.1 Information provided to us directly or through third parties
When Users register with us and use the App, we are provided with Personal Information. This Personal Information can be used to identify Users.
Once registered, all Users will be required to log on to the App using a third party social networking or integrated service (we call them “integrated services”), such as Google and Facebook (third parties). These integrated services will allow the third parties to authenticate the identity of Users and provide the option to share certain Personal Information with us like names and email addresses.
If Users connect to the App through Facebook or Google, the information we may access, collect and store may include the following, among other information allowed by you: your name; your profile picture; your email address; and basic profile information.
If you connect using Facebook or using your Google account, your profile photo may, depending on your privacy settings, be used by the App. Facebook status updates are never recorded and nor does any human have access to them. If you connect using your Google account, the system may access your Gmail email messages. [client to confirm] Your email text is never recorded, nor does any human have access to the emails. Profile photos are only seen by other Users.
2.1.2 Practice Owners and Therapists
In creating an account for a practice, Practice Owners will need to provide the following information for Therapists in their practice:
- full name;
- practice name;
- HPCSA number;
- phone numbers (landline and cell);
- email address;
- physical address of practice;
- website address; and
- Practice Owners may choose to provide the following optional information:
- company logo;
- background image; and
- a brief description of the practice.
Emails will be used to confirm the activation of each User’s account.
Information such as credit card, bank account details and other identity details will be collected directly from Therapists, stored and shared as necessary for the purpose of collecting payment. All payment information is stored within a secure vault.
2.1.3 Therapists, Parents and Guardians
Once registered by Practice Owners, Therapists, Parents and Guardians will be required to log on using an integrated service.
Parents are required to give written consent before Guardians may be recorded on the App.
2.2 Personal Information of children
Persons under the age of 18 are not permitted to create, access or use the App. We do not knowingly collect information from children.
Parents are required to consent to the entry of a child’s information on the App and to continued use of the App. Parents may withdraw consent at any time.
Any information about children that is collected by Practice Owners and Therapists, including name, date of birth and any other information is stored in an encrypted manner on our servers and protected from unauthorised disclosure.
Upon receipt of the relevant consent, each child’s name and surname will be entered on the App by the relevant Practice Owner. Each child will then be allocated to the relevant Therapist and may be assigned to a Parent or Guardian on the App.
Details of the child’s diagnosis, Therapist recommendations, as well as any sessions, past and future, may be recorded on the App by the Therapist. Notes may be recorded by the Therapist for each session. Therapists may assign exercises for the child to practice and videos for these can be accessed via the App by Parents and Guardians.
Parents and Guardians will have access to the notes, pictures and videos allocated specifically to them on the App. Feedback on the activities practiced at home can be provided to the Therapist via the App in the comment section within each session under the child’s profile.
We do not collect any Personal Information about children. We may collect information about children that does not identify them personally using software like Google Analytics for the purposes of research. This non-identifying information includes: the number of sessions attended and how long a child has been in therapy.
2.3 Information collected from your use of the App
Information may also be collected passively through the App. This information is mostly not personally identifying information. This is the kind of information that web browsers, servers and services like Google Analytics make available, like the browser type, language preference, time of each visit, and the number of times a button is clicked or a video is accessed. Other non-identifying information we might have access to includes how you use the App, your location, cookies, etc.
3. WHO HAS ACCESS TO PERSONAL INFORMATION
We do not sell or rent your information to third parties. We do not share your information with third parties for marketing information. However, we may share your information with third parties in order to achieve the purposes of the App, as set out in this policy.
3.1 Users
The Personal Information and the information (together referred to as “information” in this paragraph) stored on the App is confidential.
Consent must be obtained from Users before any Personal Information may be collected and stored on the App.
Parents and Guardians may only access the information that pertains to their children. The access granted to Parents and Guardians is limited to the notes entered by them, the therapy areas that have been or are being worked on and the videos recommended by the Therapist.
Each Therapist is granted access to all the information entered on the App by them. Therapists may only access information where the information was entered in relation to their treatment of a child. Any information entered by another Therapist in relation to the treatment of the same child may not be accessed by a different Therapist, unless an exception applies.
Where a Therapist makes notes in treating a child, those notes may only be accessed by that Therapist and the relevant Practice Owner.
Practice Owners have limited access to Personal Information. Practice Owners may access the list of Therapists, Parents and children in their practice. Practice Owners have access to the names and contact details of all Users in their practice. Where Practice Owners use the App in their capacity as Therapists, the rules pertaining to the access to information of Therapists will apply to them.
3.2 SpecialT
Your information is restricted. We will only access it at your written request or in the case where we need to debug and solve problems. All such access is closely monitored.
We do not sell or rent your information to third parties. Nor do we share your information with third parties for the purpose of marketing. We may, however, share your information with third parties for the purposes of achieving other purposes, including the purposes of this Privacy Policy.
Some of the functionalities of the App interoperate with and are dependent on the applications of third parties like Google and Facebook. We may collect Personal Information from these third parties to the extent that you authorise us to do so. The collection, use and disclosure of that Personal Information will be governed by this Privacy Policy. Where no other authorisations are provided, we will have access to the names and email addresses of Users.
In addition, if Users authorise us to do so, and to the extent authorisation is provided, we may grant third parties access to Personal Information. Users may control what Personal Information is shared with third parties. Any Personal Information shared by Users with third parties will be governed by the third party privacy policies and we do not assume any responsibility for the use of Personal Information by third parties once it has been shared.
The third parties providing payment services we use will collect all information necessary to complete the transaction, including Users’ names, credit card information, billing information and shipping information. Where this information is not collected by us, the third party Privacy Policy will apply.
IIf feedback is provided to us or you contact us via email, we will collect your name and email address, as well as the information contained in the email in order to provide a reply.
4. HOW AND WHY IS YOUR INFORMATION USED
We may use the information you give us (Personal Information or otherwise) for a number of different reasons, which include:
- providing you with the services asked for;
- providing you with support;
- carrying out our obligations under any contracts entered into between you and us;
- keeping a record of your relationship with us;
- conducting analysis and market research so that we can improve our services or information;
- asking you for your feedback on the services we provide;
- conducting research (where personal information is de-identified);
- notifying you of changes to our services; and
- sending you any communications requested by you (which may include marketing where you have consented).
Any research conducted is for the purposes of the improvement of the App, to determine the levels of parent-therapist engagement, and to determine the effectiveness of therapy.
5. COOKIES
Technologies like cookies are used by us and our analytics service providers (like Google Analytics) and affiliates to analyse usage trends, and administer the App.
A cookie is a piece of information that the App sends to your browser, which may then be stored on your device so that we recognise you when you return. We use cookies to collect information in order to improve the App. Cookies let us know who you are, they are necessary to access your account and will give us information that we can use to personalise the App according to your preferences.
We collect technical information such as: unique identifiers, user preferences, general usage, and volume information. We also use third-party analytical cookies for tracking web traffic and usage.
You can control the use of cookies from your browser. If you disable cookies, certain functionalities on the App or access to your account may be lost.
If you authorise us to do so, we may grant third parties access to Personal Information (depending on the authorisation given) for use in connection with third party services. You are able to control what information is shared with third parties. However, any Personal Information shared with third parties is governed by third party privacy policies and we do not assume any responsibility for use of the Personal Information shared with third parties through the App.
We will not share the Personal Information of children with third parties.
Information may be disclosed to third parties as required by law and when we believe it is necessary. You are able to adjust your settings to reflect your preferences.
6.1 Credit or debit card information
We may work with a third-party payment processor such as Payfast [client to advise who will store credit and debit card information] to manage and process payments in order to guarantee the security of information.
7. CONSENT
7.1 Submitting the Personal Information of others
Practice Owners and Therapists are responsible for informing Parents and Guardians about the App and for obtaining the necessary consent or authority from Parents and Guardians to save the Personal Information of children on our servers.
1.2 Closing your account with us
At any time and without penalty, you can withdraw consent to the continued use or disclosure of Personal Information by closing your account with us.
Your account will be closed one calendar month from the date we receive notification of cancellation in writing.
You are to ensure that the process has been completed in order for the account to be closed. This includes the receipt of a confirmation email.
1.3 Email and communications consent
You can opt-out of commercial email communications from us at any time by clicking on the unsubscribe link in emails, or by email request to us. Certain non-commercial communications may still be sent to you, such as system notifications, major product changes, changes to our Terms of Use, or other news that we believe will materially affect how you interact with us.
The only way for you to completely stop all emails from us is to close your account.
We only collect the Personal Information that is necessary to provide you with access to and use of the App. We may share Personal Information only as described in this policy.
We may use third party services to supplement or improve our understanding of you. This may mean cross-referencing information we have with the databases of third parties in order to do so.
We keep your Personal Information for no longer than is necessary for the purposes it was collected. We may be required to keep even after your account is terminated. Any information that is no longer in use will be archived until it may be deleted. The purposes and length of retention are determined by the type of data concerned, the purpose/s for which it is processed, and the applicable laws, including those of the HPCSA. Therapists are required to keep medical records until the child reaches the age of 18 years or, in certain circumstances, for life.
9.1 How do we protect information?
We use a combination of appropriate safeguards to protect your Personal Information. This includes appropriate technical and organisation controls.
All sensitive information is protected by encryption via [client to confirm- on client servers] on our servers and [client to advise – re third party payment services] by the third parties providing payment services.
All data is encrypted via SSL when transmitted from our servers to your browser and/or the App. The database backups are also encrypted.
Data is not encrypted while it is live in our database. This is because it needs to be available to you when you need it. [client to confirm this] Our database and access to the App is secured through the use of passwords, automatic logouts, automatic logging of access, data back-ups, powerful firewalls, and limiting access to only those who absolutely need it. [client to advise]
No Practice Owners or any employee of SpecialT will contact you by email or using the SpecialT messaging system asking for a User’s login details, password or any other Personal Information related or unrelated to the App or SpecialT. If any message claiming or appearing to come from SpecialT or its website is sent to you asking for such information, we request that it be reported immediately to [email protected].
9.2 User password
You are responsible for maintaining the confidentiality of your password and login details. You are fully responsible for all activities that occur under your account with or without your knowledge.
If you knowingly provide your password information and/or login credentials to another person, your privileges as a User may be suspended temporarily or terminated. You agree that you will notify us immediately in the event of any unauthorised use of your password or login credentials or any other breach of security.
At any time, you can ask us to:
- provide a copy of the Personal Information stored;
- correct any mistakes in Personal Information;
- delete Personal Information (this is subject to the requirements of the HPCSA);
- restrict the processing of Personal Information in certain circumstances.
You can object to:
- Personal Information being processed for direct marketing (at any time);
- the continued processing of Personal Information.
If Users would like to exercise any of these rights we can be contacted at [email protected].
Please note that the exercise of any of these rights may affect our ability to provide access to and use of the App. We will let Users know where this is the case. There are also circumstances where we may be required or permitted by law to continue processing Personal Information even where consent has been withdrawn.
We may update this privacy policy. If we make material changes, we will notify you by email using the email address specified in your account or by a notification on our website prior to the change becoming effective. We encourage you to make a practice of reviewing the Privacy Policy to stay up to date on our privacy practices.
