PRIVACY POLICY FOR MINDWAY EAP
Effective date: 11/11/2024
At Mindway Group PTY LTD, trading as Mindway EAP (ABN: 29682230075) ("Mindway EAP," "we," "us," or "our"), we prioritize your privacy and are committed to protecting your personal information. This policy explains how we collect, use, and protect your data when you use the Mindway app (“App”).
1. Key Terms

• Mobile Application: The Mindway app, designed for mobile devices (iOS, Android, etc.).
• Personal Data: Information provided by or collected about the User.
• User: Any person who downloads, activates, or uses the App.
• Copyright Holder: Mindway Group PTY LTD, trading as Mindway EAP, Australia, Victoria.
• Cookies: Small files used to enhance the functionality and performance of the App.

2. Applicability
This policy applies to all personal data collected through the App. By installing or using the App, you agree to the terms of this policy.
3. Data We Collect

• Device Data: Information like device identification and network details.
• Voluntary Data: Information you provide, such as notes, journal entries, your nickname, and the email used for signup.
• Cookies: Used to enhance user experience and manage app performance.

4. Purpose of Collecting Data
We collect and process your data to:

• Analyze app usage and improve its functionality.
• Provide technical support.
• Communicate with you regarding your account.
• Securely back up notes and journal entries.
• First-Time Client Form: Data submitted via this form is shared only with your assigned counselor and kept confidential. It will not be shared with third parties unless legally required or with your explicit consent.

5. Data Security
We implement reasonable technical and organizational measures to protect your personal data from unauthorized access, loss, or misuse.
6. Data Retention
Your personal data is retained only as long as necessary to fulfill the purposes outlined in this policy or as required by law. You may request deletion of your data by emailing support@mindwayeap.com.au.
7. EAP Services Confidentiality
We ensure that none of your personal information will be shared with your workplace, including:

• Usage data from the Mindway app.
• Emotion tracking data.
• Any personal information related to your counseling sessions.

Exceptions: We may share limited information such as:

• Name and email used for signup (for verification).
• Date of counseling sessions (for billing and statistical purposes).
• The general reason for counseling (e.g., work-related stress) but never specific personal details. This aggregated data may be shared with your employer to help identify trends without revealing personal information.

8. User Rights

• Data Access: You can request information about how your data is processed by emailing support@mindwayeap.com.au.
• Data Deletion: You can delete your account or request data removal by contacting the same email.

9. Data Storage
We store your data securely for as long as you use the App. Once you delete your account, your data will be removed within 30 days of account deletion unless required to be retained by law.
10. Minors
The App is intended for users over 18 years old. If you are under 18, you must stop using the App.
11. Policy Updates
This policy is effective from 11 November 2024 and may be updated as necessary. We recommend checking for updates to stay informed of any changes.
Disclaimer
While we employ robust security measures, no data transmission over the internet can be guaranteed to be 100% secure. You transfer data at your own risk.