Uncapt Platform Privacy Policy
Effective Date: 14/03/2024

1. Introduction

Uncapt Pty Ltd (ABN: 15 641 190 552) (“we,” “us,” or “our”) is committed to protecting the privacy and personal information of all users interacting with our services, including clients, professionals, and others. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information in compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

2. Definitions

• We/Us/Our: Refers to Uncapt Pty Ltd (ABN: 15 641 190 552).
• You: The individual reading this policy, including clients, professionals, and website visitors.
• Your Information: Any personal information that you share with us or that we collect from you.

3. Scope of This Privacy Policy

This Privacy Policy applies to personal data collected through our platform from:

• Professionals (Users): Individuals or entities (e.g., healthcare providers, occupational therapists, airport managers, negotiators) who use our platform to provide services to their clients.
• Clients (End Clients): Individuals or entities who receive services from professionals and whose personal information may be entered into our platform by the professionals.
• Marketing Leads: Individuals expressing interest in our services.
• Website Visitors: Individuals visiting our website and interacting with our online content.

4. What Information We Collect

4.1 Clients

We may collect the following personal information:

• Personal Details: Name, age, contact information, or any other information relevant to the services provided by professionals.
• Contact Information: Email address, phone number, and mailing address.
• Demographic Information: Location and language preferences.
• Service-Related Information: Information related to the services being provided, which may include sensitive data depending on the sector (e.g., health information, occupational details).

4.2 Professionals

We may collect:

• Personal Details: Full name and date of birth.
• Contact Information: Email address, phone number, mailing address.
• Professional Credentials: Qualifications, certifications, licenses, registrations.
• Employment Details: Current employer, work history, areas of expertise.
• Verification Documents: Copies of professional licenses or identification documents.

4.3 Marketing Leads

We may collect:

• Personal Details: Full name.
• Contact Information: Email address, phone number.
• Company Details: Organisation name, position/title.
• Interests: Areas of interest regarding our services.

4.4 Website Visitors

We may collect:

• Technical Information: IP address, browser type, operating system.
• Usage Data: Pages visited, links clicked, time spent on pages.
• Referring Sites: Websites or search engines that referred you to us.
• Cookies and Tracking: Details outlined in Section 9.

5. How We Collect Your Information

5.1 For Professionals (Users)

We collect personal information from professionals directly when they:

• Account Registration: Create an account on our platform.
• Profile Setup: Provide information during the registration and profile completion process.
• Communication: Interact with us via email, phone, or through our platform.
• Platform Usage: Use our platform’s features and services.
• Verification Processes: Submit documents or information for identity and credential verification.

5.2 For Clients (End Clients)

We collect personal information about clients indirectly when professionals (our users) input clients’ data into our platform as part of delivering their services. Professionals are responsible for:

• Obtaining Consent: Ensuring they have the necessary consent or legal basis to provide us with their clients’ personal information.
• Data Accuracy: Providing accurate and up-to-date information about their clients.

5.3 Automated Technologies

We collect technical information automatically when professionals and website visitors interact with our services:

• Cookies and Similar Technologies: See Section 9 for details.
• Server Logs: Recording technical details such as IP addresses, browser types, and access times.

5.4 Third-Party Sources

We may receive information about professionals from:

• Verification Services: Professional associations, licensing bodies, or other entities for credential verification.
• Publicly Available Sources: Such as websites or directories.
• Referrals: Information provided by other users or partners who refer you to our services.

6. Why We Collect Your Information

6.1 For Professionals (Users)

We collect and use professionals’ personal information to:

• Provide Services: Enable access to and use of our platform and services.
• Verify Identities: Confirm your identity, qualifications, and professional credentials.
• Facilitate Client Interactions: Allow you to manage and deliver services to your clients through our platform.
• Communicate with You: Send service-related communications, updates, and support messages.
• Improve Our Services: Analyse usage to enhance the functionality and user experience of our platform.
• Legal Compliance: Comply with legal, regulatory, and contractual obligations.

6.2 For Clients (End Clients)

We process clients’ personal information to:

• Support Service Delivery: Enable professionals to provide services to their clients using our platform’s functionalities.
• Data Management: Store and process client data securely on behalf of professionals.
• Assist Professionals: Provide tools and features that help professionals manage their client relationships.
• Compliance: Fulfill legal and regulatory obligations as required.

Note: We do not use clients’ personal information for our own marketing purposes or contact clients directly unless required by law.

7. How We Use Your Information

7.1 For Professionals (Users)

We use professionals’ personal information to:

• Account Management: Create and manage your user account.
• Service Provision: Facilitate your access to platform features, including client management tools.
• Verification: Authenticate your identity and verify your professional credentials.
• Communication: Send you important information about your account, security updates, and platform changes.
• Marketing (with Consent): Send you promotional materials and updates about our services.
• Analytics: Conduct analysis to improve our services and user experience.
• Legal Purposes: Enforce our terms of service and comply with legal obligations.

7.2 For Clients (End Clients)

We process clients’ personal information as instructed by the professionals to:

• Enable Services: Allow professionals to provide effective services to their clients.
• Support Functions: Provide platform functionalities that assist in service delivery (e.g., scheduling, record-keeping).
• Data Processing: Store, process, and handle client data securely on behalf of professionals.
• Compliance: Comply with legal requirements, such as data retention laws.

Data Protection: We handle clients’ information with the same level of security and confidentiality as we do for professionals.

8. Sensitive Information Handling

8.1 For Professionals (Users)

Any sensitive information you provide (e.g., identity documents, professional licenses) is:

• Used Solely for Verification: To confirm your identity and credentials.
• Stored Securely: Protected using robust security measures.
• Access Limited: Accessible only to authorised personnel who require it for specific purposes.

8.2 For Clients (End Clients)

We understand that professionals may input sensitive information about their clients into our platform. We handle this data with the utmost care:

• Restricted Use: We use clients’ data only to provide services as instructed by the professionals.
• Security Measures: Implement advanced security protocols to protect sensitive data from unauthorised access, alteration, disclosure, or destruction.
• No AI Training: Clients’ data is not used to train, develop, or improve our AI models without explicit consent.

De-identification: When possible and appropriate, we de-identify or aggregate client data to prevent re-identification and protect privacy.

9. Cookies and Tracking Technologies

Our website and platform use cookies and similar tracking technologies to enhance user experience and analyse usage patterns.

9.1 Types of Cookies

• Essential Cookies: Necessary for the operation of our platform.
• Performance Cookies: Collect information about how professionals and visitors use our website.
• Functionality Cookies: Remember your preferences and settings.
• Targeting Cookies: Used for marketing purposes (not applicable to clients’ data).

9.2 Managing Cookies

• Control Options: You can manage your cookie preferences through your browser settings.
• Impact on Services: Disabling cookies may affect the functionality and performance of our platform.

10. How We Protect Your Information

We are committed to safeguarding the personal information of both professionals and clients.

• Encryption: All data is encrypted in transit and at rest using industry-standard protocols.
• Secure Servers: Data is stored on servers with robust physical and digital security controls.
• Access Controls: Access to personal information is restricted to authorised personnel only.
• Regular Audits: We conduct regular security assessments and updates to prevent unauthorised access.
• Policies and Training: Staff are trained on data privacy and security best practices.

11. Sharing of Personal Information

We may share professionals’ personal information with:

• Service Providers: Third-party vendors who assist in operating our platform (e.g., hosting services, payment processors), under strict confidentiality agreements.
• Regulatory Bodies: When required by law, regulation, or legal process.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, professionals’ information may be transferred, subject to the same privacy obligations.

11.2 For Clients (End Clients)

We do not share clients’ personal information with third parties, except:

• Service Provision: As necessary to provide services to professionals, using trusted service providers under our control and instructions.
• Legal Obligations: When required by law or in response to valid legal processes.
• Protection of Rights: To protect the rights, property, or safety of our company, our users, or others.

Professionals’ Responsibility: Professionals must ensure they have appropriate consent or legal basis to share clients’ personal information with us and for us to process it.

12. Cross-Border Data Transfers

Your personal information is stored in the applicable jurisdictions. We have localised deployment of our platform for Australia and the US. In some circumstances our cloud service provider might have servers that may be located internationally. This is limited to the process of data and not the storing of data. We ensure that data processing agreements are entered into to meet all the data protection standards and legal requirements, safeguarding your personal information from unauthorised use or disclosure.

12.1 Safeguards Ensured

• Adequate Protection: We ensure that any data transferred internationally is protected by laws or agreements that provide adequate data protection.
• Data Processing Agreements: Implement contracts with third-party service providers to ensure compliance with privacy standards.
• Transparency: Professionals are informed about cross-border data transfers, and consent is obtained as required by law.

12.2 Professionals’ Obligations

Professionals should inform their clients about the potential for cross-border data transfers and obtain necessary consents.

13. Your Rights and Choices

13.1 For Professionals (Users)

Professionals have the right to:

• Access: Request a copy of the personal information we hold about you.
• Correction: Request corrections to inaccurate or outdated personal information.
• Deletion: Request deletion of your personal information where legally permissible.
• Objection: Object to processing of your personal information for certain purposes.
• Consent Withdrawal: Withdraw consent where processing is based on consent (e.g., marketing communications).

To exercise these rights, please contact us using the details in Section 19.

13.2 For Clients (End Clients)

Clients’ rights regarding their personal information are primarily exercised through the professionals who are data controllers.

• Professionals’ Responsibility: Professionals are responsible for handling requests from their clients regarding access, correction, deletion, or other rights.
• Our Support: We will assist professionals in fulfilling their obligations to respond to clients’ rights requests, as required by law.

14. Data Retention

We retain personal information only as long as necessary for the purposes outlined in this Privacy Policy.

14.1 For Professionals (Users)

• Duration of Relationship: We retain your personal information for as long as you have an active account with us.
• Legal Obligations: We may retain certain data to comply with legal obligations, resolve disputes, or enforce our agreements.
• Data Deletion: Upon request or after 12 months of the date your account is deemed inactive, we will delete or anonymise your personal information.

14.2 For Clients (End Clients)

• Professionals’ Instructions: We retain clients’ personal information as directed by the professionals and in accordance with applicable laws.
• Service Termination: Upon termination of services or upon professionals’ request, we will delete or return clients’ personal information, unless we are required to retain it by law.

15. Marketing Communications

15.1 For Professionals (Users)

• Opt-In Basis: We may send you marketing communications if you have opted in.
• Opt-Out Options: You can unsubscribe at any time via the link in emails or by contacting us.
• No Impact on Services: Opting out will not affect your access to our platform.

15.2 For Clients (End Clients)

• No Direct Marketing: We do not send marketing communications directly to clients unless required by law or if they have directly engaged with us and consented.

16. Third-Party Websites

Our platform may contain links to external websites or services. Please note:

• No Control: We are not responsible for the privacy practices of those websites.
• Recommendation: We encourage you (and professionals should encourage their clients) to review the privacy policies of any third-party sites or services before providing personal information.

17. Children’s Privacy

17.1 For Clients (End Clients)

• Minors’ Data: Professionals may input information about clients under the age of 18.
• Parental Consent: It is the responsibility of professionals to obtain verifiable parental or guardian consent before collecting and providing us with minors’ personal information.

18. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal obligations.

• Notification: Significant changes will be posted on our website with the updated effective date.
• Continued Use: Your continued use of our services after updates signifies acceptance of the revised Privacy Policy.

19. Contact Us

If you have questions, concerns, or requests regarding your personal information or this Privacy Policy, please contact us:

• Email: info@uncapt.com
• Address: Level 4, 83 Mount St, North Sydney NSW 2060 Australia