Reality Health - Privacy Policy

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**Applicability of this Privacy Policy**

Reality Health Pty Ltd (“Reality Health,” “our,” “us,” or “we”) is committed to protecting your privacy. This Privacy Policy applies to your use of Reality Health’s immersive virtual reality and web portal product (collectively, the “Product”). By using our Product, you are agreeing to permit Reality Health to process the Personal Information (as defined below) we collect from you in accordance with this Privacy Policy. Our Product includes, but are not limited to, the Reality Health Management Platform for Chronic Pain.

**THIS PRODUCT IS INTENDED FOR USE BY HEALTHCARE PROFESSIONALS
IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, DO NOT USE OUR PRODUCT.**

This Privacy Policy explains how we collect, use, share, and otherwise process Personal Information through your use of our Product. Personal Information is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. 

Please read our Privacy Policy carefully to get a clear understanding of how we collect, use, protect, or otherwise handle Personal Information we obtain through our Product.

Please note that the use of our VR platform with patients does not collect personal information. The VR platform itself collects no personal information of end users.

**What Personal Information Do We Collect?**

When you subscribe to use our Product, we may collect Personal Information and other data from you. This includes data that is automatically collected by our Product as well as data you submit to us. Specifically, we may collect, store, and use the following:
- Account information; when we register your business on our portal and create your account, you are asked to provide your name, email address, phone number, company name or other details to create that account.
- Transaction Information; when you conduct a transaction with us, you may provide information to complete the transaction, such as payment information (for example, credit card information or financial account information for another type of payment), demographic information (for example, age, date of birth, gender, or postcode). 
- Usage information; such as how often you have used the Product, your progress through the Product program (for example, which modules you use and when);
- Technical system information; such as the unique device identifier associated with your Product and device attributes;
- Your responses to any surveys we may ask you to complete to help us improve the platform and to direct our activities; and
- Your email and password when you are registered and login into the portal.

In addition, if we register you on our platform, we may collect the following information about you:
- your name;
- your email address
- your phone / mobile number
- your business name and physical address including country and postcode;
- any information you submit in response to any survey we send 

**How Do We Use Your Information?**

We may use the information we collect from you for a variety of purposes. These may include:
- to provide you with information about your use of our Product, including, but not limited to, presenting you with the collected information (for example, the number of modules you use in a specified period of time);
- to contact you or otherwise provide our support regarding your use of our Product;
- to fulfill any explicit request or consent by you to share any of the data with other individuals, such as sharing your information with another healthcare professional specifically identified by you;
- to ask for your feedback regarding our Product;
- to help us evaluate, improve, or troubleshoot our Product;
- to monitor and analyse usage and trends regarding our Product;
- to de-identify certain data and use the de-identified data for scientific analysis, research, improvement of our Product, and/or analysis or development of our business;
- to process payment, if applicable;
- to contact you regarding any product recalls or modifications;
- to detect, protect against, and address any error, fraud, wrongdoing, or illegal activity, or to enforce our legal responsibilities; and
- for any other purpose that is communicated to you or others when we collect or process any data or information.

Only Reality Health employees and our partners who need to know your data for the purposes described above will have access to your Personal Information, and we will ensure that all such individuals are subject to obligations to keep your data confidential and to use it only for the purposes described above. 

We also may confidentially use or confidentially disclose your information in the event of a corporate change in control resulting from, for example, a merger, sale of assets, or bankruptcy, solely for the purpose of effectuating any such corporate change in control, and any such use or disclosure will continue to be subject to the provisions of this Privacy Policy. 

We will not otherwise share and we will not publicise any of your Personal Information without your express written permission.

**Aggregated or De-Identified Data**

Data that is aggregated or de-identified, such that it cannot reasonably identify an individual, is not "Personal Information" and is not subject to this Privacy Policy. We are permitted to use, disclose, or share such aggregated or de-identified information for any purpose.

**Children**

The Reality Health Product is not intended for children under 13 years of age. Reality Health does not knowingly collect Personal Information or other data from children under the age of 13. Children aged 13 or older should not submit any Personal Information without the permission of their parents or guardians. 

By using the Reality Health Product, you are representing that you are at least 18, or that you are at least 13 years old and have your parents’ or legal guardian’s permission to use one of our Products and/or Services.

**Changes to Privacy Policy**

We reserve the right to update or modify this Privacy Policy at any time. Please review this Privacy Policy periodically, and especially before you provide any information. We will notify you by posting a notice on our website or sending you a notice to the email address you provided. 

Your continued use of one of the Reality Health Product following any such notification of changes will mean that you acknowledge and agree to the revised Privacy Policy.

**Changes to Your Personal Information**

We may be able to accommodate requests to change your Personal Information if you email us at the email address below. We will not be able to make changes or delete information if doing so would restrict our ability to comply with the law, enforce our policies, or protect ours or others' rights, property, or safety.

**Legal Basis for Processing Personal Information:**

Our processing of Personal Information is based on contractual necessity regarding registration for use of our platform. When you use our Product, you consent to the processing of your Personal Information in accordance with this Privacy Policy.

**Data Subject Rights:**

Under the General Data Protection Regulation (GDPR), you have certain rights regarding your Personal Information. These include the right to access, rectify, erase, restrict processing, data portability, object to processing, and not be subject to automated decision-making, including profiling. If you would like to exercise any of these rights, please contact us using the information provided within this policy.

**Data Transfer:**

Your Personal Information may be transferred to countries outside the European Economic Area (EEA) or to international organizations. By using our Product, you consent to the transfer of your Personal Information as described in this Privacy Policy. We implement appropriate safeguards to ensure the protection of your Personal Information during such transfers.

**Data Retention:**

We retain Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

**Data Controller and Data Protection Officer (DPO):**
Reality Health Pty Ltd is the data controller responsible for processing Personal Information collected through our Product. If you have any questions or concerns about our data processing practices, please contact our Data Protection Officer at [martin@reality.health].

**Complaints:**

If you believe that our processing of your Personal Information violates the GDPR, you have the right to lodge a complaint with a supervisory authority. We encourage you to first contact us with any concerns, and we will strive to address them promptly and effectively.

**A Note to Users Outside Australia**

Reality Health is based in Australia. The Product is controlled and operated by us from Australia and is not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of Australia. 
Your Personal Information may be collected, transferred to, stored, and otherwise processed in any country where we have facilities or in which we engage service providers, and, by using our Product, you consent to the transfer of information to countries outside of your country of residence which may have data protection rules that are different from those of your country.

**Contacting Us**

If you have any questions regarding this Privacy Policy, you may contact us using the information below.

Reality Health

Level 1/28 S Steyne, Manly NSW 2095

info@reality.health

Last edited May 2024

Reality Health Privacy Policy

© 2023 Reality Health

Reality Health
Level 1, 28 South Steyne
Manly
NSW 2095

Address

For more information, please contact:
Reality Health
enquire@reality.health

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