Effective Date: 1 July 2024.
This Privacy Policy applies to Thrive Child Pty Ltd and its subsidiaries, trading as Ren (referred to as “Thrive Child Pty Ltd”, “Ren,” “us,” "we," or “our”), Australian Company Number (ACN): 653 318 702.
This Privacy Policy is meant to help you understand how we collect and use information about you, and to inform you of the choices you have with respect to how we collect and use your information. This Privacy Policy also describes our data protection practices. We respect your rights to privacy and have a legal obligation to abide by the provisions of the Privacy Act 1988 (Cth) (Privacy Act). The rules that an organization must follow under the Privacy Act are known as the Australian Privacy Principles (APPs) and cover areas including the collection, use, disclosure, quality and security of personal information. This Privacy Policy should be reviewed alongside Ren’s Terms of Service.
At Ren, our mission is to provide evidence-based information and coaching to parents and caregivers, to help nurture the social and emotional wellbeing and development of children and families. To do that, we need to collect and use information from and about you (referred to within this document as “you”, “your”, “user”, “account holder”, “parent”).
Ren is committed to respecting your privacy in connection with your use of our applications and website. Ren provides services to users in various countries and is the data controller of your information. This Privacy Policy applies to all websites and mobile applications owned and operated by Ren and related online and offline services owned and operated by Ren (including our social media pages) (collectively, the “Services”).
We may modify this Policy from time to time. The date of change will be shown next to “Effective Date” at the top of this page. We encourage you to read this Policy periodically to ensure you have up-to-date knowledge of our privacy practices. Whenever material changes to this Policy are made, we will provide you with notice before the modifications are effective by sending a message to the email address associated with your account, or by posting a notice to your user account. By continuing to access or use the Services after changes to this Policy become effective, you agree to be bound by the revised Policy. If any changes are unacceptable to you, you should stop using Ren’s Services.
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.
Personal Information We Collect
We collect Personal Information when you use our Services, establish an account with us, or provide us with Personal Information. “Personal Information” is any information that directly or indirectly identifies, relates to, describes, or can be associated with a particular individual. It includes, but is not limited to, first and last names, email addresses, home or other physical addresses, phone numbers, information about your relationship status, family structure and the children in your care, and other information.
The following are examples of the types of Personal Information we may collect from you:
A. Information You Provide Us
We gather information that you provide to us when you answer screening questions, register for an account with us, use our Services, participate in surveys or promotional activities, or submit any information to us, regardless of user status.
When you create an account and/or when you use our Services (including when you speak with a Ren representative or Ren “parenting expert”), we may collect your name, email address, physical address, postal address, phone number, job title, date of birth, gender, credit card information, and other demographic and health-related information, as well as information about your the children you care for, such as their name, gender assigned at birth and date of birth, as well as your relationship to them. We may also inquire about your income or other financial information to determine whether you may qualify for reduced fees.
We may ask you to volunteer to participate in surveys, promotional activities, research, or usability studies from time to time. When a user participates, we request certain Personal Information such as name and email address. Depending on the nature of the survey or contest, we use this information to follow-up with the participants, improve our Services, or, if applicable, to notify contest winners and award prizes.
B. Communications from You
When you use our Services (for example, on our applications, website, or through partner applications and tools), complete electronic forms, or contact us through online chat, email, phone, or text, we may collect and retain specific information about you and the activity you engaged in, such as your name and contact information, information you voluntarily provide to us, the nature of your communication, the purpose of the interaction, and the action we took in response to your inquiry or request. This information may include the questions you ask and the information you provide, as well as Ren’s responses to these.
C. Information Related to Your Use of the Services
We may automatically collect information about your use of the Services, which we refer to as "Usage Data," including information transmitted by your mobile devices or computer. For example, we may collect device information, such as your hardware model, IP address, unique device identifiers, and other information such as your browser type and operating system. We may also gather website usage information concerning customer traffic patterns and website usage, including the web page you visited before accessing our website or mobile application, the pages or features of our website or mobile application you browsed, to inform us which part of our website, app, and Services you visit and how much time you spend there, and information about your preferences to make your use of the website more productive through the use of cookies.
D. Information Sent by Your Mobile Devices
We may obtain specific information that your mobile devices send when you use our Services, such as a unique identifier, user settings, the operating system of your device, and information about your use of our Services on your mobile device.
E. Location information
When you use our online Services, we may collect and store information about your general location by converting your IP address into a rough geolocation. We may also obtain access to your mobile device's GPS coordinates or course location, but only if you have agreed that we can collect this information by allowing the sharing of your location information. If you do not want us to have your location information, you agree to disable the location-sharing feature on your device or browser.
F. Information from Our Clients and Partners
We may receive your Personal Information from our business clients, business associates, vendors, and partners in connection with one or more business purposes, including making our Services available to you.
Cookies, Online Analytics, and Online Advertising
- Cookies: A "cookie" is a small file that certain websites save on your computer or smart device when you visit them. It cannot access data on your hard drive or other websites' cookie files. We utilize several types of cookies, including session cookies, which are deleted when you close your browser, and persistent cookies, which can remain even after you leave. Strictly necessary cookies allow you to use our Services and access secure areas, and cannot be disabled. Functional cookies remember your preferences, and disabling them may limit functionality. Performance or analytics cookies gather information about how you use our Services to help us improve them. Third-party cookies are provided by third-party service providers and are subject to our policies. Our cookies do not contain personal information, such as your name or credit card number.
To manage cookies, you can adjust your browser settings to receive warnings before accepting cookies or refuse them altogether. Some third-party services may also place cookies on your device, and you can block them by adjusting your browser settings. Note that disabling cookies may limit your access to certain parts or features of our website and Services. For more information on changing your browser cookie settings, please refer to your browser's instructions. - Web Beacons: Also referred to as web bugs, pixel tags or clear GIFs, are small graphical images that have a distinct identifier, and they may be present on our website to facilitate the delivery or communication of cookies. Their purpose is to track and evaluate the performance of our website and Services, as well as to monitor the number of visitors we receive, and to assess the effectiveness of our advertising. Unlike cookies that are stored on the user's device, Web Beacons are usually embedded undetectably on web pages or in emails.
- Analytics Technologies: If a user has JavaScript enabled, we utilize analytics technologies, such as Google Analytics and other providers for analytics and/or crash reporting, to track them. The Analytics feature gathers several types of data from the user, such as the web browser's type of user agent, software manufacturer and version number, operating system type, network location and IP address, geographic data, hostname, internet connection speed, time of visit, pages visited, time spent on each page of the website, referring site statistics, the website (URL) that the user used to arrive at our website, and search engine query used (for instance, typing in a phrase into a search engine and clicking on a link from that search engine). We primarily use the data collected by the analytics technology to improve the Service experience for our users. Additionally, we use this information for our own business purposes, such as analyzing the number of users we have, where visitors come from, and how they interact with us.
- Interest-Based Advertising: We may use information collected about a user’s use of our Services to arrange for advertisements about our Services to be served to the user on third party’s websites. To do so, our advertising service providers place or recognize a unique cookie on the user’s browser and use other techniques, such as pixel tags. Users may, under some circumstances, opt-out of receiving interest-based advertising. The opt-out may be provided through specific opt-out cookies. Please visit the following: YourAdChoices.com and the Networkadvertising.org to learn more.
- Mobile Applications: Depending on your permissions, we may receive your Personal Information from your internet service and mobile device providers. Users of mobile devices who do not want to receive interest-based advertising may opt-out in several ways. Learn more about your choices for mobile devices by visiting Your Ad Choices (see above). To end all targeting on a mobile device immediately, turn on “Limit Ad Tracking” in the device settings.
- Social Media: We may receive your Personal Information from your social media accounts, based on the permissions you have granted. You have the option to manage or revoke these permissions through the privacy settings of your social media account.
- Marketing tools used by Ren: Ren uses marketing tools for lead identification, lead generation and business operations, for communications in marketing campaigns and other marketing activities. To communicate with our existing or prospective business clients or users. We ensure appropriate consent and opt-outs are provided when we reach out to prospects. We perform vendor and tool security assessment and vulnerability checks before we onboard a tool. We sign required agreements along with appropriate data protection clauses with tool suppliers.
- Advertising Providers: Third party analytics and advertising companies also collect personal data through our website and apps, including identifiers and device information (such as cookie IDs, device IDs, and IP address), geolocation data, log data, and inferences based on and associated with that data, as described in our Cookie Policy. These third-parties may combine this data across multiple sites to improve analytics for their own purposes and for others. For example, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.
- Settings and Preferences: You can control the information collected by cookies and other technologies on your device by adjusting your browser settings. You can choose to receive notifications when a cookie is being set or updated, or to block cookies entirely. Some browsers also allow you to manage locally stored objects through your browser settings. However, blocking cookies may impact your use of the Service. If you want to know more about your options and not having your information used by these companies, please visit the Digital Advertising Alliance's website at https://www.aboutads.info/ or the Network Advertising Initiative's website at http://networkadvertising.org/consumer/opt_out.asp.
How We Use Your Personal Information
In accordance with this Privacy Policy, our Terms of Service, and any informed consent/clinical services documents you agree to as a condition of receiving our Services, paid or otherwise, we will use your Personal Information for the following purposes:
A. To Provide Our Services to You
We will use your Personal Information to administer our Services and provide you with the information or services you request. We may use general location information to personalize and improve our Services for you, and we may share your information with third-party service providers who are contractually obligated to protect your information.
B. For the Operations and Administration of Our Business
We will use your Personal Information to analyze trends and further our business by creating, operating, delivering, maintaining, and improving our content, design, products, and Services.
C. For Research and Development:
We may monitor how you engage with our platforms and Services for research and development purposes. We may use this information along with the questions you ask (and the context you provide in relation to these questions), as well as the responses you receive, through Ren’s communication platforms to train large language models (LLMs) to support the development of artificial intelligence (AI) and machine learning (ML). This data may be retained in perpetuity in a deidentified manner.
D. For Business Analytics Purposes:
We may analyze your Personal Information and Usage Data to inform us about the usefulness of our website, mobile applications, and other services. We may engage third parties to help us with this analysis, and they are contractually obligated to protect your information.
E. For Our Own Marketing Purposes
We may use your contact information or information about your interactions with our Services to send you marketing communications about our products and services. You may opt-out of these communications.
F. To Provide Customer Support or Respond to You
We collect information you provide to us when you contact us so we can address your needs as well as the needs of the children you report are within your care and support your use and enjoyment of our Services.
G. For Account and Network Security Purposes
We use your Personal Information to proactively manage privacy and security risks, combat spam, malware, and other malicious activities, and to monitor and verify your identity.
H. To Maintain Legal and Regulatory Compliance
We may process your Personal Information to comply with privacy laws, employment laws, healthcare laws (where applicable) or as necessary to manage risk and provide Services.
I. To Enforce Compliance with Our Terms and Agreements or Policies
We process your Personal Information to actively monitor, investigate, prevent, and mitigate any prohibited, illicit, or illegal activities on our Services, and to investigate, prevent, or mitigate violations of our terms, agreements, or policies.
To allow for additional research, product development, and insights over time, Ren may anonymize or de-identify your Personal Information information, so that such data is no longer reasonably identifiable. For users who provide consent to Ren to provide their deidentified questionnaire data to research institutions (this is done by selecting ‘opt in’ after completing a questions), we will remove information such as your name, email address and phone number, before passing on this data to an external research institute (for example, a university).
We may create statistical, aggregated data relating to our users and our Services for analytical purposes. Aggregated data includes data derived from Personal Information and obtained by Ren from other sources in aggregated and anonymous form. Aggregate Information cannot reasonably be used to identify any individual. We use Aggregate Information to understand our customer base, market our Services, improve and enhance our website, mobile application and services, and support research.
Information Sharing and Disclosure
Your Personal Information is not shared with third parties without your permission, except as described below.
A. Our Employees, Contractors and Service Providers Accessing Your Information
We may engage employees, contractors and third-party service providers to help us administer and provide our Services, or to promote them. These individuals and providers will only have access to your Personal Information for the purpose of providing services on our behalf and are strictly prohibited from disclosing or using your Personal Information for any other purpose.
B. Sharing Your Information with Business Clients
We may share your Personal Information with our business clients for the purpose of providing services and conducting business operations. Our business clients purchase our Services for their employees and dependents, and we may share your Personal Information with them as necessary to fulfill our contractual obligations, including making our Services available to you and your dependents.
C. Disclosure of Information in Business Transactions
In the event of a business transaction such as a merger, acquisition, or asset sale, or in the event we go out of business or enter bankruptcy, your Personal Information, along with our other assets, may be disclosed or transferred to a third-party acquirer. The use and disclosure of all transferred user information will be subject to this Privacy Policy, except to the extent ordered by a bankruptcy or other court. Any information collected after a transfer will be subject to the new privacy policy of the successor entity.
D. Disclosure of Information for Protection Purposes
We may cooperate with governmental or regulatory authority, judicial authority, or law enforcement officials to enforce and comply with the law, and we may disclose your information to these officials if we believe it is necessary or appropriate to do so or when we believe in good faith it is necessary for safety purposes, to prevent you or others from harm. This includes protecting the property, rights, and safety of third parties, our users, children within your care, or the general public, as well as our own property, rights, and safety. We may also disclose information to stop fraudulent, illegal, unethical, or legally actionable activity, as required by applicable local, state, or federal laws.
E. Disclosure of Information under HIPAA
We are subject to the Business Associate Agreements that we sign and we may disclose information allowable under HIPAA.
F. Court subpoena:
If information held by Ren is subpoenaed by a state or federal court of law Ren may be required to provide the subpoenaed information. Ren will endeavor to notify the Ren account holder(s) whose information is affected, unless we are restricted from doing so.
Data Security and Retention
The security of your data is very important to us, and we work hard to secure it. We employ industry standard physical, electronic, and administrative safeguards to protect the security of the information you provide us. We have implemented technical and organizational security measures to protect the security and integrity of your Personal Information in accordance with this Privacy Policy and applicable law. Such measures include restricting access to Personal Information on a “need-to-know” basis. Some of the steps we have taken to secure your data include:
Privacy by Design and Default
- We use identifiers to protect your data and identity.
- You can opt-in, rather than opt-out, to sharing your de-identified questionnaire data.
Security by Design
- SSL-encryption is used for some features of our Services to enhance the security of data transmissions.
- Random identifiers are used for data transactions between the Ren app and our servers.
- Our systems are secured with role-based access, strong passwords and two-step verification.
- We enable endpoint security in all staff systems.
- We review and maintain data processing agreements with our service providers.
- We have a strict hiring and background verification process in place.
- We require all Ren staff and contractors to agree and adhere to strict confidentiality policies.
- We provide data security training to our staff.
- We conduct annual 3rd party compliance audits and data protection certifications.
- We conduct regular checks to ensure compliance to our policies.
No method of electronic transmission or method of data storage is perfect or impenetrable. While we try our best to implement controls to protect your personal data, we cannot guarantee its absolute security. To ensure your data is secure, we require your cooperation as well.
Your account information is password-protected to ensure your privacy and security. However, we cannot guarantee the security of information transmitted over the Internet, and we encourage you to take precautions to protect your personal information, such as changing your passwords frequently, using a secure browser, and contacting us immediately if you suspect your account security has been compromised.
It is your responsibility to protect your Personal Information. We advise you to avoid posting any sensitive information on our Services that you do not want to make public, as some portions of our Services may allow users to submit comments, reviews, ratings, and other information that can be viewed by others. Any loss of privacy or harm resulting from information you post publicly is your responsibility. We will retain your Personal Information for the duration necessary to fulfill the purposes outlined in our Privacy Policy, unless a longer retention period is required and/or permitted by law. User information will be securely maintained for the greater of the minimum number of years required by state and federal law or seven years.
- Our current policy is that we may not respond to "do not track" signals or other similar mechanisms that allow you to opt out of information collection across networks of websites and online services, since there is no standard for how online services should respond to such signals. As standards evolve, we may develop policies for responding to these signals and will update this Privacy Policy accordingly.
- We are dedicated to safeguarding children's privacy in connection with the use of our Services. This section explains our practices regarding online information collection, disclosure, and consent with respect to information collected about children. Our Services include online resources that may be used to assist with a child's wellbeing. Users who provide information about a child(ren) within their Ren account and/or provide information about a child(ren) when using Ren’s Services verify that they have the legal authority to do so. Currently, individuals under the age of 18 are ineligible to register for an account. If a child or other individual accesses your Ren account, either with or without permission, we may collect information directly from the child or individual. If you prefer that a child(ren) and/or other individuals do not interact directly with Ren, please do not provide these individuals with access to your Ren account.
Other sections of this Privacy Policy contain details about the information we collect, which extend to information we collect from users about children. The information we collect will be used for the purposes described within our Privacy Policy.
No identifiable personal information about a child will be made available to the public or sold. We may share information with our service providers if necessary for them to perform business, professional, or technology services for us, always in accordance with all applicable laws. - Third-Party Site Links: Our website may include links to websites owned or operated by third parties. We cannot guarantee the privacy or security practices of these third-party websites and we are not responsible for their content. To ensure your privacy, we recommend that you review the privacy policies of these third parties before sharing any Personal Information with them.
- Social Media Use: We maintain social media accounts to post information and promote our Services. If you interact with us through social media, any Personal Information you share with us may be collected and used by us in line with the terms noted elsewhere in this Privacy Policy. However, please note that your use of social media services may result in your personal data being collected and shared by those services, over which we have no control. We encourage you to review the privacy policies and settings of the social media services with which you interact to understand how your personal information may be collected, used, and shared. Your interactions with us on social media are voluntary and at your discretion.
- International Transfer: Your Personal Information may be stored on controlled servers with limited access. We may engage an overseas service provider to provide services to us, such as cloud-based storage solutions. By providing us with your personal information, you consent to your personal information being handled and stored on servers located in Australia, USA, Canada, Asia or Europe. You acknowledge that Australian Privacy Principle 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas service provider breaches the APPs, that entity will not be bound by, and you will not be able seek redress under, the Privacy Act.
Right to access and amend information
You may contact our Privacy Officer to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. We may require you to verify your identity and specify what information you require. On the rare occasion when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to any of the personal information about you held by us.
We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusal.
We will respond to all requests for access to, or correction of, your personal information within a reasonable time.
Complaints or Requests for Additional Information
We take complaints and concerns regarding privacy seriously. If you would like further information about our privacy policies, or if you have any privacy concerns or complaints, please email us at privacy@ren.app or via post at Suite 2 / 2 Avoca Street, South Yarra VIC 3141, Australia. Ren, and/or a professional/ external agency who has been engaged to represent Ren (e.g. a lawyer/attorney), will respond within a reasonable period.
As Ren’s parent company is an Australian-registered company (Australian Company Number 653 318 702), you may also contact the Office of the Australian Information Commissioner (OAIC) regarding any complaint you have. Generally, the OAIC will require you to give them time to respond before they will investigate. For further information visit www.oaic.gov.au or call the OAIC on +61 2 9942 4099, or email the OAIC at enquiries@oaic.gov.au, or send mail to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001, Australia.
Policy Revisions
We reserve the right to change the terms of this Privacy Policy periodically, without notice. A current version of our Privacy Policy is available on our website (www.Ren.app). We encourage you to check our website periodically to make sure you are aware of our current Privacy Policy. Your continued use of our website, mobile applications and other Services following the posting of changes will mean you accept those changes in their entirety.
Questions
For questions about our privacy practices, please contact us via the contact form on our website, or by emailing privacy@ren.app.
