Gheorg App Privacy Policy

This Privacy Policy describes how Gheorg (ABN 27 636 090 036), the “Company”, collects, holds, uses and discloses personal information consistent with the Australian Privacy Act 1988. The Gheorg website has a similar but separate privacy policy and is not directly connected to the app.

Gheorg is committed to protecting the privacy of your personal information. An individual who provides personal information to the Company, either directly or through a business partner or service provider, has ready access to this Policy.

By providing personal information to the Company and having access to this Policy, either directly or through a business partner or service provider, an individual consents to the Company collecting, holding, using and disclosing personal information in accordance with this Policy.

What information do we collect and how do we use it?

Free trial registration

When you sign up for a free trial of Gheorg (our Platform), we collect your first and last name, email address, and your country. Once you log into your free trial account, we also collect your child's first and last name and their year of birth. Collection of these details is necessary for us to tailor our communications to you, manage your child's progress through the activities, and ensure we can better respond to your customer service requests. You are entitled to provide us with a pseudonym if you wish to sign up anonymously. If you choose to sign up anonymously you will still have full access to the trial and all its features.

Subscription and product purchases

When you subscribe to our Platforms, or purchase any of our products, we collect your first and last name and your credit card details. If you are purchasing one of our products. When you subscribe or purchase a product, we do not allow the option for you to use a pseudonym as we require this information for payment and/or delivery.

Surveys

Our surveys are designed to collect your feedback so that we can improve our programs and the way we market to you. When you complete one of our surveys, we may collect your first and last name, your email address, your home address if the survey entitles you to a free gift, your child's age, as well as your opinion or other personal information relating to our survey questions. We also may ask for additional mental health information to ensure Gheorg does what children need for mental health. You are not obliged to complete any of our surveys, either as part of our free trial or subscription programs or otherwise. You are entitled to provide us with a pseudonym if you wish to complete our surveys anonymously, although if completion of our survey entitles you to a free gift, we will require your correct name and address details to deliver it to you.

Social media

We periodically run competitions through the App, Website and our social media channels. By entering into a competition, you acknowledge that we may use your personal information for the purposes of administering the competition and to contact you about our products and services.

We may also provide you with joint promotional offers in conjunction with other third parties. These offers are designed to be relevant to you, but should you not wish to receive this, you may select the 'Unsubscribe' link at the bottom of every email we send you. Alternatively, you may contact us at support@gheorg.com.

Third‑party operators

We may contract third-party service providers, vendors, APi’s or plug‑ins to assist us in better understanding our app users. These service providers, including Google, Apple, Firebase, are not permitted to use the information collected on our behalf except to help support the internal operations of our business. Contact us at support@gheorg.com or the contact details provided below for all questions and concerns about your personal data and our third‑party providers.

Email communications

All Gheorg email communications are in accordance with the Spam Act 2003. When you sign up for a free trial, you will automatically receive promotional and support emails from our Websites or Platforms. To opt out of these email communications, you can click on the 'Unsubscribe' link at the bottom of the email.

Data storage and security

Limiting access to education records

Wellness records and progress are only accessible to adults logged in to the parent portal, which also contains the child’s portal. Adult users must be logged in and have been successfully authenticated by entering a username and password. The child user is only able to access their own level progress. Children can create a 4 digit pin to protect their own work from a siblings.

Child and parent entered data can only be accessed by Gheorg staff and partners. Data is never shared with third parties without explicit permission.

Management of historical data

When a subscription to the application expires, we retain the data in our database. If a user would like this data to be deleted, they can contact our customer service team and we will be happy to oblige.

Challenging the accuracy of student or teacher data

If a parent believes there is a problem with any data that has been collected, they can contact our customer service team and we will investigate the matter. If a problem is identified, we will seek a solution to fix it.

Ensuring data is secure and protected

Parent and child entered data is stored in a secure database on Amazon Web Services (AWS). Access to these servers is limited to the application, and by software developers at Gheorg, via secure shell.

All data transferred within our Websites or Platforms is protected by SSL. SSL is a technology that makes your data illegible in transit. If anyone were to intercept communication between our servers and your computer, they would not be able to easily decipher what was being passed back and forth.

Disclosure of information for research purposes

Gheorg is devoted to improving mental health outcomes for children and a lot of research is still needed to get this right, we want to contribute to the search for better outcomes. We will allow researchers access to de-identified data only. This data will be limited to data entered in to the app and surveys, and will not contain personal information at any time. All partner researchers will commit to our privacy policy to gain access to the data.

Disclosure of information to third parties

Gheorg does not sell, trade, or otherwise transfer your personal information to third party sources.

It also does not include website hosting partners and other parties who assist us in operating our Websites or Platforms, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property or safety. 

Changes to our privacy policy

We may change, modify, or revise this Privacy Policy in order to comply with any applicable laws, to reflect changes in our processes or for any other reason at any time. Material changes in our Privacy Policy will be communicated to you, but we also encourage you to check our Privacy Policy periodically to read about any changes, modifications, or revisions. You will be deemed to have consented to any variations by your continued use of the Websites or Platforms following any changes being made.

Terms of use

Please also visit our Terms of Use section establishing the use, disclaimers, and limitations of liability governing the use of our website.

Access to and correction of personal information

Gheorg will take reasonable steps to ensure that all your personal information it holds is accurate, up-to-date and relevant. You can request access to, corrections of, or erasure of your personal information held by Gheorg, or object to the use of your personal information by us, by contacting our Data Protection and Privacy Officer at support@gheorg.com.

In addition to the above, you also have the right to delete, restrict processing or change your personal information online. To change or delete your personal information, simply log into your account and click on the 'My Account' tab, where you can remove or change your name, and email. If you wish to restrict processing or delete all your information, please contact the Data Protection and Privacy Officer.

If information or consent is not provided

Without all of the required personal information being provided or consent being given, the Company will not be able to provide the product or service an individual is seeking, and may not be able to handle enquiries or claims in connection with those products or services, such as progress reports and lesson progress.

Contact us

All requests to access, update and delete personal data as well as questions and concerns about your personal data and this Privacy Policy should be directed to the Gheorg Data Protection and Privacy Officer at support@gheorg.com. We will endeavour to respond to your query as quickly as possible.

Your consent

When an individual accesses our Websites or Platforms or opens an email on which this Privacy Policy and Notification is located or linked, the individual is directed to read it. As a result, the individual is notified of the matters that the Company must notify and consents to the collection, handling, use and disclosure of personal information by the Company in accordance with this Policy.

This Privacy Statement has been developed in accordance with the Australian Privacy Act 1988 (Cth) and the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth), the New Zealand Privacy Act 1993, the United Kingdom Data Protection Act 1998 and the United States Children’s Online Privacy Protection Act and Rule as administered by the Federal Trade Commission.

Policy last updated: 18 January 2021