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Privacy Policy

Last Updated: March 14, 2020

MAP Biotech Pty Ltd., an Australian limited company (“MAP”, “we” or “us”), knows your privacy is important to you and we are committed to providing a safe and secure user experience. This Privacy Policy is incorporated into the MAP Terms of Use and applies to your use of the MAP website (the “Website”) and use of the MAP® and MAP for Workplace™ online applications, solutions and services (collectively, the “Service”).

The purpose of this Privacy Policy is to inform you (“you” or ”your”) how we collect, use, disclose, protect and retain your personal information (as defined under applicable law) submitted through the Website or the Service. We will not knowingly use or share your personal information collected on the Website or provided through the Service except as described in this Privacy Policy. 

We encourage you to read this Privacy Policy in full to understand our privacy practices before using the Website, subscribing to a Service or submitting any personal information.

PLEASE NOTE THAT THIS PRIVACY POLICY MAY BE CHANGED FROM TIME TO TIME. We indicate at the top of the page when this privacy policy was last updated

By clicking the checkbox, you agree to be bound by this Privacy Policy and you expressly consent to us contacting you to:

  1. Provide Service and Website related notices; Communicate with you regarding updates to the Service and Website; and to respond to your inquiries, requests and applications.
  1. Provide information about other MAP products and services that we believe may be of interest to you.
  1. To conduct surveys and scientific research into the nature of well-being and deep performance. If you participate in surveys, we will request certain personal information from you. Participation in these surveys is completely voluntary and you therefore have a choice whether or not to disclose this information. We may use a third-party service provider to conduct these surveys. If we use a third-party service provider, we will notify you who the third-party survey provider is at the time. We will not share the personal information you provide through a survey with other third parties unless we give you prior notice and choice.
  1. No Disclosure to Third Parties for Their Own Marketing Purposes

MAP believes in protecting your privacy and will not provide your personal information to third parties for their marketing purposes.

  1. Data Protection Officer.

We have appointed a data protection officer who is responsible for overseeing questions in relation to this Privacy Policy. If you have questions about this Privacy Policy or the way we collect, use, process, store or share your personal information, please contact our Data Protection Officer at contact MAP Support or:

Data Protection Officer
MAP Biotech Proprietary Limited
Suite 629
41/464-480 Kent Street
Sydney NSW 2000
Australia

If you are a citizen of the European Union, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) or the supervisory authority or authorities for data protection issues in your country. We would appreciate the chance to deal with your concerns before you approach the ICO or data protection supervisory authorities, so please contact us at contact MAP Support if you have a concern.

  1. Third Party Websites, Plug-ins and Applications.

The Website or Service may include links to third-party websites, plug-ins and applications to promote an enhanced user experience. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these links, plug-ins or applications and we are not responsible for the practices employed by them and cannot accept responsibility for any use of your personal information by them. We cannot guarantee that they will adhere to the same privacy and security practices as us. If you click on those links or enable those connection, we encourage you to read their privacy policies before you submit any personal information. Your use of any such resource is at your discretion and risk.

  1. Information We Collect

MAP only collects personal information that is reasonably necessary for its activities which include operation of the Website, provision of the Service and conducting scientific research, primarily in the field of Centeredness Theory, well-being, deep performance, and self-actualization. For more information on Centeredness Theory and well-being, see https://www.frontiersin.org/articles/10.3389/fpsyg.2018.00610/full.

For a user of the MAP Service, the personal information we collect may include your name, email address, physical address (including the country from which you access MAP), password, sex, profession, marital status, and age. We collect specific data like marital status because it helps research scientists to better understand the nature of well-being. Your country is collected because we use that information for scientific research to better understand how well-being varies across the world and to anonymously populate the world map of MAP users, which you can access from your dashboard.

For organizational users of the MAP for Workplace Service, the personal information we collect includes all of the information collected for the MAP Service plus the organization’s name, address, email, and all information collected from each employee or individual added to MAP for Workplace for that organization.

We do not knowingly collect Personal Information from children under the age of 13.

MAP may, through the Website and Service, receive and store certain types of information when you interact with the Website or Service including your internet browser, IP address and operating system and MAP may also use Cookies to enable features for you on the Website and Service and to analyse and understand the traffic on the Websites and Service. You may set your browser to block cookies, but this may prevent use of some or all of the relevant portions of the Website or Service. MAP does not link information stored in Cookies to other Personal Information you may submit during use of the Website or Service.

  1. How Your Information is Used

We use the information we collect to operate and provide you with the Website and Service. This includes, but is not limited to:

  • Authenticating your login;
  • Personalizing your MAP experience;
  • Allowing you to monitor your performance and progress in MAP including, for example, presenting charts and graphs of your performance to you;
  • Debugging the Website and Service, and providing follow-up service from the MAP Support Team where the user’s session has been interrupted because of an issue in the code;
  • Customizing and delivering information about our products and services by email;
  • Providing customer service and sending confirmations about your account;
  • Protecting our intellectual property or other rights; and
  • Managing and improving our business, the Website and the Service.

It is MAP’s policy not to release your personal information or any personal information of employees in an organization (or the data of the organization to the employees) under any circumstances except as described in this Privacy Policy. If you have any questions please contact your administrator or email us at contact MAP Support.

In order for the MAP for Workplace Service to operate effectively, we keep all user personal information and user data strictly anonymous. At the same time, MAP for Workplace uses the sum total of the data of all users (with a minimum of five (5) users) in order to use aggregated, de-identified data to offer insights into human wellbeing, behaviour and performance as well as organizational wellbeing, behaviour and performance in order to better facilitate personal growth and development, the teaching and development of life skills, career counselling, and overall organizational performance. Moreover, we divide this sum total into four (4) sections called quadrants. Quadrants allow the team to be seen from four (4) different hierarchical perspectives and provide deep insight into the dynamics which shape and drive it. Quadrants can be customized and are pre-set to sales, middle management, upper management and stakeholders.

MAP aggregates individual results into collective reports which do not disclose personal information or individual results to the team or organization. A minimum of five (5) users who have completed the process are required before a report is produced. This committed focus on privacy is designed to protect all users and is necessary to establish trust across the network and thereby improve overall personal and organizational well-being. In particular, the focus on privacy helps to ensure that questions are answered honestly and that users trust MAP. For MAP to function, the organization or party responsible for paying for or sponsoring the use of the MAP for Workplace Service will have access to a de-identified aggregate or percentage of user participation by members of the organization.

We also reserve the right to use non-personal information (e.g., de-identified or aggregate) data for scientific research purposes. For example, we show aggregate performance measures to users to allow them to evaluate their performance against other MAP users of the same Service. Also, we may disclose performance statistics to university collaborators to evaluate, study, and improve the effectiveness of our programs or wellbeing more generally. In these situations, all data is disclosed either in aggregate form or in a form where information that can identify you is removed. In addition, when we work with university collaborators, we contractually prohibit them from attempting to re-identify individuals from data that has been de-identified.

  1. When we Share Your Personal Information with Third Parties

We may share your Personal Information in the following ways:

  • Service providers and agents. We may share your Personal Information with certain third parties selected by us to help support our activities and operations in order to provide you with a rich user experience. These include, for example, services that help us process payments, analyse web traffic, send emails, store date and track customer service requests. These third parties may have access to your personal information only for purposes of performing these tasks on our behalf and we will contractually require them to protect your Personal Information consistent with this Privacy Policy.
  • Business transfers. We may sell, transfer, or otherwise share some or all of our assets in connection with a merger, reorganization, business transaction, or in the event of bankruptcy. In such scenarios, your Personal Information may be one of the assets transferred. We will post a notice at the top of the page or otherwise notify you before the personal information is transferred and becomes subject to a different privacy policy.
  • Compliance with law and law enforcement requests, and protection of our rights. We may disclose your personal information when we have a good faith belief we are required to do so by law, or in response to a subpoena, court order, law enforcement request or other legal mechanism. We may also disclose your personal information when we have a good faith belief that such disclosure may prevent fraud and abuse of MAP or its users or protect our intellectual property or other rights.
  • Consent. We may disclose your personal information when we believe we have your consent to do so, such as when you contact customer service and ask us about your account, or when we have the consent of someone we believe is authorized to consent on behalf of you, such as the individual associated with the payment method for your account. If you have expressly agreed to participate in a scientific research study with us or with a third party that incorporates your personal information collected by MAP, we also may disclose your personal information for the purpose of facilitating the research to which you have consented.
  1. Accessing, Reviewing and Deleting Your Personal Information

You can access, review and correct the registration and demographic information we have collected about you by accessing your profile. You can access your profile here. You may also access or delete the personal information we have collected about you by contacting us at contact MAP Support or at the address listed in Section 1 above. While we will make reasonable efforts to accommodate your requests, if allowed by applicable law, we reserve the right to impose certain requirements and restrictions on such requests, such as limiting our production of information to certain formats. We will use commercially reasonable efforts to respond to your request within 30 days.

  1. Security of Personal Information

We have put in place appropriate security measures designed to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. Consent to Processing and Storage of Personal Information in the United States

The Website and Service are provided from the United States. If you access MAP outside of the United States, you fully understand and unambiguously consent to the transfer of your personal information to, and the collection, storage and processing of your personal information in the United States. 

All MAP online services are encrypted while data is in motion and our servers are housed in an environment that has halon fire protection, constant camera surveillance, multi-level security and secured connectivity secured and that is designed to be earthquake resistant. 

  1. Contact Information

We welcome inquiries or comments about our Privacy Policy via contact MAP Support.

  1. Data Retention.

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including without limitation, for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal information), we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, the applicable legal requirements.

By law, we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.

For legal and audit purposes, we currently keep log information.

In some circumstances you can ask us to delete your personal information. See request erasure below for further information.

  1. Your Legal Rights.

Under certain circumstances, you may have rights under data protection laws in relation to your personal data. Such rights may include:

  • Request access to your personal information. You may request a copy of the personal information we retain.
  • Request correction of your personal information. You may correct any personal information we retain about you if it is incorrect or incomplete.
  • Request erasure of your personal information. You may ask us to delete your personal information if there is no good reason for us to continue to retain it. You also may ask us to delete personal information in instances where (a) if you have successfully exercised your right to object to our processing of such personal information, (b) if we processed or are processing such personal information in violation of applicable law, or (c) if we are required to erase your personal information by law. However, we may not always be able to comply with your request due to legal or technological reasons. If this is the case, we will notify you at the time you request deletion of your personal information.
  • Object to processing of your personal information. You may object to our processing of your personal information if we are using it for marketing purposes, and, in instances where we are relying upon our or a third party’s interests to process your personal information, if you believe it impacts your fundamental rights or freedoms.
  • Request restriction of processing of your personal information. You may request that we suspend processing of your personal information if (a) you need it to defend, establish or exercise legal claims, (b) we need to verify our legitimate right to use your personal information in an instance where you have requested we stop processing it, (c) our processing of such personal information is unlawful but you do not want us to erase it, or (d) you want us to establish the personal information’s accuracy.
  • Request transfer of your personal information. If you request us to transfer personal information you provide to us in an automated information or to perform a contract with you, we will use commercially reasonable efforts to provide this information to a third party in a machine-readable format.
  • Right to withdraw consent. You have the right to withdraw your consent to our processing of your personal information if we are relying upon your consent to process such information. This will not affect any processing of such personal information before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with a product or service for which you have subscribed. If this is the case, we will notify you at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at contact MAP Support.

  1. NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

  1. WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

  1. TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. Changes to Privacy Policy.

We will notify you of changes to this Privacy Policy by posting the amended terms on our Website at least thirty (30) days before the effective date of the changes. If you have provided us with your email address, we will also notify you of material changes to this Privacy Policy by sending an email at least thirty (30) days before the effective date of the changes to the email address you most recently provided to us.We encourage you to keep the email address you provide to us current, and to promptly notify us of any changes to your email address, so that you may receive any notices we send to you regarding material changes to this Privacy Policy.