Privacy Policy
Last updated: January 2024
Nautilus Media Group Pty Ltd (ACN 164 132 781), an Australian corporation and its subsidiaries CaringLife UK Ltd and CaringLife USA LLC (hereafter referred to as CaringLife, we, us, our) is the owner, operator and licensor of the Website and the Service.
CaringLife provides an online platform to establish and maintain a Child Profile within the Service. The Service enables Authorised Account Holders to create, manage and transfer Child and Carer Profile accounts.
In the Privacy Policy, capitalised terms are defined as follows:
- Account Managers means (i) an Agency or (ii) any person authorised by an Agency to create, manage and transfer a profile on the Service.
- Agency means a local agency or authority that is charged with the management of the Child's Case Manager and/or Child depending on the relevant authority.
- Authorised Account Holders means any Agency, authority, Account Manager or case worker who may create, manage and transfer Child Profiles and/or Carer Profiles within the Service.
- Case Manager means a Child’s current case manager or social worker appointed by an Authorised Account Holder to manage and oversee the placement a Child with a Carer and review any content uploaded to a Child Profile.
- Carer means any person who is presently or has been in the past charged with the care of a Child by government mandate or authority.
- Carer Profile means a profile within the Service related to a Carer.
- Child means a person who is in foster kinship or residential care who is 18 years or younger, and Children has a corresponding meaning.
- Child Profile means a profile within the Service related to a Child, and is overseen by a Carer or Case Manager.
- Service means the CaringLife software and applications, including those available on and through the Website.
- Terms of Service means the CaringLife terms of use governing use of the Service, available at https://www.caringlife.com/terms-and-conditions.
- Website means the website located at caringlife.com.
Unless stated otherwise, this Privacy Policy applies to all users of the Service, including Children or Authorised Account Holders, whether as the holder of a CaringLife Account or otherwise (collectively, User, you, your).
CaringLife provides this Privacy Policy to help you make an informed decision about whether to use or continue using the CaringLife Website and/or the Service. If you do not agree to our practices, please do not use the Website or Service. Your continued usage of the Service will signify your acceptance of our Privacy Policy and Terms of Service.
This Privacy Policy is to be read together with the Terms of Service. Your use of the Website and the Service and any personal information you provide on the CaringLife Website or Service remains subject to the Terms of Service.
We know how important security and privacy is to you. Safeguarding security and privacy is at the heart of CaringLife and as such we strive to make things as safe and clear as possible for everyone involved.
This Privacy Policy sets out how we treat the Personal Information of those who use our Website and associated services, and others with whom we interact.
Please take a moment to read this Privacy Policy so you understand how we process Personal Information. If you have any questions or comments about this Privacy Policy and procedures, or you wish to exercise the rights you have under applicable privacy laws (which are explained further below) please contact us using the methods set out below.
Privacy Policy
- Application
In this Privacy Policy, Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.
This Privacy Policy applies to all Personal Information processed by CaringLife, including, but not limited to, Personal Information submitted by Authorised Account Holders and Users through the Service.
This Privacy Policy does not apply to the practices of companies that CaringLife does not own or control, nor to individuals whom CaringLife does not employ or manage, including any of the third parties to whom CaringLife may disclose user information as set forth in this Privacy Policy.
- Updates
From time to time we will review our Privacy Policy to keep pace with changes in our Service and any data protection and privacy laws applicable to the processing of Personal Information that we are committed to comply with, which may include:
- (a) the Privacy Act 1988 (Cth) (Australia);
- (b) the Privacy Act 1993 (New Zealand);
- (c) the Personal Information Protection and Electronic Documents Act, SC 2000, c5 (federal, Canada);
- (d) the Personal Information Protection Act (Alberta, Canada);
- (e) the Personal Information Protection Act (British Columbia, Canada);
- (f) all applicable United States federal and state privacy laws, including, but not limited to, the California Online Privacy Protection Act (CalOPPA) and Early Learning Personal Information Protection Act (ELPIPA);
- (g) the General Data Protection Regulation (EU);
- (h) the Data Protection Act 2018 (UK); and
- (i) any other applicable privacy legislation,
(collectively referred to as the Data Protection Laws).
We may update this Privacy Policy from time to time by publishing it on the Website. We encourage you to read our Privacy Policy carefully.
- Collection of Personal Information
We may collect your Personal Information if you:
- speak with us directly over the phone or via our support service;
- have contact with us in person;
- participate in public or closed surveys, questionnaires, or events;
- register for face-to-face or online events (such as webinars);
- interact with us online, via our website, email, or mobile applications;
- apply for a position with us either as an employee, volunteer or as a contractor).
The collection of your Personal Information may be required in order for you to:
- join our Website as a registered user;
- receive information from us including alerts via email or SMS communications;
- register to use our forum or digital application;
- download our online resources;
- register as a volunteer;
- access Services or resources;
- receive information about or become involved in our programs, campaigns or other initiatives; or
- work with us.
The types of Personal Information we collect about you depends on the dealings you have with us. We have set out below the types of Personal Information we collect, and the circumstances in which such Personal Information is collected.
Category of information Circumstances of collection Types of Personal Information Personal Information you voluntarily provide to us
When you give us your Personal Information directly (whether face-to-face, by telephone, email, post, through social media or by communicating with us in any way), when we meet with an organisation wishing to do business with us and an individual from that organisation provides Personal Information about themselves, or when you sign up or register to become an Authorised Account Holder, or enter into a transaction with us.
Name, email address, login for the Service, feedback and suggestions for the Service, IP address, billing information, occupation, employer, job title, organisation details, communication preferences and area of responsibilities. We may also request:
- your preferences for receiving further information about our programs, campaigns or activities;
- additional types of Personal Information such as government department name (where applicable) or demographic information.
Our email communication list
When you become an Authorised Account Holder, or have an activated Carer or Child Account, or where you elect to sign up to our email communication list.
Name, email address, and email communication preferences. This information will not be disclosed to any third party, and will only be used for our direct communication with you.
Personal Information we collect automatically
We may collect Personal Information (such as log files) and store it against the associated CaringLife Account, and link it to the other Personal Information we hold about a CaringLife Account.
IP address, time, date, and your interaction with the Service (including any Content and comments).
Personal Information uploaded and transferred to the Service by Account Holders
We collect Personal Information when an Authorised Account Holder:
- creates a Child Profile, or invites another person to become an Authorised Account Holder or User;
- uploads and transfers Content that contains Personal Information; or
- posts a comment or tags Content on the Service that contains Personal Information of another person.
Comments and tags, any Content uploaded to the Website, photographs or videos of any other person (including children), or uploads and transfers of materials created by another person (including Children).
Statistical information
We may collect statistical (non-personal) information about your use of the Website and the Service to improve the features and overall user experience.
Statistical information, such as pages accessed on the Website and the Service, search terms, links that are clicked on, Website and Service visit times, browsers and operating systems, IP address, and cookies. This information is anonymised and is not Personal Information.
Sensitive information
We may collect sensitive information where an Authorised Account Holder or Carer uploads a Child's cultural and identity support plan or other such related documents to the Service. No other form of sensitive information is permitted to be uploaded or transferred to the Service.
Information relating to a Child's racial or ethnic origin that may form part of a cultural and identity support plan.
We have no ability to access, use or view the data you upload to the Website. As such, any Authorised Account Holder is a data controller and we are a data processor in respect of such Personal Information . All Authorised Account Holders are solely responsible for ensuring the appropriate consents are obtained for us to collect and process information about any such person, including Children, in accordance with your obligations in our Terms of Service.
- Anonymous or pseudonymous use of our Services
You may choose how much information you provide to us, but we require certain information from you in order to provide particular services. Where possible, you have the option of interacting with us anonymously (for example, as a visitor of the website without having to log in) or by using a pseudonym if you feel more comfortable with this.
- Cookies and tracking
We may use various technologies to collect and store information when you use our Service, and this may include using 'cookies. A cookie a small summary file containing a unique ID number) to your computer or internet enabled device.
We may use various technologies to collect and store information when you use our Service, and this may include using 'cookies. A cookie a small summary file containing a unique ID number) to your computer or internet enabled device.
- recognise your computer or internet enabled device;
- greet you each time you visit our website;
- keep track of services you view;
- measure traffic and engagement patterns, to evaluate our website visitor’s habits; and
- identify and continually improve our services, programs, Content and resources.
You may control the use of cookies at the individual browser level; however, your use of the Website and Service may be affected.
Personal Information may be collected as log files, or through cookies or other tracking technologies, stored against associated CaringLife Accounts, and linked to the other Personal Information we hold about associated CaringLife Accounts.
- Disclosure of Personal Information
Personal Information will only be disclosed to third parties in accordance with this Privacy Policy. We will not sell Personal Information to anyone, and we will limit the information we provide to third parties to the information they need to help us provide or facilitate the provision of our Services and associated purposes.
We share Personal Information with third parties for limited purposes, such as to help us run our business and provide the Website and Service. Those third parties can be categorised as follows:
6.1 Authorised Account Holders
An Authorised Account Holder may disclose Content (which may contain Personal Information) to other Authorised Account Holders. As such,, you are responsible for making sure you have the appropriate permission for us to disclose any Content (which may contain Personal Information) in the manner you direct through the Service. Please see our Terms of Service which outline your obligations in this regard.
6.2 Third party service providers
We may share a limited amount of Personal Information with our third party service providers, who help us provide and support our Service, including organisations who carry out credit, fraud and other security checks, payment processors, hosting services, Content delivery services, IT support providers and communications businesses engaged by us to disseminate materials to which recipients have consented.
We limit the information we provide to third party service providers to the information they need to help us provide or facilitate the provision of goods and services and associated purposes. We deal with third parties that are required to meet the privacy standards required by law in handling your Personal Information, and use your Personal Information only for the purposes that we give it to them.
6.3 Sale, merger, consolidation, liquidation, reorganisation, or acquisition
If CaringLife, or its assets are acquired by a third party, Personal Information which we hold may be one of the assets transferred as part of the sale.
6.4 Legal obligation
We may share Personal Information if we are under a duty or have a legal right to disclose or share Personal Information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions or to protect our rights, property, or the safety of our personnel or third parties. This may include authorities such as the police, tax agencies or other authorities if we are required to do so by law, or under some circumstances if you have requested us to do so.
- Use of Personal Information
We collect your Personal Information for the primary purpose of providing our Services to you. We may also use your Personal Information for secondary purposes related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.
We process Personal Information for the following purposes:
- to administer CaringLife Accounts;
- to enable the features of the Services to be utilised and enjoyed, subject always to our Terms of Service. This may, for example, entail incidental posting of photographs or videos of a Child on another Child’s Profile. Those posts may remain viewable even once a Child’s Authorised Account Holder no longer uses the Service as long as the other relevant Child Profile is retained;
- to analyse user behaviour (in respect of the Website) and Authorised Account Holder behaviour (in respect of the Service) for the purposes of:
- determining Service developments;
- inviting Users or Authorised Account Holders to explore other features within the Website or Service, and otherwise to generally promote our Service;
- ensuring the security of the Website and the Service; and
- combating and preventing breaches of our Terms of Service, other user agreements, this Privacy Policy and our other policies;
- to respond to enquiries, feedback or complaints received from you;
- to perform authorised financial transactions with you and to help us to manage our CaringLife Accounts and administrative services;
- to verify your identity;
- for directly communicating with you (including by email, post, other means, or through functionality within the Service) with information about our Service;
- on an aggregated non-identifiable basis, to:
- help CaringLife understand its market position;
- assist with marketing our Service to others, including in respect of any online communications; and
- understand the quantum, jurisdictions and localities in which data has been uploaded to the Service;
- to protect our legal interests and fulfil our regulatory obligations (if and to the extent necessary);
- for ensuring the trust and safety of any Child and Users of the Service; and
- in other circumstances, provided we comply with applicable Data Protection Laws.
- Lawful Basis for processing
As an Authorised Account Holder with the status of a data controller, you acknowledge and agree that the legal basis for processing Personal Information by us will be one of the following:
- you have given (or in the case of Child, obtained the necessary) consent;
- the processing is necessary for the performance of a contract you are party to, or in order to take steps at your request prior to you entering into a contract;
- the processing is necessary in order for us to comply with our legal obligations; or
- the processing is necessary for the pursuit of our legitimate business interests, provided these do not override your rights and interests.
In respect of all other processing of Personal Information detailed in this Privacy Policy (including direct marketing activities), such processing is necessary for the purposes of a legitimate interest pursued by CaringLife, and we have assessed that such interests are not overridden by the interests or fundamental rights and freedoms of the persons to whom the Personal Information relates. You have the right to object to the way we process your Personal Information where the processing is based on legitimate interests. For more information see the Your Rights section below.
- Direct communication
All Authorised Account Holders with whom we interact have the option to opt-out of receiving direct email communications from us. If you do not wish to continue to receive direct communications from us and/or selected third parties, you should opt-out by clicking on the “unsubscribe” link in any email communications that we might send you.
- Retention and deletion of Personal Information
We will retain your Personal Information for as long as the CaringLife Account associated with you is active, or as long as needed to provide you with our Service.
We will destroy or de-identify unsolicited Personal Information if it is lawful and reasonable. We take steps to regularly destroy Personal Information. However we may:
- in some cases, retain a copy of your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements and to comply with our trust and safety obligations. Personal Information retained for this purpose will be archived and stored in a secure manner after your CaringLife Account has been closed, and will not be accessed unless required for any of these reasons;
- retain a record of any stated objection by you to receiving marketing for the purpose of ensuring we can continue to respect your wishes and not contact you further; and
- retain Personal Information in an aggregated, de-identified or otherwise anonymous form, such that there is no reliable way of identifying you from the information.
- Cancelling your CaringLife Account
If your CaringLife Account terminates (for whatever reason), the Personal Information associated with it may no longer be accessible to you. Any Content or Personal Information you have posted from your CaringLife Account may still be available to other Authorised Account Holders with which the Content or Personal Information has been associated. There may continue to be residual copies of such Content and Personal Information due to ongoing data back-up, archiving and to comply with our legal obligations.
- Crosssborder Personal Information flows
CaringLife is a global service. Therefore, CaringLife processes and stores the information gathered on Amazon Web Services (AWS) cloud servers located in Australia and the UK.
Where possible, Personal Information is only processed and stored in the country of residence of the Child. In some instances, this will be based on AWS Regions where AWS servers are not available in the country of residence.
We may store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it is not always practicable to know in which country your information may be accessed or held.
If we, or our service providers, transfer any of your Personal Information we collect from you out of Australia or the United Kingdom, it will only be done with relevant protections in place. We will take steps to ensure that your Personal Information will be afforded the level of protection required of us under and in accordance with applicable Data Protection Laws and in accordance with current legally recognised data transfer mechanisms, such as where the country has been deemed adequate by the relevant data protection authorities, or by adopting approved standard contractual clauses.
This will not affect CaringLife’s compliance will all legal requirements for data transfer and storage as may be applicable in each jurisdiction.
- Security of Personal Information
We take all reasonable steps to protect Personal Information, including through internal and external security, restricting access to Personal Information to those who have a need to know, maintaining technological products to prevent unauthorised computer access and regularly reviewing our technology to maintain security. We choose technology partners based on their security and privacy policies and practices.
Personal Information stored in our system is protected by electronic and procedural safeguards. We take all reasonable precautions to protect Personal Information (and other Content) from accidental loss and theft by storing it in secure data centres with off-site backups. Communication between Authorised Account Holders, Carer and Child accounts and our servers is encrypted via industry-standard secure sockets layer (SSL).
The Service is protected by secure and encrypted passwords.
CaringLife does not store the passwords of Authorised Account Holders on our servers. Authorised Account Holders should never share their passwords.
In case of a security incident or any other breach of security safeguards, such as the loss of, unauthorised access to or unauthorised disclosure of Personal Information under CaringLife’s control, we will respond in accordance with applicable laws.
- Your Rights
You may decline to submit Personal Information through the Website or the Service, in which case CaringLife may not be able to provide certain services to you.
14.1 How to access your information
Subject to applicable laws, you may request access to your Personal Information. We will need to verify your identity before we can give you access. We will acknowledge receipt, and we will endeavour to deal with and respond to your request within a reasonable time. Please note that where we are not, or are no longer, in a position to identify you within the information we hold (including because of any de-identification techniques we may have employed), then your rights as described below will not apply to the relevant de-identified information.
In certain circumstances, we are permitted by law to refuse access to your Personal Information. In such cases, we will give you a written explanation for our decision (including, where applicable, an alternative means of access to the information, such as supervised inspection), and how you can complain if you are not satisfied with our decision.
You will not be charged for making a request for your Personal Information However, we may charge a fee to provide your information to cover administrative costs (including for supervised inspection). We will inform you of any fee at the time your request is made.
We will give you access to your information in the form you want it where it is reasonable and practical.
If you would like to request access to your Personal Information, contact us using the details below.
14.2 How to correct your information
If you think that any Personal Information we hold about you is inaccurate, you may ask us to correct it. We will take reasonable steps to correct it unless we disagree with your reasons. If we refuse to correct your Personal Information we will give you a written explanation why.
If you would like to request correction of your personal information, contact us using the details below.
14.3 Additional rights and choices
If you are in the United Kingdom or the European Economic Area, you can:
- obtain information about the processing of your Personal Information;
- ask us to erase your Personal Information, such as if you withdraw your consent and we are not otherwise legally entitled to retain it;
- object to, and ask us to restrict, our processing of your Personal Information, although we may continue to process your Personal Information while we verify your assertion your information is inaccurate or if we are processing your information for our legitimate interests;
- request the porting of any or all your Personal Information to another organisation; /li>
- receive some Personal Information you have given us in a structured, commonly used and machine-readable format or ask us to transmit it to someone else if technically possible feasible; and
- withdraw your consent (but we may be able to continue processing without your consent if there is another legitimate reason to do so). The withdrawal of your consent will not affect the processing of your information to which you had consented.
Please contact CaringLife (see contact details at the end of this Privacy Policy) with any questions or comments about this Privacy Policy, your Personal Information , your consent, access, correction requirements, or your opt-in or opt-out choices.
We will respond to any request made in respect of the above in accordance with the applicable Data Protection Laws where you are resident.
We will respond to any request made in respect of the above without delay, but in any case within one month of a request, or two months where the requests are complex or numerous (in which case, we will inform you of such delay).
- Maintaining the quality of your personal information
It’s important to us that your Personal Information is up to date.
We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records to ensure we continue to provide quality services to you.
- Questions, comments or complaints
If you have any questions, comments, or want to access, update, delete or exercise any of your rights in relation to the Personal Information we hold about you, or have a privacy concern please write to us at:
The Privacy Officer
Nautilus Media Group Pty Ltd
PO Box 1004
Brighton Road
Victoria 3184or by email to: hello@caringlife.com
Please provide sufficient detail about the information in question to help us locate it. We will respond to any privacy request in compliance with the applicable Data Protection Law.
If you still feel your issue or request has not been resolved to your satisfaction, then you have the right to make a complaint to the relevant data protection authority (for example in the place you reside or where you believe we breached your rights). We can, on request, tell you the relevant authority for the processing of your Personal Information.
If you are located in Australia, the relevant authority is the Office of the Australian Information Commissioner, who can be contacted online at http://www.oaic.gov.au/.
If you are in the United Kingdom, the relevant authority is the Information Commissioner's Office, who can be contacted online at www.ico.org.au.