Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use, storage, retention, transfer and disclosure of Your Personal Information and tells You about Your privacy rights and how we handle your Personal Information.

We use Your Personal Information to provide and improve Our Services which are provided under the “Appellon” and “Zyrrah” brands. By using any of the Services, You agree to Our collection and use of information in accordance with this Privacy Policy.

Some of the Personal Information that a user of any of Our Services may provide to us may include information about that person's health, wellbeing, interpersonal relationships or workplace relationships. We treat that information as Sensitive Information and apply the additional handling practices described in this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

“Account”: means a unique account created for You to access any of Our Services or parts of any of Our Services.
“Company”: (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) means Pulse Australasia Pty Ltd (ACN 154 929 450) of Level 36, Gateway Tower, 1 Macquarie Place.
“Cookies”: are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
“Country”: means Australia.
“Device”: means any device that can access any of Our Services such as a computer, mobile phone or a digital tablet.
“Personal Information”: is any information or an opinion about a person or from which the person can reasonably be identified.
“Sensitive Information”: means Personal Information that is considered to be “Sensitive Information” under the Australian Privacy Principles such as information about a person's health, identity and characteristics (such as racial or ethnic origin or their sexual orientation or practices), about a person's beliefs and affiliations (such as political opinions, religious or philosophical beliefs or their trade union or professional association memberships).
“Service”: refers to any of the software programs or Apps that we provide and which include without limitation the programs supplied under the “Appellon” name (which are currently “Lead-Rite”, “Work-Rite”, and “Culture Audits”) and the App supplied under the “Zyrrah” name for personal use.
“Service Provider”: means any natural or legal person who processes data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate any of the Services or to provide any of the Services on behalf of the Company or to perform services related to any of the Services or to assist the Company in analysing how any of the Services are to be used. It also refers to the creators of third party software and systems which connect to and provide ancillary products and services that are used in connection with any of the Services. Service Providers may include hosting providers, support providers, analytics providers, communications providers, security providers, payment or billing providers, software integration providers, professional advisers, contractors and other providers who support the operation, maintenance, security, analysis or improvement of any of the Services.
“Usage Data”: refers to data collected automatically, either generated by the use of any of the Services or from the Service infrastructure itself.
“Website”: refers to Appellon, accessible from appellon.com.
“You”: means the individual accessing or using any Service, or the company, or other legal entity on behalf of which such individual is accessing or using any Service, as applicable.

Collecting and Using Your Personal Information

Types of Data Collected

Personal Information

While using any of Our Services, We may ask You to provide Us with or You may choose to provide Us with information that can be used to contact or identify You. Personal Information may include, but is not limited to:

Email address
First name and last name Phone number
Address, State, Province, ZIP/Postal code, City Usage Data
Information regarding the state of your health or wellbeing or regarding the state of your interpersonal and workplace relationships
Information You provide when creating or managing Your user Account
Information You provide when contacting Us, requesting support or submitting feedback
Information generated through Your use of any of the Services, including responses, activity records, settings, preferences and Service outputs

Sensitive Information

While using some of Our Services, You may choose to provide Us with, Sensitive Information, such as when you provide information about the state of Your health or wellbeing or regarding the state of Your interpersonal and workplace relationships.

Sensitive Information may include:

information that you provide in your responses to questionnaires, prompts, surveys, assessments or exercises;
information obtained from wellbeing indicators, ratings, reflections, observations or notes;
information that you or others provide about interpersonal relationships, workplace relationships, team dynamics, communication, behaviour, stressors, performance or development matters;
information generated from Your use of the Services, including personalised responses, reports, insights, recommendations, scores, summaries or outputs; and
any other information You choose to provide through a Service that relates to Your health, wellbeing, interpersonal relationships or workplace relationships.

We collect Sensitive Information only where it is reasonably required for the relevant Service, feature, assessment, report, insight, support function or account function and where You have consented to that collection.

You may choose not to provide Sensitive Information. If You do not provide it, some features of the Services may not operate, may provide less personalised responses, may provide limited outputs and therefore be less useful to You, or may be unavailable.

We will not use identifiable Sensitive Information for marketing, promotional campaign analysis, external benchmarking, global wellbeing insights or workplace insights unless You have provided separate consent or the information has first been de-identified so that You are not reasonably identifiable.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages or any of the other parts of any of Our Services that You visit or access, the time and date of Your visit or access, the time spent during that visit or access, unique device identifiers and other diagnostic data.

When You access any of Our Services by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

Usage Data may be associated with Your Account or other Personal Information where this is necessary to provide, secure, maintain, support, analyse or improve any of the Services.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Services and store certain information. The technologies We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of Our Services. Unless You have adjusted Your browser setting so that it will refuse Cookies, Our Services may use Cookies.

Flash Cookies. Certain features of Our Services may use locally stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on Our Services.

Web Beacons. Certain sections of Our Services and Our emails may contain small electronic files known as web beacons that permit the Company to count users who have visited those pages or opened an email.

We may use Cookies and similar technologies for purposes including authentication, account management, security, remembering preferences, analysing usage, maintaining functionality, improving the Services and understanding whether communications have been opened or acted upon.

We do not use Cookies or similar tracking technologies to collect Sensitive Information unless this is necessary for a feature of the Services, has been clearly notified to You, or You have chosen to provide the relevant information through the Services.

Use of Your Personal Information

The Company may use Personal Information for the following purposes:

To provide and maintain Our Services, including monitoring the usage of Our Services.
To manage Your Account: To manage Your registration as a user of Our Services. The Personal Information You provide can give You access to different functionalities of Our Services that are available to You as a registered user. The Personal Information You provide can also provide You with more personal responses from the use of Our Services.
For the performance of a contract: including the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us that Your employer or another person has entered into with Us to enable Your use of any of Our Services.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To manage Your requests: To attend and manage Your requests to Us.

For other purposes:

To analyse and improve the Services: We may use Personal Information to analyse Service performance, identify usage trends, diagnose technical issues, test features, maintain functionality, improve user experience, improve Service outputs and develop or enhance Our Services, products and support functions.
To personalise the Services: We may use Personal Information, including Sensitive Information where You have provided it, to provide personalised responses, insights, reports, recommendations, prompts, assessments or other outputs within the Services.
To maintain security and integrity: We may use Personal Information and Usage Data to monitor, detect, prevent, investigate or respond to security, technical, operational, misuse, fraud, safety or integrity issues affecting the Services.
To prepare de-identified or aggregated insights: We may use information that has been de-identified or aggregated to contribute to wellbeing and workplace insights, understand trends, improve the Services and develop broader insights. We will not treat information as de-identified if You remain reasonably identifiable from that information alone or in combination with other information available to Us.
To conduct marketing and promotional analysis: We may use Personal Information to understand the effectiveness of communications, marketing or promotional campaigns. We will not use identifiable Sensitive Information for marketing or promotional campaign analysis unless You have provided separate consent.
To comply with obligations and manage disputes: We may use Personal Information where necessary to comply with obligations, resolve disputes, enforce agreements and policies, protect Our rights or property, and manage legal, safety, security or operational issues.

Where a use relates to Sensitive Information, We will limit the use to the purpose for which the information was collected, a directly related purpose that You would reasonably expect, a purpose to which You have consented, or another purpose described in this Privacy Policy.

Disclosure of Your Personal Information

We may disclose Your personal information with Your consent in the following situations:

To Service Providers: We may disclose Personal Information to Service Providers who help Us host, operate, maintain, secure, support, analyse, integrate, communicate about or improve any of the Services.
To connected software and systems: We may disclose Personal Information to the creators, operators or providers of third-party software, systems or integrations which connect to or provide ancillary products or services used in connection with any of the Services.
To employers, organisations or account administrators: Where Your access to a Service is arranged by Your employer, organisation or another person, We may disclose limited information to that employer, organisation or account administrator to manage access, accounts, billing, reporting, Service usage, support, security or contracted Service delivery. We will not disclose identifiable Sensitive Information to an employer, organisation or account administrator unless the disclosure is clearly notified to You and is necessary for the relevant Service or You have consented to that disclosure.
To support de-identified or aggregated reporting: We may disclose de-identified or aggregated information, including de-identified wellbeing or workplace insights, provided that the information does not reasonably identify You.
For business transactions: We may disclose Personal Information where reasonably necessary for a merger, acquisition, restructure, financing, due diligence process, asset sale or similar transaction involving the Company or its business.
For safety, security and dispute management: We may disclose Personal Information where reasonably necessary to protect the rights, property, safety, security or integrity of the Company, users, Service Providers, the Services or the public, or to prevent, detect, investigate or respond to possible wrongdoing, misuse, fraud, security incidents or technical issues.

Other Legal Requirements

The Company may disclose Your Personal Information in the good faith belief that such action is necessary to:

Comply with an obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Services
Protect the personal safety of Users of the Services or the public
Protect against legal liability

Where practicable, We will limit any disclosure under this section to the information reasonably necessary for the relevant purpose.

We will take reasonable steps to limit any disclosure of Personal Information to what is reasonably necessary for the relevant purpose.

De-identified information and Insights

We may use de-identified or aggregated information to understand usage trends, improve the Services, develop insights and contribute to global wellbeing and workplace insights.

Before using information for de-identified or aggregated insights, We take steps designed to remove, alter or aggregate information that could reasonably identify You.

We do not treat information as de-identified if You remain reasonably identifiable from that information alone or in combination with other information available to Us.

We will not publish or disclose reports, benchmarks or insights in a way that is intended to identify an individual user.

Where insights relate to a workplace, organisation, team or group, We may apply additional controls such as aggregation, minimum group thresholds, suppression of small cohorts or removal of direct identifiers where appropriate.

Retention of Your Personal Information

The Company will retain Your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Information to the extent necessary to comply with Our legal obligations, resolve disputes, and enforce Our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of any of Our Services or We are legally obligated to retain this data for longer periods of time.

In determining retention periods, We may consider the type of information, the sensitivity of the information, the purpose for which it was collected, the nature of the Service, Your account status, operational requirements, security requirements, dispute management requirements, contractual requirements and whether the information can be deleted, de-identified or securely archived.

Sensitive Information is retained only for as long as reasonably necessary for the relevant Service, feature, assessment, report, insight, support function or account function, unless a longer retention period is required for security, dispute management, operational, contractual or compliance purposes.

Where Personal Information is no longer required, We will take reasonable steps to delete it, de-identify it or securely archive it.

Backup copies may be retained for a limited period after deletion from active systems, subject to access controls and scheduled deletion, replacement or overwriting.

De-identified or aggregated information may be retained for analytics, reporting, Service improvement, benchmarking or insight purposes, provided that individuals are not reasonably identifiable.

Transfer of Your Personal Information

Your information, including Personal Information, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on - computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

The Company will take all steps reasonably necessary to ensure that Your Personal Information is treated securely and in accordance with this Privacy Policy.

Some Service Providers may store, process or access Personal Information from locations outside Australia. This may include cloud hosting, technical support, analytics, communications, security, software development, integration or maintenance services.

Where Personal Information is disclosed to or accessed by a recipient outside Australia, We will take reasonable steps designed to ensure that the recipient handles the information consistently with this Privacy Policy, including through contractual, confidentiality, access control, security and data handling arrangements.

We will apply additional care before allowing overseas access to Sensitive Information, including considering whether the access or transfer is necessary for the relevant Service and whether appropriate safeguards are in place.

The countries or regions in which information may be processed may change from time to time depending on the Service Providers and infrastructure used to deliver the Services. You may contact Us to request further information about the countries or recipient classes relevant to Your information.

Security of Your Personal Information

The security of Your Personal Information is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. We take reasonable technical, organisational and administrative steps designed to protect Your Personal Information against misuse, interference, loss, unauthorised access, modification and disclosure. While We strive to use commercially acceptable means to protect Your Personal Information, We cannot guarantee its absolute security.

These steps may include encryption in transit, encryption at rest where appropriate, access controls, authentication controls, role-based permissions, logging and monitoring, secure hosting arrangements, backup controls, vulnerability management, staff and contractor confidentiality obligations, Service Provider controls and incident response procedures.

We limit access to Sensitive Information to personnel, contractors and Service Providers who require access for the purposes described in this Privacy Policy.

Although no method of transmission over the Internet or method of electronic storage is completely secure, We maintain safeguards designed to protect Personal Information having regard to the nature and sensitivity of the information We hold.

Access and Correction

You may request access to Personal Information We hold about You. You may also request that We correct Personal Information if You believe it is inaccurate, out of date, incomplete, irrelevant or misleading. You may also contact us if You have a question, concern or complaint about how We collect, use, store, retain, transfer or disclose Personal Information.

You may contact Us using the contact details made available through the Services or on Our Website.

We may need to verify Your identity before responding to an access or correction request.

We will respond to access and correction requests and other queries within a reasonable period.

In some circumstances, We may be unable to provide access to, or correction of, particular information. If that occurs, We will explain the reason where it is reasonable and appropriate to do so.

Account Closure, Deletion and De-identification

You may contact Us to request closure of Your Account or deletion of Personal Information associated with Your Account.

Following an Account closure or deletion request, We will take reasonable steps to delete, de-identify or securely archive Personal Information that is no longer required for the purposes described in this Privacy Policy.

Some information may be retained where reasonably necessary for security, operational, dispute management, contractual, backup, compliance, or record-keeping purposes.

De-identified or aggregated information may be retained where You are not reasonably identifiable.

Direct Marketing and Communications

We may use Your contact details to send You Service-related communications, including account, support, operational, security, feature or update communications.

We may send marketing or promotional communications where appropriate. You may opt out of marketing communications by using any unsubscribe or preference management function provided in the communication or by contacting Us.

We will not use identifiable Sensitive Information for marketing communications, marketing segmentation or promotional campaign analysis unless You have provided separate consent.

Children's Privacy

Our Services are not intended for use by anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Information, please contact Us. If We become aware that We have collected Personal Information from a person under the age of 13 without appropriate involvement from a parent or guardian, We will take reasonable steps to delete that information or otherwise manage it appropriately.

Links to Other Websites

Our Services may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third-party's site. We encourage You to read the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

This Privacy Policy does not apply to third-party websites, software, systems, applications, integrations or services that are not operated by Us, even if they are linked to or integrated with any of the Services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

Where changes are material, We may also take additional steps to notify You, such as by email, in-Service notification or other reasonable means.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact

For privacy questions, access requests, correction requests, account closure requests or privacy complaints, You may contact Us at:

Email: admin@zyrrah.app

Pulse Australasia Pty Ltd (ACN 154 929 450)
Level 36, Gateway Tower, 1 Macquarie Place

If You are not satisfied with Our response, You may also lodge a privacy complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.