Legal & Compliance
Privacy Policy
Sahha is our cloud based engine, which, when integrated into a third party mobile app via our software development kits (Third Party App), collects, monitors and analyses a Third Party App ’s end user’s (End User) behavioural and other data.
1. SAHHA PTY LTD – PRIVACY POLICY
Sahha Pty Ltd (ABN 26 649 986 505) ( we , us or our ), understands that protecting your personal information is important. We are an API tool to collect and analyse health and wearable device data for health and fitness applications ( Services ). This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or collected by us, when interacting with you.
This policy does not include data we share or process if you are an end user of a third-party application built by our clients which may integrate, rely on, or are otherwise driven by our Services. You can access the relevant policy to you here .
This Privacy Policy takes into account the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles , as well as the New Zealand Privacy Act 2020 and the Information Privacy Principles . In addition to the Australian laws, individuals located in the European Union (EU) or European Economic Area (EEA) may also have rights under the General Data Protection Regulation 2016/679 (GDPR) . Individuals located in the United Kingdom (UK) may have rights under the General Data Protection Regulation (EU) 2016/679 (UK GDPR) and the Data Protection Act 2018 (DPA 2018) . Appendix 1 outlines the details of the additional rights of individuals located in the EU and UK, as well as information on how we process the personal information of individuals located in these regions.
2. The Information We Collect
Personal Information : Personal information is data or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.
The types of personal information we may collect about you include:
- Identity Data : Including your name, profession.
- Contact Data : Including your telephone number, address, and email.
- Financial Data : Including bank account and payment card details.
- Transaction Data : Including details about payments to you from us, payments from you to us, and other details of products and services purchased from us or by us.
- Technical and Usage Data : When you access any of our Services, websites, or platforms, this includes details about your IP address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of our website (including through Internet cookies), and communications with our website.
- Profile Data : Including your username and password for our application (if applicable), and any support requests you have made.
- Interaction Data : Information you provide to us when you participate in any interactive features, including surveys, contests, promotions, activities, or events.
- Marketing and Communications Data : Your preferences in receiving marketing from us and third parties, as well as your communication preferences.
- Professional Data : If you are a worker of ours or applying for a role with us, this includes your professional history such as previous positions, professional experience, or whether you hold required authorisations or licenses.
- Sensitive Information : This is a sub-set of personal information given a higher level of protection. Sensitive information includes details relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information, or biometric information.
3. How we collect personal information
We collect personal information in a variety of ways, including:
- when you provide it directly to us, including face-to-face, over the phone, over email, or online;
- when you complete a form, such as registering for any events or newsletters, or responding to surveys;
- when you use any website we operate (including from any analytics and cookie providers or marketing providers. See the “Cookies” section below for more detail on the use of cookies);
- from third parties; and
- from publicly available sources.
4. Why we collect, hold, use and disclose personal information
We have set out below, in a table format, a description of the purposes for which we plan to collect, hold, use and disclose your personal information:
| Purpose of Use / Disclosure | Type of Personal Information |
|---|---|
| To enable you to access and use our Services, including to provide you with a login. | Identity Data, Contact Data |
| To work or do business with you, including to provide our Services to you, or integrate our API with your applications. | Identity Data, Contact Data |
| To contact and communicate with you about our business, including in response to any support requests or other enquiries. | Identity Data, Contact Data, Profile Data |
| To contact and communicate with you about any enquiries you make via any website we operate. | Identity Data, Contact Data |
| For internal record keeping, administrative, invoicing, and billing purposes. | Identity Data, Contact Data, Financial Data, Transaction Data |
| For analytics, market research, and business development, including to operate and improve our business and applications. | Profile Data, Technical and Usage Data |
| For advertising and marketing, including to send you promotional information or information that may be of interest to you. | Identity Data, Contact Data, Technical and Usage Data, Marketing and Communications Data |
| To run promotions, competitions, and/or offer additional benefits to you. | Identity Data, Contact Data, Profile Data, Interaction Data, Marketing and Communications Data |
| If you have applied for employment with us, to consider your employment application. | Identity Data, Contact Data, Professional Data |
| To comply with our legal obligations or if otherwise required or authorised by law. | Any relevant Personal Information |
| Sensitive information : We only collect, hold, use and disclose sensitive information for the following purposes: Any purposes you consent to, The primary purpose for which it is collected, Secondary purposes directly related to the primary purpose, including disclosure to third parties as necessary to do business with you, To contact emergency services, or speak with family, partner, or support person in case of serious risk to life, health, or safety, If otherwise required or authorised by law. | Sensitive Information |
5. Our disclosures of personal information to third parties
Personal information : We will only disclose personal information (excluding sensitive information) to third parties where it is necessary as part of our business, where we have your consent, or where permitted by law. This means that we may disclose personal information (excluding sensitive information) to:
- our employees, contractors and/or related entities;
- IT service providers, data storage, web-hosting and server providers;
- marketing or advertising providers;
- professional advisors, bankers, auditors, our insurers and insurance brokers;
- payment systems operators or processors;
- our existing or potential agents or business partners;
- sponsors or promoters of any promotions or competition we run;
- if we merge with, or are acquired by, another company, or sell all or a portion of our assets, your personal information may be disclosed to our advisers and any prospective purchaser’s advisers and may be among the assets transferred;
- courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
- courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
- third parties to collect and process data, such as analytics providers and cookies; and
- any other third parties as required or permitted by law, such as where we receive a subpoena.
Sensitive information : We will only disclose sensitive information with your consent or where permitted by law. This means that we may disclose sensitive information to:
- our employees, contractors and/or related entities;
- IT service providers, data storage, web-hosting and server providers;
- professional advisors;
- if we merge with, or are acquired by, another company, or sell all or a portion of our assets, your personal information may be disclosed to our advisers and any prospective purchaser’s advisers and may be among the assets transferred;
- courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
- third parties to collect and process data, such as analytics providers and cookies; and
- any other third parties as required or permitted by law, such as where we receive a subpoena.
Google Analytics : We may use Google Analytics Advertising Features. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together. These cookies and identifiers may collect Technical and Usage Data about you.
You can opt-out of Google Analytics Advertising Features, including using a Google Analytics Opt-out Browser add-on found here .
To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here , or if you wish to opt-out permanently even when all cookies are deleted from your browser, you can install their plugin here .
To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device:
- On Android, open the Google Settings app on your device and select “Ads” to control the settings.
- On iOS devices with iOS 6 and above, use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.
To find out how Google uses data when you use third party websites or applications, please see here .
6. Overseas disclosure
We may store personal information in Australia, New Zealand, the European Union or the United States of America. Where we disclose your personal information to the third parties listed above, these third parties may also store, transfer or access personal information overseas. We will only disclose your personal information overseas in accordance with the applicable laws.
7. Your rights and controlling your personal information
Your choice : Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to do business with you.
Information from third parties : If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Restrict and unsubscribe : To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Access : You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.
Correction : If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
Complaints : If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (if you are an Australian resident), or the Office of the New Zealand Privacy Commissioner (if you are a New Zealand resident).
8. Storage and security
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the internet. The transmission and exchange of information is carried out at your own risk.
Some of the security measures we implement include:
- use reputable cloud hosting providers to host personal information;
- passwords and access control procedures, anti-virus, firewall and security controls for email and other applicable computer software and systems;
- maintain files, in both hard-copy and electronic form, at our offices and other access-controlled premises;
- operate online records managements systems on secure networks;
- regularly perform security testing;
- maintain physical security measures in our buildings and offices such as visitor access management, cabinet locks, surveillance systems and alarms to ensure the security of information systems (electronic or otherwise);
- require our employees, agents and contractors to comply with privacy and
- confidentiality provisions in their employment and subcontractor agreements that we enter into with them;
- use SSL encryption on our systems;
- have data backup archiving and disaster recovery processes in place;
- if appropriate in the circumstances taking into account the state of the art, the costs of implementation and the nature, scope, content and purpose of the processing, we will encrypt personal information; and
- with respect to personal information that we no longer require or where we are otherwise required to destroy it under applicable law, we ensure that such personal information is securely destroyed.
- We will retain personal information only for as long as necessary to:
- fulfil the purposes for which it was collected and any other purposes set out in this Privacy Policy;
- any additional purposes notified to you at or before the time of collection of the relevant personal information; or
- as required or permitted by any applicable laws.
When retention of personal information is no longer required for legal, compliance or other business purposes, we will use reasonable measures to ensure the personal information is either securely deleted, destroyed or anonymised.
You may request deletion of your personal information, which we will comply with subject to certain exceptions (such as complying with our legal obligations).
9. Cookies
We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
For more information about the cookies we use, please see our cookie policy below:
| Cookie | Category | Purpose |
|---|---|---|
| Currency | Functionality | This cookie stores the currency used for the online Services (USD). |
| Language | Functionality | This cookie stores the language used for the online Services (English). |
| PHPSESSIONID | Analytical/Performance | This cookie contains a unique ID to support functions (e.g., last viewed pages) to improve user experience. |
| newsbcsub | Functionality | This cookie is stored once the user has completed or closed the Register Pop Up, preventing it from re-appearing until after 7 days. |
| TLSCookiesEU | Strictly necessary | This cookie tracks when a user has accepted that the online Services use cookies, preventing the popup from being displayed again during that session. |
| _ga / _gid / _gat | Analytical/Performance | These cookies are used by our Google Analytics account to track customer traffic through the website to help us understand how our website is being used by users. |
| accountId | Functionality | This cookie stores the account identifier used for the online services. |
| environment | Functionality | This cookie stores the environment used to load the last used environment again on subsequent logins. |
| token | Functionality | This cookie stores the authorisation bearer token used to authenticate and authorise access in the online Services. |
10. Links to other websites
Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.
11. Personal information from single sign-on accounts
If you connect your account with us using a single sign-on account, we will collect your personal information from the single sign-on provider. We will do this in accordance with the privacy settings you have chosen with that provider.
The personal information that we may receive includes your name, ID, user name, handle, profile picture, gender, age, language, list of friends or follows and any other personal information you choose to share.
Where we have accessed your personal information through your Facebook account, you have the right to request the deletion of personal information that we have been provided by Facebook. To submit a request for the deletion of personal information we acquired from Facebook, please send us an email at the address at the end of this Privacy Policy and specify in your request which personal information you would like deleted. If we deny your request for the deletion of personal information, we will explain why.
12. Amendments
We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.
For any questions or notices, please contact our Privacy Officer at:
Sahha Pty Ltd (ABN 26 649 986 505)
Email: aleks@sahha.ai
13. APPENDIX 1: ADDITIONAL RIGHTS AND INFORMATION FOR INDIVIDUALS LOCATED IN THE EU OR UK
Under the GDPR individuals located in the EU and the UK have extra rights which apply to their personal information. Personal information under the GDPR is often referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual). This Appendix 1 sets out the additional rights we give to individuals located in the EU and UK, as well as information on how we process the personal information of individuals located in the EU and UK. Please read the Privacy Policy above and this Appendix carefully and contact us at the details at the end of the Privacy Policy if you have any questions.
14. What personal information is relevant?
This Appendix applies to the personal information set out in the Privacy Policy above. This includes any Sensitive Information also listed in the Privacy Policy above which is known as ‘special categories of data’ under the GDPR.
15. Purposes and legal bases for processing
We collect and process personal information about you only where we have legal bases for doing so under applicable laws. We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please reach out to us if you need further details about the specific legal ground, we are relying on to process your personal information where more than one ground has been set out in the table below.
| Purpose of Use / Disclosure | Type of Data | Legal Basis for Processing |
|---|---|---|
| To enable you to access and use our Services, including to provide you with a login. | Identity Data, Contact Data | Performance of a contract with you |
| To do business with you. | Identity Data, Contact Data | Performance of a contract with you |
| To contact and communicate with you about our business, including in response to any support requests or other enquiries. | Identity Data, Contact Data, Profile Data | Performance of a contract with you |
| To contact and communicate with you about any enquiries you make with us via our website. | Identity Data, Contact Data | Legitimate interests: to ensure we provide the best client experience we can offer by answering all of your questions |
| For internal record keeping, administrative, invoicing, and billing purposes. | Identity Data, Contact Data, Financial Data, Transaction Data | Performance of a contract with you, To comply with a legal obligation, Legitimate interests: to recover debts due and notify you of changes to terms |
| For analytics, market research, and business development, including to operate and improve our business, API, algorithms, and social media platforms. | Profile Data, Technical and Usage Data | Legitimate interests: to keep our website updated and relevant, to develop and improve our business, and to inform our marketing strategy |
| For advertising and marketing, including to send you promotional information about our events and experiences. | Identity Data, Contact Data, Technical and Usage Data, Profile Data, Marketing and Communications Data | Legitimate interests: to develop and grow our business |
| To run promotions, competitions, and/or offer additional benefits to you. | Identity Data, Contact Data, Profile Data, Interaction Data, Marketing and Communications Data | Legitimate interests: to facilitate engagement with our business and grow our business |
| If you have applied for employment with us, to consider your employment application. | Identity Data, Contact Data, Professional Data | Legitimate interests: to consider your employment application |
| To comply with our legal obligations or if otherwise required or authorised by law. | Any relevant Personal Information | To comply with a legal obligation |
If you have consented to our use of data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your data because we or a third party have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer doing business with us. Further information about your rights is available below.
16. Data Transfers
The privacy protections available in the countries to which we send data for the purposes listed above may be less comprehensive than what is offered in the country in which you initially provided the information. Where we transfer your personal information outside of the country where you are based, we will perform those transfers using appropriate safeguards in accordance with the requirements of applicable data protection laws and we will protect the transferred personal information in accordance with this Privacy Policy and Appendix 1. This includes:
- only transferring your personal information to countries that have been deemed by applicable data protection laws to provide an adequate level of protection for personal information; or
- including standard contractual clauses in our agreements with third parties that are overseas.
17. Data retention
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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 unauthorised 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, and the applicable legal, regulatory, tax, accounting or other requirements.
18. Extra rights for EU and UK individuals
You may request details of the personal information that we hold about you and how we are process it (commonly known as a “data subject request”). You may also have a right in accordance with applicable data protection law to have your personal information rectified or deleted, to restrict our processing of that information, to object to decisions being made based on automated processing where the decision will produce a legal effect or a similarly significant effect on you, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to you or another organisation.
If you are not happy with how we are processing your personal information, you have the right to make a complaint at any time to the relevant Data Protection Authority based on where you live. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Authority, so please contact us in the first instance using the details set out above in our Privacy Policy above.
For any questions or notices, please contact us.