Last updated 18 December 2024

We use your information and data to improve the Platform and provide our Products and Services. By using the Platform, our Products and Services, you agree to the collection, use and disclosure of your information and data in accordance with this Privacy Policy.

What is Privacy Policy?

Your privacy and trust are very important to us. This Privacy Policy explains the Personal Information that Enosis Therapeutics processes, how we process it and for what purposes it is processed.

Unless otherwise expressly stated in this Privacy Policy, the terms used in this Privacy Policy have the same meaning as in our Terms and Conditions (“Terms”). Our Terms govern the use of our Products and Services and the said Terms together with the Privacy Policy collectively constitute your agreement with us.

Furthermore, this Privacy Policy is intended to help you understand what data and information Enosis Therapeutics (“us”, “we”, or “our”), including our websites and Apps collect, use and your rights related to it. For purposes of this Privacy Policy and unless otherwise specified, “data” includes all information that is linked to one person or household including but not limited to data such as names, email addresses, phone numbers, device ID, third party identifiers, contact information, and voice recordings and drawings recorded on our platform (the “Platform”) to provide the Services. Some jurisdictions might consider this to be “personal data,” “personally identifiable information,” or “sensitive personal data” in certain circumstances. When you use and access any of our Apps or websites, you accept and agree to both the Terms and this Privacy Policy, including sharing certain data and information with our third party service providers. 

We value the users of our Platform and Services. We recognise that you may be concerned about collection, use and disclosure of the data and information that we collect when you use the Platform and the Services offered on the Platform or Services. By using our Platform and Services you are accepting the practices described in this Privacy Policy. If you have any questions or comments regarding this Privacy Policy or any suggestions on how we should improve it, please contact us at privacy@enosistherapeutics.com. 

What information and data we collect

Information and data that you provide us 

Personal Information you may provide to us through the Platform or otherwise including:

• Contact data, such as your first and last name, phone number and email address;
• Registration data, that you provide when you register through the Platform, such as your first name, last name, email address, display name, state, country, gender and date of birth;
• Profile data, such as the username and password that you may set to establish an Account (defined in our Terms) on the Platform, photographs, list of people you follow and those who follow you and any other information that you add to your Account;
• Communications that we exchange with you, including when you contact us through the Platform, email, social media or otherwise;
• Transactional data, such as information relating to your Enosis Therapeutics Subscriptions or needed to complete your orders on or through the Platform, including order numbers, subscription method and transaction history;
• Marketing data, such as your preferences for receiving our marketing communications;
• User-generated content, such as profile pictures; photos; images; music; videos; comments; questions; messages; drawings; voice recordings; lists of friends, followers, and circles you are connected to and interact with; and other content or information that you generate, transmit, or otherwise make available on the Platform, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited.  Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data;
• Voice, voice recordings and audio data, such as your voice, audio information and voice recordings that we may collect when you use our Platform and Services. With your permission, your voice recordings will be acquired via the Platform and transferred to us;
• Relationship data, such as familial or other relationships to third parties whose personal information you may provide to us;
• Health and fitness data that you store in your mobile health apps, such as Apple HealthKit and Google Fit, when you choose to grant us access to it or that you choose to record in the Platform;
• Mood and feeling based on your voluntary responses to surveys and questionnaires;
• Body dimensions that you choose to store in the tracking features of your VR device such as a Meta Quest;
• Biometric information, including but not limited to genetic, physiological, behavioural, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait or other physical patterns, and sleep, health or exercise data, electroencephalogram (EEG) data, eye movement data and any other biometric information you voluntarily provide or that may be collected during your use of the Platform;
• Payment information needed to complete transactions, including payment card information or bank account number. Note that your payment card information is processed directly by our third party service providers. For more information on how we share your Personal Information, please see the section on “How we share your Personal Information”;
• Survey and promotions data including information you share when you choose to participate in a promotion or complete a survey. We recommend that you read all instructions, terms or rules applicable to the survey or promotion before participating; and
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third party sources

We may combine the Personal Information we receive from you with information and data we obtain from other sources including:

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources;
• Data providers, such as information services and data licensors that provide demographic and other information;
• Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs; 
• Marketing partners, such as joint marketing partners and event co-sponsors; and
• Third party services, such as social media services, that you use to log into, or otherwise link to your Account. This data may include your username, profile picture and other information associated with your Account on that third party service that is made available to us based on your Account settings on that service.

Automatic data collection 

We, our third party service providers and our business partners may automatically log information about you, your computer, mobile device or VR headset and your interactions over time with the Platform, our communications and other online services, including:

• Device data, such as your computer, mobile or VR headset’s operating system type and version, manufacturer and model, browser type, graphics processing unit, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers including VR App identifiers and identifiers used for advertising purposes, language settings, mobile device carrier, radio or network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area;
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing the Platform, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them;
• Interaction data, such as information about the content, features, length and frequency of sessions undertaken on the VR App;
• Technical system information, such as crash logs which may contain your user ID, device ID, IP address, local computer file path, feature quality, and use of that feature;
• Precise geolocation data when you authorise our mobile App to access your mobile device’s location;
• Fitness, such as the number of calories you have burned or how long you have been physically active when you choose to track this data using the health tracking features of your device;
• Physical characteristics and movement, such as head and controller movement, including the position, orientation and speed of your VR headset and controllers;
• Physiological data, such as your heart rate, breathing rate and EEG data;
• Body dimensions, such as your height, derived from the VR headset’s distance from the floor;
• Eye direction through cameras that estimate the direction of where your eyes are looking if you choose to grant us access to it through your device’s operating system;
• Hand data, such as estimated hand size, orientation, and finger configuration to generate a generic hand model that can be used to navigate the VR App if you choose to grant us access to it through your device’s operating system;
• Facial expressions estimating how your face is moving if you choose to grant us access to it through your device’s operating system; and
• Physical environment data, such as the dimensions of the room where you use your device.

Cookies and other technologies 

Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third party business partners and service providers place;
• Local storage technologies, such as HTML5, that provide cookie equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications;
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked;
• Session replay services, which employ software code to record users’ interactions with the Platform in a manner that allows us to watch DVR-like replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement (For example, we use session replay services provided by Hotjar. You can learn more about Hotjar at https://www.hotjar.com/legal/policies/privacy/); and
• Software development kits (SDKs), or third party computer code, that may be used for a variety of purposes, including to provide us with analytics regarding the use of our applications, to integrate with social media, add features or functionality to our applications, or to facilitate online advertising. SDKs may enable third parties to collect information directly from our applications.

Data about others 

We may offer features that help users invite their friends or contacts to use the Platform, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless they have granted their express consent to do so.

How we use your Personal Information

We may use your Personal Information for the following purposes or as otherwise described at the time of collection:

Service delivery 

We may use your Personal Information to:

• provide, operate and improve the Platform and our business;
• personalise your experience on the Platform by analysing your usage patterns, preferences and interactions to tailor or services and content on the Platform;
• facilitate your invitations to friends who you want to invite to join the Platform;
• communicate with you about the Platform, including by sending announcements, updates, security alerts, and support and administrative messages;
• understand your needs and interests, and personalise your experience with the Platform and our communications; and
• provide support for the Platform, and respond to your requests, questions and Feedback.

Research and development 

We may use your Personal Information for research and development purposes, including to analyse and improve the Platform and our business. We use the data we collect to develop, test and improve our Services and Products, including by conducting surveys and research, and testing and troubleshooting new products and features.

Marketing and advertising 

We, our third party service providers and advertising partners may collect and use your Personal Information for marketing and advertising purposes:

•  Direct marketing. We may send you direct marketing communications.  Your information and data may be utilised to reach out to you with newsletters, marketing or promotional content that could be of interest. If you wish to opt out of receiving any or all of these communications, you can do so by emailing us at support@EnosisTherapeutics.com.
• Interest-based advertising. Our third party advertising partners may use cookies and other technologies to collect information about your interactions (including the data described in the automatic data collection section above) with the Platform, our communications and other online services over time, and use that information to serve online advertisements (“Ads”) that they think will interest you. This is called interest-based advertising. We may also share user lists with these companies to facilitate interest-based advertising to those or similar users on other online platforms. If you wish to limit interest-based advertising you may do so by changing your web browser or mobile device settings. 

Compliance and protection 

We may use your Personal Information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Platform; 
• prevent, identify, investigate and deter fraudulent, harmful, unauthorised, unethical or illegal activity, including cyberattacks and identity theft; and
• to create anonymous, aggregated or de-identified data (“Anonymised Data”). We may create Anonymised Data from your Personal Information and other individuals whose personal information we collect. We make Personal Information into Anonymised Data by removing information that makes the data identifiable to you. In order to provide our Services, we work with third party service providers who perform Services on our behalf and with whom we share personal data and information of a user to support our Services. We may use this Anonymised Data and share it with third parties for our lawful business purposes, including to analyse and improve the Platform and promote our business. We do not attempt to reidentify such Anonymised Data.

Cookies and other technologies. 

In addition to the other uses included in this section, we may use the cookies and other technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Platform, such as by remembering your selections and preferences as you navigate the Site, and whether you are logged in when you visit password protected areas of the Platform;
• Advertising. To help our third party advertising partners collect information about how you use the Platform and other online services over time, which they use to show you Ads on other online services they believe will interest you and measure how the Ads perform; and
• Analytics. To help us understand user activity on the Platform, including which pages are most and least visited and how visitors move around the Platform, as well as user interactions with our emails. (For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.)

How we share your Personal Information

We may share your Personal Information with the following parties and as otherwise described in this Privacy Policy or at the time of collection. 

• Affiliates: Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

• Service Providers: Third parties that provide services on our behalf or help us operate the Platform or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and analytics).

• Advertising partners:  Third party advertising companies for the interest-based advertising purposes described above.

• Business and marketing partners: Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

• Linked third party services: If you log into the Platform with, or otherwise link your Account to social media or other third party services, we may share your Personal Information to the extent that is required for the service providers to provide such third party services. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your Account with the third party service.

• Professional advisors: Professional advisors, such as, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

• Legal advisors: Insofar as reasonably necessary to defend our legal rights, we may share your Personal Information with our legal advisors.

• Authorities and others: Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

• Business transferees: Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganisation, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Enosis Therapeutics or our affiliates (including, in connection with a bankruptcy or similar proceedings). 

• Other users and the public:  Your profile and some user-generated content may be visible to other users of the Platform and the public.  Other users of the Platform or the public may have access to your Personal Information if you choose to make your profile or your Personal Information and such other information and data available to them through the Platform, such as when you provide comments, reviews, survey responses, or share other content. Please be aware that such information and data can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (i.e. search engines), and we are not responsible for any such use of the information and data. We do not share any messages, drawings and voice recordings that we collect from you through our Platform to the public or any other user unless it is required by law.

• Research partners:  We maintain an ongoing collaboration with research partners to iteratively enhance our Products and Services. It’s important to note that, as part of this process, specific information and data collected during your participation in surveys or other research activities may be shared with our research partners to contribute to improvement efforts. This sharing occurs in accordance with the information we provided to you at the time of data collection, and in some instances, we may share such information without obtaining your explicit consent. This practice reflects our dedication to consistently refining and innovating our Services and Products.

Other sites and services 

The Platform may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control any websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the relevant privacy policies of any other websites, mobile applications and online services you use.

Storage and data transfers

We store the Personal Information you provide us on secure servers, which are protected by industry standard security measures. Your Personal Information may also be stored on secured third party servers or cloud-based systems which adhere to our data security standards.  

We are headquartered in Australia and we may use third party service providers that operate in other countries. All your information and data, including Personal Information, may be transferred to and maintained on computers and servers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside Australia and choose to provide information and data to us, please note that we transfer such information and data, including your Personal Information, to Australia and process it there. Your consent to this Privacy Policy, followed by your submission of such information and data, represents your agreement to that transfer. We will take all the steps reasonably necessary to ensure that all your information data including Personal Information is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Information will take place to an organisation or a country unless there are adequate controls in place to ensure security of your Personal Information. For more information on how we transfer the personal information of individuals based in Europe, please see the Information for Individuals in Switzerland, UK and the EEA  section.

How do we keep your information and data secure

We apply industry standards and strive to apply best practices to prevent any unauthorised access and disclosure. Internet based services carry inherent security risks, but our systems, infrastructure, encryption technology, operation and processes are all designed, built, and well maintained to ensure your information and data are given the requisite security and privacy. However, we cannot guarantee the security of any personal information transmitted over the internet and therefore you disclose information to us at your own risk and we will not be liable for any unauthorised access, modification or disclosure, or misuse of your personal information.

For your own security, keep the following in mind: 

• Phishing: This is a type of online identity theft or account hacking. We will never request your login information to your Account or any payment information in any non-secure or unsolicited communication. You should always be diligent when you are asked to provide your Account information and payment information and make sure it is in our secure system. 
• External links: Our Platform may contain links to an external website or service. We do not control external websites and do not have control over their privacy policies and terms of use. The fact that we link to a website is not an endorsement, authorisation, or representation of our affiliation with that external party or of their privacy and security policies or practices.

How do we treat information and data of children?

We do not knowingly collect or solicit any data or information from anyone under the age of 18 years or knowingly allow such persons to become our users. The Platform is not directed at and not intended to be used by children under the age of 18 years. If you are aware that we have collected any personal information or data from a child under the age of 18 years please let us know by contacting us at support@EnosisTherapeutics.com, and we will delete that information or data immediately.

Data access and deletion 

Subject to certain limits and conditions provided under applicable laws, we honour the exercise of the right of access or deletion for all of our users, regardless of their location. Any Enosis Therapeutics user may exercise this right by contacting us at support@EnosisTherapeutics.com.

Information for individuals in Switzerland, UK and the EEA 

This section applies to you if you use our Platform while in Switzerland, the United Kingdom or the European Economic Area (collectively, “Europe“). Enosis Therapeutics is the data controller for personal data governed by this Privacy Policy. 

Legal basis for processing 

When we utilise your Personal Information we will only do so in the following situations: 

• as necessary to perform our responsibilities under our contract with you such as processing payments and providing the Products or Services (including data analytics) that you have requested; 
• when we have a legitimate interest in processing your Personal Information, including communicating with you about changes or modifications to our Platform, to help secure and improve our Platform (including prevention of fraud) and to analyse the use of our Platform; 
• as necessary to comply with our legal obligations; and 
• when we have your express consent to do so. 

Data Subject requests 

Subject to certain limits and conditions provided under applicable laws, you have the right: 

• to access your Personal Information we possess about you and to ask that your Personal Information be corrected, erased, or made available in a portable form; 
• to object to certain processing (such as receiving direct marketing), or request that we restrict processing in certain circumstances (such as to retain but not further process pending resolution of a claim); 
• to withdraw your consent at any time when we seek approval for your consent; and 
• to file a complaint regarding our data protection practices with a supervisory authority as mentioned below: 

Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en. 

If you are in Switzerland, please visit this FDPIC website for contact details: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html. 

If you are in the United Kingdom, please see this website for contact details: https://ico.org.uk/global/contact-us/. 

If you would like to exercise any of these rights and cannot do so directly through the above websites or your device, you may contact us at support@EnosisTherapeutics.com.

Data retention 

We will retain all your information and data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use all your information and data to the extent necessary to comply with the rules and regulations under the applicable laws, 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 the Platform, our Products and Services or we are legally obligated to retain this data for longer time periods.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any given time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our Site or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Platform, our Products and Services after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to contact us 

You can contact us via email at support@EnosisTherapeutics.com or at Enosis Therapeutics Pty Ltd at 2 Gwynne St Ground Floor, Cremorne VIC 3121.