Privacy Policy

Introduction

Welcome to Positive Medicine

At Positive Medicine, we believe in empowering each individual on their journey towards whole person health and healing. Your trust and safety are at the heart of our business, and we understand that this includes responsibly managing and protecting the personal information you share with us.

This privacy policy is not just a legal requirement for us; it’s a vital part of our commitment to transparency and respect in all our interactions. Here, we explain in clear and straightforward language how we collect, use, and protect your data. Whether it’s the health data from your wearable devices or the personal goals you set in our app, we handle every piece of information with the utmost care and consideration.

Our aim is not just to comply with privacy laws, but to foster a space where you feel confident and secure in sharing your journey with us. We believe that understanding and trust are the foundations of any strong community, and we’re dedicated to upholding these principles in every aspect of Positive Medicine, The Positive Medicine Academy, The Positive Medicine Community and Improving Me.

As you read through our policy, remember that this is a collaborative effort. We encourage you to reach out if you have questions, need clarifications, or have suggestions on how we can improve. Together, we can ensure that Improving Me and Positive Medicine platforms remains a safe, supportive, and empowering environment for everyone.

Thank you for being a part of our community. Let’s continue to grow and improve, together.

What Information we Collect and Process

Personal Contact Details:

If you create an account with us, your name, phone number, and email address are vital for us to create your unique account and ensure secure access. We use these details to contact you and provide a two-factor authentication mechanism, enhancing the security of your account and personal information.

Epidemiological Data:

  • Types of Data: This includes your date of birth, gender, and location.
  • Purpose: These details help us to understand you better and tailor the Improving Me experience to your unique needs. They also assist us in generating insights and providing more relevant and personalized guidance.

Personal Contact Details:

  • Insurance or Employer Information: Context of Collection: If your access to Improving Me or the Positive Medicine Academy is provided through an insurance provider or your workplace, we collect relevant details to verify and facilitate this access.
  • Purpose: This information ensures that you receive the benefits and features specific to your organization’s arrangement with the Positive Medicine Academy and Improving Me.

App-Provided Information: Your ‘Hero’s Journey’

  • User-Generated Content: This encompasses the information you input directly into the app as part of your “Hero’s Journey” – including your journey map and personal goals.
  • Tracking Progress: We also collect data on your progress towards these goals.
  • Purpose: By understanding your journey and goals, we can offer more personalized support and insights, helping you stay on track and motivated.

Standardised Assessment Tools

  • Data Collection: As you use various standardised tools within the app to support your Hero’s Journey, we collect the data generated from these interactions.
  • Purpose: This information is crucial for us to provide you with tailored advice, measure your progress, and enhance your journey towards self-improvement.

Wearable Tracking Data

  • Types of Data Collected: This includes data from wearable devices such as physical activity levels, sleep patterns, and other health metrics.
  • Purpose: By integrating this data, we gain a comprehensive view of your health and vitality, allowing us to offer more nuanced and effective guidance. We are also able to support your understanding on how, for instance, sleep may impact on your emotional or psychological health, and how some of the psychological health tools you may have implemented impact on your physical stress levels through your HRV readings. The choices you make and the actions you take in each pillar of your health, impact on your physical health, and over time, the numbers you are tracking will show you the positive outcomes you are making on your own health through the positive choices that you have made.

In every aspect of data collection and processing, we are committed to transparency and respect for your privacy. We collect only the information necessary to provide you with a valuable and personalized experience on Improving Me. Our goal is to support you in your journey while ensuring the highest standards of data privacy and security. If you have any questions or need further clarification about the data we collect and how we use it, please don’t hesitate to reach out to us.

Sharing your Data from the Improving Me App

At Improving Me, we believe in the power of collaboration and community. However, we also understand the importance of privacy and are committed to handling your data with care and responsibility. Below, we outline how and why we share your data with certain third parties.

Sharing with Mighty Networks:

  • Data Shared: Only your name and contact details.
  • Purpose: This sharing enables you to join the Improving Me Community, which is hosted on Mighty Networks through our app.
  • Privacy Policy: For more information on how Mighty Networks handles data, please refer to their privacy policy here.

Use of Third-Party Platform: Intervengine:

  • Data Handling: Data collected through our app is securely stored on Intervengine, an ISO27001 certified platform.
  • Processing: Once on Intervengine, your data is anonymized and aggregated before being transferred for analysis.

Analysis by Positive Medicine Limited:

  • Data Transfer: Anonymized and aggregated data is shifted to Databrix for analysis.
  • Analytical Use: This data is used by Positive Medicine Limited, the parent company of Improving Me, to enhance user engagement, experience, and the overall development of the Improving Me product.
  • Further Application: The insights gained are also used to inform the development of Positive Medicine (www.positivemedicine.com), a pioneering field in healthcare. This includes training healthcare professionals through the Positive Medicine Academy to adopt the Positive Medicine model of care, integrating Whole Person Health and Healing practices into medical science.

Recruitment of Expert Data Analysts:

  • Purpose: We may recruit expert data analysts to delve deeper into the data, aiming to continuously improve our services and products.

Employer-Provided Program Participants:

  • Data Collection: For participants provided access to our program by their employer, certain standardized assessment tool data is collected, anonymized, aggregated, and shared with the employer.
  • Specificity and Consent: These specific tools and their data sharing practices are clearly noted within the app at the start of the assessment.
  • Purpose: This is done to provide employers with insights for the collective well-being of their workforce while maintaining individual privacy.

Your privacy is our priority. We share data only for purposes that align with our mission of fostering positive change and improving health outcomes. Each step in this process is conducted with the highest standards of data privacy and security. If you have any questions or concerns about how your data is shared, please feel free to reach out to us for further clarification.

International Data Transfer

At Improving Me and Positive Medicine, we are committed to managing your data with the utmost care and in compliance with the highest standards of data privacy. As part of our international operations, especially between New Zealand and Australia, it is necessary for us to transfer data across borders. Below, we detail our practices and commitments in relation to international data transfer.

Compliance with New Zealand and Australia Data Privacy Laws

  • Our Foundation: Positive Medicine is based in New Zealand and adheres strictly to the legal requirements of data privacy in both New Zealand and Australia.
  • Cross-Border Operations: In our effort to provide seamless services across both countries, we transfer data between New Zealand and Australia.

Safeguarding Your Data During Transfer

  • Data Protection Measures: We employ robust security measures and protocols to ensure the safety and integrity of your data during these transfers.
  • Legal Compliance: Every transfer of data is conducted in full compliance with the relevant data protection regulations of both New Zealand and Australia.

Purpose of Data Transfer

  • Operational Necessity: The transfer of data is essential for the smooth operation of our services and for providing you with a consistent and high-quality experience, regardless of your location in these countries.
  • Ensuring Service Continuity: By transferring data, we can ensure that all users, whether in New Zealand or Australia, receive the same level of service and support.

Our Commitment

  • Transparency: We are transparent about our data transfer practices and the reasons behind them.
  • User Rights: We respect your rights regarding your personal data, including your rights to access, correct, or delete your data, irrespective of the country in which the data is stored or processed.

Should you have any concerns or require further information about how we handle international data transfer, please do not hesitate to reach out to us. Our commitment to your privacy and data security remains our top priority, across all borders.

How we Store and Secure Personal Data

At Positive Medicine, the security and privacy of your personal data are paramount. We take rigorous measures to ensure that all information you share with us is stored securely and handled with the utmost care. Here’s how we manage the storage and security of your data across different platforms:

Storage in Mighty Networks

  • Community Interaction Data: Your interactions within the Improving Me community and the Positive Medicine Academy are stored on Mighty Networks.
  • Analysis via Google Analytics: This data is analysed through Google Analytics, as per Mighty Networks’ privacy policy, to understand how members engage with the community. We use these insights to enhance the community experience.
  • Mighty Networks’ Privacy Policy: For detailed information on how Mighty Networks handles and secures your data, please refer to their privacy policy available here.

Storage through Intervengine

  • Personal Journey, Health, and Wearable Data: All data related to your personal journey mapping, health metrics, and wearable device data, along with your goal-setting information, are securely stored through Intervengine.
  • Intervengine’s Security Measures: Intervengine is committed to high standards of data security. The Intervengine platform, all data pipelines and integrations, and all tools used are subject to regular security and privacy reviews.

Anonymized Data Storage in Databrix

  • Post-Processing Storage: Once your data is anonymized and aggregated, it is stored in Databrix.
  • Purpose of Anonymization: This process ensures that your personal identity is not associated with the data when it is used for analysis and improvement of our services.

Our Security Practices

  • Robust Security Measures: We employ state-of-the-art security measures to protect your data against unauthorized access, alteration, disclosure, or destruction.
  • Regular Reviews and Updates: Our security protocols are regularly reviewed and updated to stay ahead of emerging threats and to comply with the latest security standards.
  • Transparency and Responsibility: We are transparent about our data storage and security practices and take full responsibility for the protection of your data.

Your trust in us is our most valuable asset, and we are committed to maintaining that trust through rigorous data security and privacy practices. If you have any questions or concerns about how we store and secure your personal data, please feel free to reach out to us for further clarification.

Cookies and Similar Technologies

In our commitment to transparency and to ensure you have a clear understanding of our practices, this section outlines how we use cookies and similar technologies, particularly in relation to our use of Mighty Networks and on the websites of Positive Medicine and Improving Me.

Use on Mighty Networks

  • Purpose: Cookies and similar technologies are used within the Mighty Networks platform to enhance your experience in the Improving Me community and the Positive Medicine Academy. These technologies help in maintaining your session, personalizing content, and understanding user interactions within the community.
  • Mighty Networks’ Policy: For specific details on how cookies are used on Mighty Networks, please refer to their privacy policy here.

Use on Our Websites

  • Application: On the Positive Medicine and Improving Me websites, we use cookies and similar technologies primarily for analytics purposes.
  • Google Analytics: These technologies enable us to integrate with Google Analytics, allowing us to understand how visitors interact with our websites. This data helps us improve user experience, track website performance, and make informed decisions about content and design.
  • Control by Users: We respect your choice and control over your data. You will be prompted to give consent for the use of such technologies when you visit our websites. Additionally, you can manage your preferences through your browser settings.

Understanding Cookies and Similar Technologies

What Are Cookies? Cookies are small text files stored on your device by a website. They are widely used to make websites work more efficiently, as well as to provide information to the site owners.

  • Types of Cookies: We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device for a set period or until you delete them).

Our Commitment

  • Privacy and Security: We ensure that the use of cookies and similar technologies on our platforms complies with relevant privacy and data protection laws.
  • Transparency: We are committed to being transparent about our use of these technologies and the purposes they serve.

If you have any questions or concerns about our use of cookies and similar technologies, please do not hesitate to contact us. We are committed to ensuring that your experience with Improving Me and Positive Medicine is both enriching and respectful of your privacy.

Your Privacy Rights and Choices

At Positive Medicine, we not only respect your privacy, but we also empower you with control over your personal information. This section outlines the rights and choices you have regarding your data, ensuring that you remain informed and in control.

Access to Your Information

  • Right to Access: You have the right to access the personal data we hold about you. This includes understanding what data is being processed, why it is being processed, and who it is shared with.
  • Request Process: To request access to your data, please contact us through the designated channels provided in our app or on our website.

Correction and Updating Your Information

  • Right to Correct: If you believe that any information we hold about you is inaccurate or incomplete, you have the right to request a correction.
  • Updating Information: You can also update your personal information directly through the app or by contacting us.

Data Portability

  • Right to Data Portability: You have the right to request a copy of your personal data in a structured, commonly used, and machine-readable format.
  • Transfer of Data: You can also request the transfer of this data to another service provider, where technically feasible.

Deletion of Your Information

  • Right to be Forgotten: You can request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent (where consent was the legal basis for processing).
  • Process for Deletion: To initiate a request for data deletion, please reach out to us through the contact information provided.

Objection to Processing

  • Right to Object: You have the right to object to the processing of your personal data, particularly for purposes of direct marketing, research, or statistical purposes.

Withdrawal of Consent

  • Revoking Consent: If we are processing your data based on your consent, you have the right to withdraw that consent at any time. This does not affect the lawfulness of processing based on consent before its withdrawal.

Automated Decision Making and Profiling

  • Right to Opt-Out: You have the right to opt-out of decisions based solely on automated processing, including profiling, that have legal or similarly significant effects on you.

Complaints to Authorities

  • Right to Lodge a Complaint: If you believe that our processing of your personal data infringes on data protection laws, you have the right to lodge a complaint with a supervisory authority responsible for data protection in your country.

Our Commitment to Your Rights

  • Respecting Your Choices: We are committed to respecting your choices and ensuring that exercising your rights is as easy as possible.
  • No Adverse Effects: Exercising your privacy rights will not result in any negative consequences or a diminished service experience.

For any questions, or to exercise any of your rights, please contact us directly through the app or our website. Our team is dedicated to assisting you and ensuring that your rights are upheld.

Data Protection Officer

To ensure the highest standards of data privacy and compliance, Positive Medicine has appointed a Data Protection Officer (DPO). Our DPO is responsible for overseeing our data protection strategy and ensuring that we are consistently upholding our commitment to the privacy and security of your personal information.

Data Protection Officer Contact Details:

  • Name: Gayle Snyders
  • Email: Email Gayle
  • Postal Address: Positive Medicine, PO Box 331, Cromwell, 9342, New Zealand

Role of the Data Protection Officer:

  • Overseeing Compliance: The DPO monitors our compliance with data protection laws, advises on data protection obligations, and acts as a contact point for data protection authorities.
  • Handling Inquiries and Concerns: If you have any questions about how we handle your data, concerns about your privacy rights, or any related matters, our DPO is available to assist you.
  • Privacy Advocacy: The DPO ensures that all our data processing activities are conducted in the best interest of your privacy and in accordance with legal requirements.

 

Other Important Privacy Information

This section encompasses additional essential information about our privacy practices. These details are vital for your comprehensive understanding of how we manage and protect your personal data at Positive Medicine.

No Sale of Data

  • Commitment to Privacy: We want to reassure you that we do not sell your personal data to anyone. Protecting your privacy and maintaining your trust are core to our values.

Changes to Our Privacy Policy

  • Updates and Revisions: We may occasionally update or revise our privacy policy to reflect changes in our practices, legal requirements, or technological advancements.
  • Notification of Changes: Significant changes to our privacy policy will be communicated to you through our app, website, or via email, as appropriate.
  • Regular Review: We encourage you to review our privacy policy periodically to stay informed about how we are safeguarding your data.

Third-Party Links and Services

  • External Links: Our app and website may feature links to third-party websites or services. Please note that we are not responsible for the privacy practices of these external entities.
  • Due Diligence: We recommend that you review the privacy policies of any third-party sites you access from our platforms, as their policies may differ from ours.

Data Retention

  • Retention Period: Your personal data is retained only for as long as necessary to achieve the purposes mentioned in this privacy policy, or as required or allowed by law.
  • Data Disposal: Once the data is no longer needed, we will either anonymize it or securely delete it.

Children’s Privacy

  • Age Limitation: Our services are not intended for children under the age of 13. We do not knowingly collect personal information from children under this age without parental consent.
  • Parental Involvement: If you believe we have mistakenly collected information from a child under 13 without proper parental consent, please contact us immediately so we can address the issue.

Contact Us

  • Open Communication: For any inquiries, concerns, or feedback regarding our privacy practices, please feel free to reach out to us. We highly value your input and are committed to addressing your concerns.

We at Positive Medicine are dedicated to upholding the highest standards of privacy and data protection. This policy reflects our commitment to creating a safe and secure environment for all our users, with a particular emphasis on transparency and respect for your personal information.