This Privacy Policy applies to all personal information collected by The Violet Initiative Ltd ACN 143 224 293 and Violet Social Enterprise Pty Ltd ACN 669 153 539 (Violet, we, us or our) via the websites located at www.violet.org.au and www.meetviolet.ai or in conversation with our Violet Guides (the Platform and Services).
1. What information do we collect?
The kind of Personal Information that we collect from you will depend on how you use the Platform and Services. The Personal Information which we collect and hold about you may include:
Login or appointment booking credentials, including but not limited to: your name, email address, location (state or postcode), IP address, whether you are the Registered User of the Platform and Services for your own benefit or if you're acting as a Carer of someone else, their relationship to you, their preferred name, and a password for your account.
At various intervals we will ask you how you are feeling in general. And also more specifically how you are feeling about your ability to talk about and plan for the last stage of life, for yourself or in your carer role. We will store and track your responses over time as part of our effort to improve our services and measure how Violet is helping you to progress.
When interacting with the Violet Companion digital assistant, your conversational 'threads' are stored. These are de-identified before registration and partially identifiable once logged in. Digital Personal Information, such as email addresses, are not shared between Violet and OpenAI. Currently, while Open AI's API assistant technology is in beta, these threads are stored indefinitely. It's likely their storage policy will change to a 60-day storage period soon, after which Violet may indefinitely store the threads. This is done so that Violet Companion can recall previous conversations and prevent you from repeating them. We advise against inputting personal or sensitive data into the Violet Companion interface, such as contact details, usernames, or customer numbers. However, you can discuss delicate and sensitive topics, opinions, and personal circumstances with Violet because it's designed to handle such interactions securely.
OpenAI does not share or train its LLM on conversations with users of their API assistant technology. And OpenAI’s storage capability meets strict industry standards. You can read more about OpenAI’s Terms of Use and Privacy Policies in relation to the service provided via their API Platform here, here and here.
When speaking with a Violet Guide during a booked appointment, you should feel free to discuss and disclose whatever personal or private information you feel comfortable doing so. The sessions are completely private and confidential. We keep case notes for the duration of your relationship with a Violet Guide, and we record the sessions for quality and feedback purposes only.
Once you are logged in as a Registered User, the Platform will offer you the opportunity to input, upload and store content, data and detailed personal information about yourself or the person you are caring for. Including, but not limited to: personal identification, contact details, the names and contact details of key people in your life, your online usernames, customer and membership numbers for various service providers, government agencies, utilities, clubs, unions, employers, associations, evidence of your assets and liabilities, legal and financial documents, details of your final wishes or funeral plans, advanced care directives, and a range of other information about yourself or the person you are caring for. The Platform will not invite you to submit personal medical information. Nor will it invite you to enter or upload passwords.
If you make a donation to Violet via our third party partner GiveEasy, you may also provide credit card details and other information which will allow them to process your request and make the transaction. Read GiveEasy’s Terms & Conditions.
2. Types of information
The Privacy Act 1998 (Cth) (Privacy Act) defines types of information, including Personal Information and Sensitive Information.
Personal Information means information or an opinion about an identified individual or an individual who is reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.
If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “Personal Information” and will not be subject to this privacy policy.
Sensitive Information is defined in the Privacy Act as including information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive Information will be used by us only:
(a) for the primary purpose for which it was obtained;
(b) for a secondary purpose that is directly related to the primary purpose; and
(c) with your consent or where required or authorised by law.
3. How we collect your Personal Information
(a) We may collect Personal Information from you whenever you input or upload such content, data and information into the Platform, discuss such information in conversation with Violet Companion or a Violet Guide, or provide it to Us in any other way.
(b) We may also collect cookies from your computer which enable us to tell when you use the Platform and Services and also to help customise your experience. As a general rule, however, it is not possible to identify you personally from our use of cookies.
(c) We generally don’t collect Sensitive Information, but when we do, we will comply with Clause 3.
(d) Where reasonable and practicable we collect your Personal Information from you only. However, sometimes we may be given information from a third party (such as a Carer), in cases like this we will take steps to make you aware of the information that was provided by a third party.
4. Purpose of collection
(a) We collect Personal Information to provide you with the best service experience possible via the Platform, for the purpose of data analytics, and to keep in touch with you about developments in our business.
(b) We customarily only disclose Personal Information to our service providers who assist us in operating the Platform. Your Personal Information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties.
(c) By using our Platform, you consent to the receipt of direct marketing material. We will only use your Personal Information for this purpose if we have collected such information directly from you, and if it is material of a type which you would reasonably expect to receive from us. We do not use sensitive Personal Information in direct marketing activity. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature, such as an unsubscribe button link.
5. Security, Access and correction
(a) We store your Personal Information in a way that reasonably protects it from unauthorised access, misuse, modification or disclosure. When we no longer require your Personal Information for the purpose for which we obtained it, we will take reasonable steps to destroy and anonymise or de-identify it. Most of the Personal Information that is stored in our client files and records will be kept for the term of your registration and continued use in accordance with our Terms of Use and this Privacy Policy. Whilst we attempt to protect your personal data, no information provided over the internet is 100% secure and we cannot guarantee security, therefore you are disclosing personal information at your own risk.
(b) The Australian Privacy Principles:
(i) permit you to obtain access to the Personal Information we hold about you in certain circumstances (Australian Privacy Principle 12); and
(ii) allow you to correct inaccurate Personal Information subject to certain exceptions (Australian Privacy Principle 13).
(c) Where you would like to obtain such access, please contact us in writing on the contact details set out at the bottom of this privacy policy.
6. Complaint procedure
If you have a complaint concerning the manner in which we maintain the privacy of your Personal Information, please contact us via the details set out at the bottom of this policy. All complaints will be considered by Violet's Privacy Officer and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.
7. Overseas transfer
Your uploaded content and data will not be disclosed to recipients outside Australia unless you expressly request us to do so. If you request us to transfer any of your uploaded content or data to an overseas recipient, the overseas recipient will not be required to comply with the Australian Privacy Principles and we will not be liable for any mishandling of your information in such circumstances. When using the Violet Companion digital assistant, your conversational ‘threads’ are stored on servers located in the USA (de-identified pre-registration, identifiable when logged-in), currently indefinitely whilst Open AI’s API assistant technology is in beta. Our understanding is that this will likely shift to a 60-day storage period, at which point Violet may store the same threads indefinitely ourselves on servers located in Australia.
8. GDPR
In some circumstances, the European Union General Data Protection Regulation (GDPR) provides additional protection to individuals located in Europe. Where this is the case, there may be additional rights and remedies available to you under the GDPR if your Personal Information is handled in a manner inconsistent with that law.
9. How to contact us about privacy
If you have any queries, or if you seek access to your Personal Information, or if you have a complaint about our privacy practices, you can contact us through: info@violet.org.au
If you are not satisfied with our response, then you may lodge a formal complaint with the Office of the Australian Information Commissioner (for more information, please see www.oaic.gov.au).