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. Click here to find out more about Sahha!

This Privacy Policy describes how Sahha Pty Ltd ABN 26 649 986 505 (we, our, us) manages personal information about individuals whose data is collected and processed by us that we receive from Third Party Apps and providers of Third Party Apps (Third Party App Providers).

Sahha provides Third Party Apps with certain functionality that processes End User behavioural data collected from an End User’s mobile phone sensors and/or native software such as Apple HealthKit or Google Fit in order to allow the Third Party App to provide services based on that data (the Services).

WE DO NOT PROVIDE ANY MEDICAL ADVICE, RECOMMENDATIONS OR DIAGNOSES. WE RECOMMEND THAT YOU SEEK ALL NECESSARY MEDICAL ADVICE, RECOMMENDATIONS OR DIAGNOSES FROM YOUR HEALTHCARE PRACTITIONER. WE DO NOT PROVIDE, OR REPRESENT THAT WE PROVIDE, ANY MEDICAL SERVICE AND WE ARE NOT A PARTY TO ANY CONTRACT FOR THE PROVISION OR RECEIPT OF ANY MEDICAL SERVICE. FURTHER, WE DO NOT REPRESENT OR WARRANT THAT SAHHA WILL RESULT IN THE DIAGNOSIS, DETECTION, CURE OR PREVENTION OF ANY BEHAVIOURAL, PSYCHOLOGICAL, MENTAL OR OTHER MEDICAL DISORDER OR ILLNESS.

We are committed to complying with our privacy obligations in accordance with all applicable data protection laws, including the Australian Privacy Principles contained in Schedule 1 to the Privacy Act 1988 (Cth) (each, an APP), the Privacy Act 2020 (New Zealand) (Privacy Act (New Zealand)) and the Information Privacy Principles contained in Part 3 of the Privacy Act (New Zealand (each, IPP). If we decide to change this Privacy Policy, we will post the updated version on this webpage. Our policy is to always be open and transparent about our privacy practices.

Details about how we collect and process personal information collected from our New Zealand End Users is set out at the end of this Privacy Policy.

1    Consent

1.1   Third Party App Providers are required to comply with all applicable privacy laws.

1.2   We rely on Third Party App Providers to obtain the relevant privacy consents and authorisations required by law in order for the personal information that is entered by End Users into Third Party Apps to be collected, disclosed and otherwise processed by us. We provide Third Party App Provider with a template collection notice made under APP 5 for them to issue to their End Users as part of their End Users’ registration of an account with the relevant Third Party App. We do not verify any document signed between the Third Party App and their End User however, we require Third Party Apps to electronically verify that they have obtained their End User’s consent to the collection and processing of End Users’ personal information by us.

1.3   Third Party App Provides may not use personal information that is processed about their End Users via Sahha without obtaining all consents required by applicable law.

1.4   We rely on Third Party Apps to ensure that all information collected from End Users and held by us is accurate, up to date, complete, relevant and not misleading.

1.5   We encourage Third Party Apps to ensure that their End Users are familiar with their privacy policies so that their End Users understand how the Third Party App will collect, use and otherwise process personal information about them, via Sahha or otherwise.

2   The types of personal information we collect and hold about end users

2.1   We collect and hold the following types of personal information:

• Demographic data, including age, gender, weight, income range and other information inputted by End Users via Third Party Apps, which may include health and other sensitive information;
• Behavioural data, including GPS, heart rate and steps data collected by the Third Part App via the End User’s mobile device, which may include health and other sensitive information; and
• personal information, including health information, about the End User generated by Sahha’s algorithms such as information about the End User’s apparent health as determined by those algorithms, which may include health and other sensitive information.

3   How we collect personal information

3.1   Our policy is to not collect personal information by means that are unfair or unreasonably intrusive in the circumstances. We only collect personal information that is necessary to provide the functionality of Sahha and to otherwise operate our business.

3.2   We collect personal information, including health information, about End Users when it is transmitted to us via a Third Party APp in accordance with our obligations pursuant to a contract in place with the Third Party App Provider. This includes personal information entered by the End User into the Third Party App, End User behavioural data made available to the Third Party App by an End User via their mobile device, and when an End User voluntarily discloses personal information to the Third Party App (via the Third Party App, telephone, surveys, e-mail, online forms or otherwise).

3.3   Third Party Apps are responsible for ensuring that all End User consents and authorisations have been obtained or provided by them as required by law for the lawful collection of personal information that we collect from them

3.4   In the first instance, we do not directly collect personal information from End Users. Third Party App Providers are responsible for the lawful collection of their End User’s personal information. We receive an End User’s personal information from the Third Party App via our software development kit integrated into the Third Party App.

3.5   We collect information about Third Party Apps and their personnel when they voluntarily disclose it to us or when we collect it about them when they use Sahha. We collect personal information about Third Party Apps and their personnel when they enter into a contract with us, when they activate their account on Sahha, complete an online purchase via our online store, contact us for technical support and when they otherwise provide it to us.

4   How we use personal information

4.1   How we use personal information about End Users is set out in the following table: