Introduction
This Privacy Policy applies to Vigil Monitoring Limited, trading as Jupl and referred to as Jupl within this policy. It sets out how we will collect, store, use and disclose your information and how we will meet our privacy obligations under applicable privacy legislation, including the New Zealand Privacy Act 2020, New Zealand Health Information Privacy Code 2020, Australian Privacy Act 1988, the Australian Privacy Principles Guidelines 2015 and other relevant legislation and guidelines.
This Privacy Policy should be read in conjunction with the Terms and Conditions document. By agreeing to the Terms and Conditions, and installing and using a Jupl Product, you give consent for us to collect information from you (potentially including alarm calls, physiological or environmental data) and to hold, use and disclose that information as set out in this Privacy Policy.
In the context of this policy, “we” refers to Vigil Monitoring Limited (Jupl), and “our” and “us” have the respective meanings.
By “the Jupl System” or “Product” we mean the technology package provided by us, either directly or through a support organisation.
By "support organisation" we mean an organisation that supplied Jupl Products to you and that has the primary relationship with you, e.g. the provider of your medical alarm service.
By "wearers" we mean users of Jupl wearables and other wearables which are connected to the Jupl Gateway or VBN.
By "carers" we mean those who are actively involved in the support of a wearer and who have access to information about the wearer through the Jupl system.
By "Jupl community" we mean the group of enthusiastic individuals who are willing to provide feedback on Jupl products. The information they provide feeds into the Jupl product development process. It is used to validate Jupl products by providing indirect and direct feedback on physical, digital and service aspects of the user experience.
By "anonymised" we mean that information cannot be reconstituted in such a way that it can be related to you.
Personal information we collect
Information we may collect from you includes:
Contact details
Demographic information
Location of wearer
Data collected by one of our Products or third party products connected to our System, including alarm calls, physiological, environmental (ambient temperature, humidity, light) and other data.
Information entered into our System, e.g. your name and address, entered when a Gateway is installed in your home.
Information you give us regarding relationships between yourself and other wearers or carers about whom we hold information.
If you are a member of the Jupl community, information that you choose to share with us through interviews or surveys. This may include information about family relationships, your health and that of family members and other information about your personal situation.
We use common internet technologies such as cookies and may store your IP address.
How your personal information is used
Jupl websites
If you visit an unsecure area of our website (that is, an area where you are not required to log on) to read, browse or download information, our system may record the date and time of your visit to our site, the pages viewed, any information downloaded and your region. However, our record will not identify you.
IP Address
It is necessary for us to collect your IP address for your interaction with various parts of the website. Your IP address is the identifier for your computer when you are using the internet. For instance, we collect and store your IP address when you log into the Jupl System. As part of our security, we use this information when we attempt to detect and prevent fraudulent access to our systems. We store your IP address for security, audit and reporting purposes. Your IP address will not be used by us or released to any third party except in the case of security, inappropriate behaviour or fraud issues, such as unauthorised access to your, or our, computer systems.
Cookies
We use cookies as part of our interaction with your Internet browser. The purpose is to provide you with better and more customised service and a more effective website. A cookie is a small text file that can be stored on your computer, tablet or phone when you visit a website. A web server sends you a cookie and your browser accepts it. The browser then returns the cookie to the web server next time you visit that particular website. You can choose if and how a cookie will be accepted by configuring your preferences and options in your browser.
Please note that if your browser is configured to reject all cookies you will be unable to use services on our website that require cookies in order to participate. Those services may include surveys. You may still be able to use some information-only pages even if you do not accept cookies.
Analytics
We use third party analytics to monitor and measure activity on our websites. We may record information about visitors and what they do to improve your experience of our websites. This information is anonymised.
Links to third party websites
Our website contains links to other websites operated by third parties and may include social media features such as Facebook and Twitter buttons (such as “Like,” “Tweet” or “Pin”). These third party sites may collect information about you if you click on a link and the social media sites may automatically record information about your browsing behavior every time you visit a site that has a social media button. Your interactions with these features are governed by the privacy policy of the company providing the feature, not by our privacy policy. We do not control what information these third parties collect. Please review your privacy settings on your social media sites and think carefully before clicking on links which may take you to a third party website.
Your contact information
You may give us contact information because you are interested in our Products. If you give us your contact information for this purpose, we may use it to respond to you with product and sales information.
Jupl Products
Jupl Products may collect information about medical alarms, environmental conditions, location and physiological parameters of wearers. The Jupl System may provide timely information to employers and carers on the well-being of their employees, family members, friends in order to improve communication and flows of health and social related information to improve support and care for wearers.
Messages sent by the Jupl System using SMS technology (texts to mobile phones) are transmitted in an unencrypted format across the normal operator networks. While we are careful, Jupl cannot guarantee the privacy or timing of any such message.
Jupl Community
Information provided by members of the Jupl Community as part of the product development process, including surveys and interviews, is used to develop and improve Jupl Products by providing indirect and direct feedback on the physical, digital and service user experience.
Within Jupl, your information in an identifiable form will only be accessible to the people who are involved in collecting it. When information derived from the product development process is shared with other people, you will not be personally identified.
Disclosure of your information
We will not disclose your information to anyone besides you (or someone authorised by you) unless that is what we have collected it for, e.g. to send an alarm to an alarm monitoring centre or to share with your support organisation who need the data to manage the service, or in the unlikely event that we are legally required to disclose the information. We will ensure that your information is protected as much as possible from any disclosure beyond what is necessary for the purpose.
Aggregation and anonymisation
If your information is used for statistical, regulatory reporting or academic purposes, it will first be anonymised and used in aggregate form. It will not personally identify you or allow any means of you being identified.
Commercial use
We do not share personal information for any commercial or marketing purpose unrelated to the delivery of Jupl Products and services. We do not rent or sell our customer lists.
Security of your information
Your responsibility
You are responsible for protecting your user name and password. If you are a carer and you share your login details, the person you share with will have access to the wearer's personal information and you may be responsible for breaching the wearer's privacy.
Looking after your information
We will store your information properly and protect it so as to avoid loss or unauthorised access, use, modification, or disclosure. This includes standard information security measures, such as data encryption, secure storage and destruction of printed documents, and careful monitoring of access to premises. We only provide wearer and carer information to those people and support organisations who require it in order to fulfil the purpose of the data’s collection. Disclosure beyond this purpose is prevented.
Storage of data in Australia
The Jupl System stores information about all users in Australia.
Your rights and choices
You have the right to access, correct or request correction of your personal information, except where the information held is not readily available, or where excepted by law.
Subscribers
Please contact your support organisation or us as soon as possible if any of your contact information changes.
Opting Out
While the benefits to you as a wearer or carer are dependent upon your providing us with information, including through use of the Jupl system, you are not obliged to provide information.
You may choose to stop providing information at any time by discontinuing use of the Jupl Products, subject to the terms and conditions agreed upon with your support organisation, and agreements between yourself and other family members or medical professionals involved in the use of your System.
If you stop using the Jupl System or any part of it, Jupl takes no responsibility for discrepancies in medical care or support, or any penalties imposed by support organisations.
Jupl Community
If you have consented to take part in testing of any component of the Jupl System, you may withdraw from the testing process at any time.
Contacting us
For more information, or to make an enquiry or complaint about the privacy of your information held by Vigil Monitoring Ltd (Jupl), please contact the Privacy Officer at privacy@jupl.com.