Say66 Pty Ltd (ABN 97 640 147 299) (“Say66”, “us” or “we”) owns and operates the website at url www.say66.com (the Website) and the application “Say Bananas!” (App). Say66 is committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and in accordance with other applicable privacy laws.  This Privacy Policy explains how we manage the personal information and sensitive information that is collected, used, disclosed and stored about you and/or the children in your care.

About Say66

Say66 is an Australian company which provides a digital platform offering children access to speech therapy games and which allows speech pathologists to remotely assign speech exercises within these games and monitor children’s progress. At Say66, we’re revolutionising speech therapy by making it more accessible and fun.

What is personal information?

“Personal information” means information or an opinion that is capable of reasonably identifying you, whether that information or opinion is true or not and whether the information or opinion is recorded in a material form or not. Personal information may include your name, age, gender, postcode and contact details, as well as sensitive information.

“Sensitive information” includes, for example, the following:

  • health information, such as details of your medical history;
  • your genetic and biometric information; and
  • information or an opinion about your racial or ethnic origin, membership of a professional association, trade association or trade union or your religious beliefs (which is also personal information). 

Say66 collects personal information and sensitive information.

What personal and sensitive information do we collect?

Say66 collects the following information from users of the App, which may include parents/guardians (and minors) as well as speech pathologists:

  • full name;
  • post code;
  • email address;
  • age and gender;
  • first language;
  • the name of the user’s speech pathologist and his/her email address; and
  • recordings of the user’s speech, which are made during the user’s use of the App.
  • type of speech disorder

When creating an account to use the App, we also collect you/your child’s preferred accent for English (for example Australian, US or Cantonese).

If you are interested in working with us, we may collect:

  • your full name;
  • contact details (such as address, phone number and email address);
  • employment history and education details; and
  • details of referees.

How do we collect personal information?

We may collect personal and/or sensitive information from you in variety of ways, including:

  • when you download the App and create a user account (for you or a child in your care);
  • if you apply for a position with us (as an employee or contractor);
  • when you visit the Website and any other webpages that we own and/or manage, including our social media webpages such as Facebook and LinkedIn;
  • when you manage/change your user information;
  • if you participate in research we conduct including when you provide feedback about you/your child’s use of the App and any new speech therapy games we may develop; and
  • if you contact us by phone, email, post or via our Website or Appenquiry forms.

Where a user is a minor, we will collect user personal information from their parent or guardian.

Why do we collect your information and how do we use it?

Say66 may collect and use your (or your child’s) personal and/or sensitive information for the purposes of providing you (and/or your child) with our services and for our internal business purposes.  These purposes include (but are not limited to):

  • registering, setting up and managing user accounts;
  • evaluating user performance and providing feedback to the user and their nominated speech pathologist;
  • evaluating patterns of usage by age, gender and location (for example, urban / rural / remote) for research and development purposes;
  • evaluating and improving performance of speech recognition engines for both Australian-accented and non-Australian accented English for research and development purposes;
  • responding to your questions, comments, requests and complaints and to otherwise provide customer services;
  • the prevention of fraud and/or identifying and investigating any suspicious use of our Website, App and/or services;
  • to assess a candidate’s suitability for employment or engagement as an independent contractor, including conducting due diligence as part of pre-employment screening;
  • for our internal business and management processes, for example accounting or auditing purposes;
  • for any other purpose to allow us to comply with our obligations under law; and
  • for any other purposes that would reasonably be expected by you.

We may use de-identified or anonymised data (information which does not identify you or your child) for the purposes of:

  • monitoring patterns of usage
  • testing the technology’s performance (e.g. speech recordings may be used for generating improvement in the user and to analyse the accuracy of the user’s speech attempts, as well as to iteratively test the performance of updates to the speech recognition engines. Recordings will be de-identified.

The results of these tests, technology assessments and user data statistics may be published in scientific journals or used for marketing our products or services. Only de-identified, aggregated data are used.

Who will we disclose your information to?

Say66 may disclose your personal information (and/or sensitive information, where permitted) to third parties as follows:

  • to the users’ account holder, which may be the parent/carer of a child using the App;
  • to users’ nominated speech pathologists;
  • third party service and content providers, agents, contractors, advisors and suppliers who assist us in managing our business or operating our Website and App, for example, business support services, payment processors, webhosting service providers, software developers, cloud storage providers etc;
  • our professional advisors including lawyers, accountants, tax advisors and auditors;
  • law enforcement bodies to assist in their functions, courts of law or as otherwise required or authorised by law; and
  • regulatory or government bodies for the purposes of resolving customer complaints or investigations.

Overseas disclosure

Personal information and sensitive information is not disclosed ordinarily to overseas recipients.

Direct Marketing

Say66 does not use personal information for the purposes of marketing our services or the services of the third parties.

How do we secure and protect your personal and sensitive information?

We take such steps as are reasonable in the circumstances to maintain the integrity of your personal and sensitive information and to store it securely to protect it from interference, misuse and loss and from unauthorised use, access, modification or disclosure. 

In order to protect your personal and sensitive information, we have undertaken a thorough audit of the technological requirements for maintaining the security of this information in line with Australian privacy legislation. All data are processed and stored in Australia.

Data in transit (between users and Say66) are protected with Secure Socket Layer(SSL) / Transport Layer Security (TLS), which provides privacy (through encryption) as well as authenticity of the communicating server, which protects against impersonation.Wherever possible, more advanced protective methods are also employed.

Despite the above measures, please note that we cannot guarantee the security of your personal information.

To the extent permitted by law, Say66 takes reasonable steps to destroy or permanently de-identify personal and sensitive information if it is no longer needed for any purpose under this Privacy Policy, except in circumstances where we are required or authorised to retain this personal and/or sensitive information (including as a result of the operation of tax, health, financial services or other applicable law).

Cookies

We may collect personal information about you (and/or your child) when you (and/or your child) use and access our Website and App. While we do not use browsing information to identify you (or your child) personally, we may record certain information about use of the Website and App, such as the pages or screens visited, the time and date of the visit and the internal protocol or IP address assigned to the computer or device.

Our Website and App also use cookies or similar tracking technologies to help us track Website and/or App use and remember user preferences. Cookies are small files that store information on your computer, mobile phone or other device. A cookie enables the entity that put the cookie on your device to recognise you when you use different websites, devices and/or browsing sessions.

You can disable cookies through your internet browser. However, our Website and App may not work as intended if you do so.

We may also use cookies to collect data that may include personal information, for example, where a cookie is linked to your user account. Where we collect personal information via cookies, the personal information will be handled in accordance with this Privacy Policy.

Third Party Links

Our Website may contain links to websites operated and maintained by third parties over which we have absolutely no control.  These third party websites are not subject to this Privacy Policy or our privacy standards and procedures. Any information you provide to third party websites will be governed by the terms of the websites’ privacy policies. We have no responsibility or liability whatsoever for the content, actions or policies of third party websites. The inclusion of third party links on our Website in no way constitutes an endorsement of such websites’ content, actions or policies.  

Accuracy and requests for access and correction of personal and sensitive information

You are entitled to access your (and/or your child’s) personal and sensitive information held by Say66 on request. To request access to your (and/or your child’s) personal and sensitive information, please contact our Privacy Officer using the contact details set out below.

You will not be charged for making an access and/or correction request but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.

We will take reasonable steps to ensure that the personal and sensitive information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.

However, if you consider any information we hold about you (or your child) is inaccurate, out-of-date, incomplete, irrelevant or misleading, you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct the information. Alternatively, you may be able to update your contact information, for example, by logging into your account.

We may decline your access and/or correction request in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal (or sensitive) information about the requested correction.

Complaints

You may contact Say66 at any time if you have any questions or concerns about this Privacy Policy or about the way in which your (and/or your child’s) personal or sensitive information has been handled.

You may make a complaint about privacy to the Privacy Officer using the contact details set out below.

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint.

Your complaint will then be investigated. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within a reasonable time, usually within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.

If you are not satisfied with our response to your complaint, or you consider that Say66 may have breached the Australian Privacy Principles or the Privacy Act, you may make a complaint to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.

Changes to Our Privacy Policy

Say66 reserves the right to make changes to this Privacy Policy from time to time.  We will publish any changes to the Privacy Policy on our Website and App. We encourage you to review the Privacy Policy regularly for updates and amendments. 

Contact Details

If you have any questions or comments about this Privacy Policy, please contact us:

Privacy Officer

Say66 Pty Ltd

Email: privacy@say66.com