Legend Land Privacy Policy

This is the Privacy Policy of NeuroGames Pty Ltd ACN 652 749 392 (NeuroGames, we, us, our) and applies to the management of personal information we collect and use in connection with our business, including via our websites https://www.neurogames.com.au and https://www.legendland.com.au (our Websites) and the Legend Land Multiplayer Server (Application). This Privacy Policy is intended to keep you information of the ways we collect, use, disclose, store and protect your personal information and help you understand your rights (and our obligations) under the Privacy Act 1998 (Cth) (Privacy Act).

Kinds of information that NeuroGames Pty Ltd holds

The kind of information that we hold about you depends on your relationship with NeuroGames and our business functions and activities. Personal information generally means information about an individual who is reasonably identifiable from the information. It does not include data where the identity has been removed and it is not possible to connect the data to the individual. The types of information we collect may include (but is not limited to):

User Information

Data we collect about how you use and interact with the Application and/or our Websites. If a user chooses to use, access or participate in Application therapy sessions, we collect the user’s Universally Unique Identifiers (UUID), information regarding character appearances or ‘skins’, Minecraft user account authentication, user display names, and miscellaneous statistics from Minecraft (Microsoft). If you use, access or participate in the Application and/or our Websites, we will collect information about that use. This might include minigames and player statistics during the sessions, rewards obtained during the game, account information, including email address, postal or residential address, contact number, username, and password, player progress during the game, and any data the user chooses to enter into the Application and/or our Websites.

Information about parents/guardians of users

We will collect information that a user's parent/guardian enters into the Application and/or our Websites, including account details, email address, postal or residential address and contact number and updates to reward charts.

Information about prospective employees

The information held on prospective employees includes resumes, cover letters, qualifications, contact details, and information collected from referees.

Information about service providers

The information held about contractors includes resumes, cover letters, qualifications and contact details, identification, and bank details for payment.

How users' personal information is collected

A user's personal information is collected in a number of ways by NeuroGames, including when: you use our Websites, the user provides information directly to NeuroGames using hardcopy and electronic forms, information that is entered into the Application by the user, when you correspondence with us in person, via telephone or email, when the user interacts directly with NeuroGames employees such as the receptionist, and as otherwise provided to NeuroGames through the course of NeuroGames conducting its business and providing you with access to our Websites and/or the Application.

Purposes of collecting, holding, using and disclosing personal information

As a general rule, we only process personal information for the purposes that would be considered relevant and reasonable in the circumstances. A user’s personal information, including information provided by your parent/guardian (where applicable), is gathered and used by NeuroGames for the purpose of providing you with access to and administering the Application, our Websites and other related products and services of NeuroGames, managing the Application, our Websites and those products and services, including account keeping procedures, communicating with you, complying with our legal and regulatory obligations and otherwise to manage our business. We use information provided by prospective employees to assess an application for employment, including by obtaining comments from the identified referees. We use information from our service providers to manage our business.

Consequence of not providing personal information

If the user does not wish for their personal information to be collected in a way anticipated by this Privacy Policy, NeuroGames may not be in a position to provide its products and services to the user or may not provide access to the Application and/or our Websites. We may not be able to assess an application for employment if it does not include relevant information. We may not be able to engage service providers who do not provide us with information necessary to manage our business.

Disclosure of personal information

All personal information gathered by NeuroGames during the course of its business will remain confidential except when:

  1. It is subpoenaed by a court, or disclosure is otherwise required or authorized by law; or
  2. Failure to disclose the information would, in the reasonable belief of NeuroGames, place you or another person at serious risk to life, health, or safety; or
  3. Your prior approval has been obtained to:
    • Provide another person, e.g., parent or guardian, with access to the NeuroGames portal to view your information in the Application, update materials and worksheets, download worksheets and record their own data.
    • Disclose the information in another way; or
    • Disclose to another professional or agency (e.g., your GP) and disclosure of your personal information to that third party is for a purpose which is directly related to the primary purpose for which your personal information was collected.
    • Disclose information to related service providers such as the Full Potential Psychology Pty Ltd clinic in order to provide a product or service that you and/or your parent/guardian have given consent to.
  4. There are incidental disclosures associated with the technology you agree to use in your therapy sessions, namely:

    Minecraft Server Hosting: NeuroGames uses a dedicated private server with OVH and the game Minecraft to host and play Minecraft online for some sessions. In order to access this server, NeuroGames Pty will be required to enter your unique Minecraft user ID into OVH in order for you to access the Application.

    Further information regarding OVH’s privacy policy can be found here https://www.ovhcloud.com/en/terms-and-conditions/privacy-policy/. You may choose not to register for Minecraft or not provide us with your Minecraft user ID, but this will mean that you will not be able to access or use the Application. You are not required to enter any information into Minecraft or the Application as part of your therapy sessions, as we will be online with you using telehealth at the same time. Any information that you type into the Application during or between our sessions will be collected by Minecraft and will be outside the control of NeuroGames.

    Minecraft is owned by Microsoft. Further information regarding Minecraft's privacy policy, including how they use and disclose information, can be found here https://account.mojang.com/terms#privacy. By using, displaying or access the Application, you agree to comply with Minecraft’s privacy policy.

    The Application contains third party products which may be provided, accessed or located overseas. NeuroGames may disclose a users’ personal information to overseas recipients as a result of these third party products. By providing us with your personal information, you consent to the storage of such information on overseas servers and acknowledge that we may disclose your personal information to an overseas recipient. You agree that Australian Privacy Principle 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the Australian Privacy Principles, that entity will not be bound by, and you will not be able to seek redress under the Privacy Act.

    In the event that unauthorized access, disclosure, or loss of a user’s personal information occurs, NeuroGames will activate its data breach plan and use all reasonable endeavors to minimize any risk of consequential serious harm.

Direct Marketing

Like most businesses, marketing is important to our continued success. We believe we have a unique range of products and services that we provide to customers at a high standard. We therefore like to stay in touch with customers and let them know about new opportunities. We may provide you with information about new products, services and promotions either from us, or from third parties which may be of interest to you.

We will not disclose your personal information to third parties for marketing purposes without your consent.

You may opt out at any time if you no longer wish to receive commercial messages from us. You can make this request by contacting us at info@neurogames.com.au.

Cookies

A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre-defined period of time. We use cookies to identify specific machines in order to collect aggregate information on how visitors are experiencing the Application. This information will help to better adapt the Application and/or our Websites to suit personal requirements. While cookies allow a computer to be identified, they do not permit any reference to a specific individual. For information on cookie settings of your internet browser, please refer to your browser’s manual.

Requests for access and correction to user information

You may request to access and/or correct the personal information that we hold about you at any time. If we are satisfied that personal information that we hold is inaccurate, out of date, or incomplete, reasonable steps will be taken in the circumstances to ensure that this information is corrected. All requests by users, parents/guardians, prospective employees, and contractors for access to or correction of personal information held about them should be lodged with NeuroGames. These requests will be responded to in writing within a reasonable time, and an appointment will be made if necessary, for clarification purposes.

We are not obligated to correct any of your personal information if we do not agree that it requires correct and may refuse to do so. On the rare occasions when we refuse access, we will provide you with written notice stating our reasons for refusing access.

Protection of personal information

We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers, which may be located overseas.

We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of personal information. This also applies to disposal of personal information.

We further protect personal information by restricting access to personal information to only those who need access to the personal information do their job. Physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your personal information.

We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.

Changes to this Privacy Policy

We keep our Privacy Policy under regular review to make sure it is up to date and accurate. If we update it, we will update the “effective date” at the top of this page. If we make a material update, we will provide you with notice prior to the update taking effect, such as by posting a notice on our Websites or sending you an email if we consider it is urgent.

We encourage you to periodically review this privacy policy to stay informed about how we collect, handle, store and share your personal information.

Concerns

If you have any questions or concerns about this Privacy Policy or the management of your personal information, you may inform NeuroGames by emailing info@neurogames.com.au and we will investigate your complaint and respond to you within a reasonable time.

If we are unable to resolve your concern, or you are dissatisfied with the handling of your complaint, you may lodge a formal complaint with the Office of the Australian Information Commissioner by phone on 1300 363 992, online at https://www.oaic.gov.au/privacy/making-a-privacy-complaint, or by post to: Office of the Australian Information Commissioner, GPO Box 5218, Sydney, NSW 2001.