Privacy Policy 

Last updated: 6th February 2026

  1. About this Privacy Policy

In this Privacy Policy, ‘us’ ‘we’, ‘our’ or ‘MyComms’ means Communication Spectrum Pty Ltd (ABN 676 037 979) and any of our group companies. 

This Privacy Policy sets out our commitment to protecting the privacy of your personal information provided to us, or otherwise collected, used, stored, handled or disclosed by us when providing our online platforms, website and app (together, the Services).or when otherwise interacting with you in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth).

We may also choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions, or U.S. states. Please refer to Section 11 (Region-Specific Disclosures) for additional disclosures that may be applicable to you. 

By using our Services, or in providing any personal information to us, you consent to our collection, use, storage, handling and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

“Personal information” includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information. 

Data protection laws sometimes differentiate between “controllers” and “processors” of personal information. A “controller” determines the purposes and means (the why and how) of processing personal information. A “processor” processes personal information on behalf of a controller subject to the controller’s instructions. In some jurisdictions, the term “service provider” is used instead of “processor”.

This Privacy Policy describes our privacy practices where we are acting as the controller of personal information.

If you access our Services or otherwise interact with us from the European Economic Area (“EEA”), United Kingdom (“UK”), please see Schedule 2 (Additional EEA and UK Privacy Disclosures) for more information.

We only collect personal information reasonably necessary to provide you with our Services, or for its functions or activities. We may collect the following types of personal information:

  • name;
    • mailing or street address;
    • email address;
    • telephone number and other contact details;
    • age or date of birth;
    • gender;
    • photos of you and any other content you or third parties on your behalf upload when using our Services;
    • government identifiers to the extent required by law; 
    • payment and transaction data including details about payments from you and other details of the Services you have purchased from us or that you have enquired about (however, we do not directly collect and hold credit card and bank details, but these may be collected on our behalf via our third-party payment service providers); 
    • your device ID, device type, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
    • analytics data, such as data from third-party analytics tools to help us understand user interactions;
    • any additional information relating to you that you provide to us directly or indirectly through our Services or when making an enquiry with us, or through other websites or accounts from which you permit us to collect information; 
    • information you provide to us through customer surveys and promotions; or
    • any other personal information that may be required in order to facilitate your dealings with us. 

We may collect these types of personal information either directly from you, or from third parties when you: 

  • sign up on our website or platform or sign up to events with us;
    • communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;
    • interact with our sites, Services, content and advertising; or
    • invest in our business or enquire as to a potential purchase in our business.

In addition, when you apply for a job or position with us we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract. This Privacy Policy does not apply to acts and practices in relation to employee records of our current and former employees, which are exempt from the Privacy Act.

  • Personal information and consent of third parties

From time to time, you may provide us, and we may collect from you, personal information of a third party. Where you provide the personal information of a third party, it is your responsibility to ensure that you have obtained their consent to provide their personal information to us (where required under applicable law) and inform them that their details will be collected, stored, used and disclosed in accordance with this Privacy Policy. This includes informing them of the purpose of collection, how their information will be used, and their rights regarding access and correction of their information as set out in this Privacy Policy. 

If you are signing up to our Services for a minor or a person who you have legal responsibility for (ie: where you are the parent or legal guardian), you must consider the privacy of the user over whom you have responsibility. You may also be responsible for providing any necessary consents on behalf of those individuals.

Sensitive Information

Under the Privacy Act and other applicable law, “sensitive information” includes but is not limited to information or an opinion about an individual’s race or ethnic origin, religious belief, or criminal record and also includes health, genetic or biometric information about an individual.

In certain circumstances, when you use our Services, we may collect sensitive information such as information about your physical, mental or psychological health. We will only use sensitive information for the primary purpose it was collected, with your consent or where required or authorised by law.

We may collect, hold, use and disclose your personal information for the following purposes:

  • to enable you to access and use our Services;
    • to operate, protect, improve and optimise our Services, business and our users’ experience, such as to perform analytics, conduct research, develop new features and for advertising and marketing;
    • to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
    • to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
    • to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
    • to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
    • to consider your employment application.

We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.

If you are in the UK or EEA, please refer to Schedule 2 (Additional EEA and UK Privacy Disclosures) for further information regarding the lawful basis we rely on and process your personal information.

  • Automatic Data Collection Preference 

Where a specific preference manager or privacy setting is not available, you may be able to utilize third-party tools and features to further restrict our use of automatic data collection technologies. For example:

  • some browsers may allow you to change browser settings to limit automatic data collection technologies on websites
    • some email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies; and
    • many devices allow you to change your device settings to limit automatic data collection technologies for device applications. 

Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using our Services, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies, or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.  

  • Do we use your personal information for direct marketing?

We and/or our carefully selected business partners may send you direct marketing communications and information about our Services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out in Section 17 (Enquiries, Requests, Complaints, Breaches) or by using the opt-out facilities provided (eg an unsubscribe link). 

If you are in the UK or EEA, we will only use your personal information for direct marketing where we have your consent to do so and we do not sell personal information. Please refer to the Schedule 2 (Additional EEA and UK Privacy Disclosures) for further information about our use of your personal information for direct marketing and how to withdraw consent.

We work with other companies that help us provide our systems and Services to our customers. We may provide personal information to these companies for the purpose of providing the Services to you and to facilitate our interests. Those service providers will only be provided with access to your personal information as is reasonably necessary for the purpose that we have engaged the service provider, and we will require such third parties comply with our standards and all applicable laws. 

We may disclose personal information for the purposes described in this privacy policy to:

  • our employees, contractors and related entities;
    • third party suppliers and service providers (including providers for the operation of our websites and/or our business, such as therapists, behaviour support practitioners and researchers) or in connection with providing our Services to you;
    • marketing or advertising providers;
    • IT service providers, data storage, web-hosting and server providers;
    • professional advisors, dealers, agents, auditors, business partners, sponsors, business brokers, our insurers and insurance brokers;
    • payment systems operators (eg merchants receiving card payments); 
    • our existing or potential agents, business partners or partners;
    • our sponsors or promoters of any competition that we conduct via our Services
    • specific third parties authorised by you to receive information held by us; and
    • courts, tribunals, governmental agencies, regulatory authorities and law enforcement agencies, or as required, authorised or permitted by law.
  • Disclosure of personal information outside Australia

As we operate on a global scale, we may store and process personal information in a cloud services or data centres located outside the country in which you are located, including but not limited to Australia, New Zealand, EU, India, Singapore, Canada, the United States and the UK or in any country where we or our service providers operate.

For the provision of customer support, to troubleshoot issues or for other IT or marketing services, we may give controlled access to our systems to suppliers or personnel located outside of the country where you are located. Such access is provided strictly under applicable data protection laws, contractual safeguards, and security measures designed to protect your personal information.

Additionally, we may disclose personal information overseas when required by legal or regulatory obligations, such as responding to a lawful request from a foreign law enforcement body.

We take reasonable steps to ensure that any international transfer of personal information is carefully managed to protect your privacy rights and interests. This includes implementing measures such as encryption, pseudonymisation, and contractual safeguards to ensure your data is handled securely and in compliance with applicable privacy laws.

If you are in the UK or EEA, please refer to Schedule 2 (Additional EEA and UK Privacy Disclosures) for further information regarding international transfers of your personal information and the transfer mechanisms we rely on.

  • Using our website and cookies

We may collect personal information about you when you use and access our website.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer. 

We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so. If you are in the UK or EEA, we will only collect and process your personal information via cookies if we have your consent to do so or if strictly necessary to provide a feature or functionality of our Services to you.

We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy. 

For information about the choices you may have in relation to our use of automatic data collection technologies, please refer to Section 8 in Schedule 1 (Your Additional U.S Privacy Choices) and Section 7 in Schedule 2 (Your Additional EEA and UK Privacy Choices).

  1. Children’s Personal Information

Where required by applicable law, we will obtain consent from the parent or legal guardian of a child who is under the age of 16 before knowingly processing the child’s personal information. Please refer to the Section 12 (Region Specific Disclosures) for additional children’s privacy disclosures for the region where you live.

If you believe a child under the age of 16 has provided personal information to us without appropriate consent, please contact us so that we may delete such information.

  1. Data Retention

We will only retain your personal information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal information is no longer reasonably necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if that is not possible (for example, because personal information has been stored in backup archives), we will securely store the personal information and isolate it from further active processing until deletion or deidentification is possible

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

  • EEA or UK: If you are located in the EEA (Member States of the European Union together with Iceland, Norway, and Liechtenstein) or the UK, please click here for additional European-specific privacy disclosures, including a description of the personal information rights made available to individuals located in those jurisdictions under applicable law.
  • United States: If you are a resident of the United States, please click here for additional U.S.-specific privacy disclosures. Our U.S.-specific privacy disclosures include information about children’s privacy under the Children’s Online Privacy Protection Act (“COPPA”) as well as a description of the personal information rights made available to residents of certain states under applicable law.
  • Security

We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. However, we cannot guarantee the security of your personal information. 

  1. Links

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

  1. Unsubscribe

To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details set out in Section 17 (Enquiries, Requests, Complaints, Breaches). or opt-out using the opt-out facilities provided in the communication.

  1. Accessing or correcting your personal information

You may have the right to ask for your personal information by requesting:

  • a copy of your personal information;
    • that we correct inaccuracies relating to your personal information;
    • that your personal information be deleted or that we restrict access to it; and
    • a structured electronic version of your personal information.

You may also have the right to object to our use of your personal information. 

Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.

If you think that any personal information, we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.

Should you wish to make a request in respect of your personal information please contact us using the information in Section 17 (Enquiries, Requests, Complaints, Breaches).

Please refer to Section 12 (Region-Specific Disclosures) for further information on the rights that may be available to you.

You can make enquiries or complaints regarding this Privacy Policy or the personal information we hold on you to our customer service team, whose contact details are below.

For any questions or notices, please contact us at:

Privacy Officer, Communication Spectrum Pty Ltd

Address: Unit 13, 94-96 Wycombe Road, Neutral Bay NSW 2089

Email: info@commspec.co 

We will take all reasonable steps to ensure your claims are investigated and a formal response will be provided to you, within a reasonable time, considering the circumstances of your claims. If any corrective action is determined to be required, as a result of that investigation, we will take all reasonable steps to rectify the situation and advise you of such, again within a reasonable time considering the circumstances. 

If we do not resolve your enquiry, concern or complaint to your satisfaction or you require further information in relation to any privacy matters, you can contact the relevant regulatory authority, whose contact details are below: 


Individuals based in Australia

Office of the Australian Information Commissioner

Telephone: 1300 363 992

Email: enquiries@oaic.gov.au  

Address: Level 3, 175 Pitt Street, Sydney NSW 2000, Australia


Individuals based in New Zealand

Office of the Privacy Commissioner

Telephone: 0800 803 909

Address: PO Box 10 094, Wellington 6140


Individuals based in the United Kingdom

Information Commissioner’s Office

Telephone: +44 (0) 303 123 1113

Address: Wycliffe House, Water Lane, Wilmslow SK9 5AF, United Kingdom


Individuals based in the United States

Refer to your relevant State privacy and data protection body


Individuals based in Canada

Office of the Privacy Commissioner of Canada

Phone: +1 819-994-5444

Address: 30 Rue Victoria, Gatineau, QC J8X 2A1, Canada


Individuals based in Singapore

The Personal Data Protection Commission (PDPC)

Telephone: +65 6377 3131

Address: 10 Pasir Panjang Road #03-01, Mapletree Business City, Singapore 117438

These disclosures supplement the information contained in this Privacy Policy by providing additional information about children’s privacy under the Children’s Online Privacy Protection Act (“COPPA”) and about our personal information processing practices relating to individual residents of certain states in the United States. 

  1. Children’s Privacy (COPPA)

For US users, we will obtain consent from the parent or legal guardian of a child who is under the age of 16 before knowingly processing the child’s personal information. We do not use children’s personal information for targeted advertising.

  • Nevada Residents

If you are a resident of the state of Nevada in the United States, you have the right to opt out of the sale of your personal information. Although we do not currently sell personal information of Nevada residents (as defined under Nevada law), you may submit a request to opt-out of the sale of your personal information by contacting us at info@commspec.co

  • California, Colorado, Connecticut, Delaware, Indiana, Kentucky, Montana, Nebraska, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia Residents

If you are a resident of the state of California, Colorado, Connecticut, Delaware, Indiana, Montana, Nebraska, Oregon, Tennessee, Texas, Utah, or Virginia in the United States, the following supplementary disclosures apply to you.

  • Personal information disclosures, sales and targeted advertising

We disclose all of the categories of personal information we collect to the categories of recipients set forth in the Section 7(Who we may disclose your Personal Information to) of this Privacy Policy. Our disclosure of personal information to the third parties qualifies as the sale of personal information or the sharing or processing of personal information for the purpose of displaying advertisements that are selected based on personal information obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”) under certain privacy laws. 

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal information or the processing of personal information for purposes of targeted advertising as described in Section 8 (Your Additional U.S. Privacy Choices).

  • Sensitive Personal Information

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit, or withdraw your consent for, our use of sensitive personal information as described in Section 8 (Your Additional U.S. Privacy Choices).

  • Deidentified Information

We may at times receive, or process personal information to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law. 

  • Automated Decision-Making and Profiling

We do not conduct automated processing of personal information for the purposes of evaluating, analyzing, or predicting an individual’s personal aspects in furtherance of decisions that produce legal or similarly significant effects. As a result, we do not provide a right to exercise control over such forms of automated decision-making and profiling. 

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights: 

  • Right to Know: The right to confirm whether we are processing personal information about you and, under California law only, to obtain certain personalized details about the personal information we have collected about you, including: 
    • the categories of personal information collected;
    • the categories of sources of the personal information;
    • the purposes for which the personal information were collected;
    • the categories of personal information disclosed to third parties (if any), and the categories of recipients to whom this personal information was disclosed;
    • the categories of personal information shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal information was disclosed for these purposes; and
    • the categories of personal information sold (if any) and the categories of third parties to whom the personal information were sold.
  • Right to Access & Portability: The right to obtain access to the personal information we have collected about you and, where required by law, the right to obtain a copy of the personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
  • Right to Correction: The right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. 
  • Right to Control Over Sensitive Personal Information: The right to exercise control over our collection and processing of certain sensitive personal information. 
  • Right to Control Over Automated Decision-Making / Profiling: The right to direct us not to use automated decision-making or profiling for certain purposes. 
  • Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share personal information for certain targeted advertising purposes. 
  • Right to Opt-Out of Sales: The right to direct us not to sell personal information to third parties, including the right to opt-out of the disclosure of personal information to third parties for the third parties’ direct marketing purposes under California’s “Shine the Light” Law.
  • Right to Deletion: The right to have us delete personal information we maintain about you. If you are a resident of the State of California under the age of 18, you may also request and obtain removal of user-generated content you have posted on our platform (though please note that such a request does not ensure complete or comprehensive removal of all user-generated content, particularly where user-generated content has been republished by another user or third party).
  • Submitting Privacy Rights Requests

Please submit a request specifying the right you wish to exercise by contacting us at info@commspec.co.

To exercise your right to opt-out as it relates to the use of cookies and related technologies that involve the sharing of personal information or the use of personal information for targeted advertising purposes, please go to the “cookie settings” in your web browser and adjust your preferences accordingly. In addition, you can also opt-out of cookie-based sales by businesses that participate in the Digital Advertising Alliance’s CCPA Opt-Out Tool by visiting https://www.privacyrights.info/. Lastly, you may follow the other steps set forth in Section 8 (Your Additional U.S. Privacy Choices) to further exercise control over automatic data collection technologies. Our site does not respond to the Global Privacy Control signal.

Before processing your request to exercise certain rights (including the Right to Know, Access & Portability, Correction, and Deletion), we will need to verify your identity and confirm you are a resident of California. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests to include first and last name, email address, phone number, state of residency and/or the date of your last transaction with us.

In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible states. 

  1. Submitting Authorized Agent Requests

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request. 

California law requires we provide disclosures to you about what personal information we collect by reference to the enumerated categories of personal information set forth within California law. To address this obligation, we have identified below the relevant enumerated California personal information category for the personal information described in Section 4(How do we collect, hold, use and disclose personal information) of this Privacy Policy:

These disclosures supplement the information above by providing additional information about our personal information processing practices relating to individuals who access our website (“Site Users”) and individuals who access and use our Services or otherwise interact with us from the EEA and UK (“Service Users”). For a detailed description of how we collect, use, disclose, and otherwise process personal information, please read Section 4 (How do we collect, hold, use and disclose personal information) of this Privacy Policy. 

Communication Spectrum Pty Ltd (“MyComms”) is the “controller” responsible for the controlling and protecting of personal information in connection with our EEA and UK Services. This means MyComms determines and is responsible for how your personal information is used. You may contact MyComms by sending an email to: info@commspec.co.

  • Automated Decision-Making and Profiling

We do not conduct automated processing of personal information, including profiling, for the purposes of making decisions about you with legal or similarly significant effects.

  • Purposes and Legal Bases of Use

When we use your personal information, we will do so in reliance on the following lawful bases. You are not required to provide personal information to us, but we do rely on your personal information to provide our Services. If you choose not to provide us with your personal information, we may not be able to provide you with the Service you request. We will inform you at the point that we collect personal information from you if the provision of certain personal information is mandatory or optional for receipt of our Services. 

If you are minor (under 18), we may collect some or all of the below information from your parent or legal guardian. 

  • Personal Information We Collect

We collect personal information that you submit directly to us when you contact us or access or use our Services, as follows: 

Categories of Personal Information used How we use Personal InformationLawful basis
Site Users and Service Users
Contact information and identifiers, including title, first name, last name, email address, and telephone numbers.We use this information to communicate with you in response to any queries that you submit to us. If you purchase or use our Services, this processing is necessary for the performance of, or to take steps prior to, a contract with you.  Otherwise, the processing is necessary for our legitimate interests, namely to communicate with you and respond to and appropriately investigate specific information requests made by you. 
We use this information to send notifications and alerts to if you have signed up to receive our newsletter or other marketing emails, surveys and/or information about promotions.We will only process this personal information to the extent we have your consent to do so.
Communications with us (including uploaded content), when you contact us directly e.g., by email, webform or phone, we will record your comments and opinions and any content you upload in connection with your comment or query.We use this information to handle your customer service requests including:directing your questions to the appropriate team members; andinvestigating and addressing any concerns.If you purchase or use our Services, this processing is necessary for the performance of, or to take steps prior to, a contract with you. Otherwise, the processing is necessary for our legitimate interests, namely to respond to and appropriately investigate your request. 
We use this information to identify ways in which we can improve the website and service as well as to inform our development of new products and digital content.The processing is necessary for our legitimate interests, namely identifying ways in which we can improve and further develop the website and service.
Marketing and communications preferences including your preferences in receiving marketing from us and our third parties, and your communication preferences.We use this information to send notifications and alerts in accordance with your preferences.The processing is necessary to comply with legal obligations to which we are subject, namely privacy and electronic communications legislation.   
Service Users Only 
Account information, including username and password or security pinWe use this information to set up your account profile and to authenticate you to service. The processing is necessary for the performance of a contract with you.If you are a minor (under 18), the processing is necessary for our legitimate interests, namely to provide you and your parent or legal guardian with the Services at your or their request.
Government identifiers including official identification document detailsNote that we do not directly collect identification document details, but these may be collected on our behalf via our third-party verification service providers.We use this information to verify your identity for the purpose of providing Services to you.   The processing is necessary to comply with a legal obligation to which we are subject.  
Profile information, including name, contact information (phone and email address), postal address, age or date of birth, gender, photo, creator or therapist name.We use this information to set up your account profile for your use when using our Service.  The processsing is necessary for the performance of a contract with you. If you are a minor (under 18), the processing is necessary for our legitimate interests, namely to provide you and your parent or legal guardian with the Services at your or their request.
Account and profile settings, such as profile information, manage notifications, subscription and app settings.We use this information to set up your account profile and manage your settings in order to provide the Service to you in accordance with your, or your parent or legal guardians wishes.  The processing is necessary for the performance of a contract with you. If you are a minor (under 18), the processing is necessary for our legitimate interests, namely to provide you and your parent or legal guardian with the Services at your or their request.
Service User content, including photos and any other materials you (or others on your behalf) upload to the ServicesWe use this information to allow you (or others on your behalf) to upload content.The processing is necessary for the performance of a contract with you. If you are a minor (under 18), the processing is necessary for our legitimate interests, namely to provide you and your parent or legal guardian with the Services at your or their request.
Tasks, daily schedules and calendars, such as progress or photos of tasks, details of your daily schedule and calendar, which may or may not include information entered by you such as information about your physical, mental or psychological health.We use this information to allow you and your parent or legal guardian to track and monitor your wellbeing, at your and their request. We will only process this information where we have your consent to do so.  If you are a child (under 16, depending on your country of residence), we may require such consent from your parent or legal guardian.
Transaction information, including details of Services you purchase from us and app subscription details.We use this information to allow you to purchase our Services and to deliver our Services to you.The processing is necessary for the performance of a contract with you. 
We use this information for our own internal record-keeping purposes and to ensure the security and integrity of the Services, including identifying and preventing unlawful, fraudulent, or malicious use of the Services. The processing is necessary for our legitimate interests, namely to maintain our own internal legal records and identifying and mitigating the risk of unlawful behavior to protect the Services. 
Payment details, including card and bank details, purchased Services and date / time of purchases.Note that we do not directly collect and hold credit card and bank details, but these may be collected on our behalf via our third-party payment service providers.We use this information to allow you to purchase our Services.The processing is necessary for the performance of a contract with you. Note that we do not collect this information in relation to minors’ (under 18s’) accounts. 
We use this information for our own internal record-keeping purposes and to identify suspicious transactions and prevent unlawful, fraudulent, or malicious use of the Services. The processing is necessary for our legitimate interests, namely to maintain our own internal legal records and identify fraud. 
All of the above information (other than sensitive data collected, such as data regarding your health).   Where permitted by law, we may use all of the above personal information to allow us, and our partners, to present advertising that is tailored to you. We will only process your personal information in this way to the extent that you have given us your consent to do so via our cookie consent banner or in-app preferences. Note, we do not use personal information in this manner when collected from accounts identified as minors’ (under 18s’) accounts.
  • Personal information we collect automatically 

Like all online Services, we also collect certain personal information about you automatically when you use the Services in order to understand how the Services are used and how we can improve it, as well as to tailor the adverts you see online to your interests.

If you are a Service User, certain information (e.g. your use of the Services) is collected automatically to provide you with features of the Services, as described further below. 

Categories of Personal Information usedHow we use Personal Information Lawful basis 
Site Users / Service Users / Aged Care Users
Your IP address, including date and time. Note, other than when strictly necessary to provide Service functionality or to secure the Service, we do not automatically collect this type of personal information from accounts identified as children’s (under 16s’) accounts.We use this information to tailor the website or service to you and ensure it is personalized to your needs and preferences.We will only process your personal information in this way to the extent that you have given us your consent to do so via in-app preferences.  
Where relevant and where permitted under applicable law, we use this information to identify potential risk or unlawful behavior including fraud detection, theft prevention, emergency response purposes and legal compliance.The processing is necessary for our legitimate interests, namely identifying and mitigating the risk of unlawful behavior to protect the Services, MyComms and its users.
Information about how you access and use the Services,the time you access the Service and how long you access it for, the approximate location that you access the website or Services, the site from which you came and the site to which you are going when you leave the Services, the pages you visit, the links you click, your interactions on the website or service and other actions you take on the Service. Note, other than when strictly necessary to provide Service functionality or to secure the Service, we do not automatically collect this type of personal information from accounts identified as children’s (under 16s’) accounts.We use necessary information to present the Service to you on your device. The processing is necessary for our legitimate interests, namely presenting the Service to our users so they can access and use our Services.
Where relevant and where permitted under applicable law, we use this information to ensure the security and integrity of the Services, including identifying and preventing unlawful, fraudulent, or malicious use of the Service.The processing is necessary for our legitimate interests, namely identifying and mitigating the risk of unlawful behavior to protect the Services, MyComms and its users.
We use this information to tailor the Service to you and ensure it is personalized to your needs and preferences.We will only process your personal information in this way to the extent that you have given us your consent to do so via in-app preferences.
We use this information to monitor and improve the Service and to resolve any issues.  We will only process your personal information in this way to the extent that you have given us your consent to do so via in-app preferences.
Log files and information about your device. We also collect information about the tablet, smartphone or other electronic device you use to connect the Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Service through the device, your IP address and your device’s telephone number (if it has one). Note, other than when strictly necessary to provide Service functionality or to secure the Service, we do not automatically collect this type of personal information from accounts identified as children’s (under 16s’) accounts.We use necessary information to present the Service to you on your device. The processing is necessary for our legitimate interests, namely presenting the Service to our users so they can access and use our Services.
Where relevant and where permitted under applicable law, we use this information to ensure the security and integrity of the website or Services, including identifying and preventing unlawful, fraudulent, or malicious use of the website or service.The processing is necessary for our legitimate interests, namely identifying and mitigating the risk of unlawful behavior to protect the Services, MyComms and its users. 
We use this information to tailor the website or service to you and ensure it is personalized to your needs and preferences.We will only process your personal information in this way to the extent that you have given us your consent to do so via in-app preferences.  
We use this information to monitor and improve the Service and to resolve any issues.  We will only process your personal information in this way to the extent that you have given us your consent to do so via in-app preferences.  
We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Services and to understand more about the demographics of our users. You can learn more about Google’s practices here and view its additional opt-out options here. Note, we do not automatically collect this type of personal information from accounts identified as children’s (under 16s’) accounts. We use this information to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users.We will only process your personal information in this way to the extent that you have given us your consent to do so via in-app preferences. 
All of the above information  Where permitted by law, we may use all of the above personal information to allow us, and our partners, to present advertising that is tailored to you. We will only process your personal information in this way to the extent that you have given us your consent to do so via in-app preferences. Note, we do not use personal information in this manner when collected from accounts identified as minors’ (under 18s’) accounts.
  • Adequacy Decisions

We may transfer personal information about you to countries that the relevant regulatory authority has deemed to adequately safeguard personal information, either automatically or in connection with a specific safe harbor framework. 

Certain regulatory authorities have adopted standard contractual clauses, which provide safeguards for personal information transferred outside of the originating jurisdiction. We may use these standard contractual clauses when transferring personal information to a third country that has not been deemed to adequately safeguard personal information. 

  • EU-U.S. Data Privacy Framework and UK Extension

The EU-U.S Data Privacy Framework and UK Extension (“DPF”) was designed by the U.S. Department of Commerce and the European Commission (and the the UK Secretary of State) to ensure adequate protection for personal information transferred to a company participating in the DPF. If we transfer any personal information about you from the EEA or UK to a third party outside the EEA or UK who is participating in the DPF, we may rely on their participation in the DPF to ensure adequate protection for personal information so transferred. 

We may transfer your personal information to, or store your personal information in, the following countries:

CountryAppropriate Safeguard
AustraliaStandard Contractual Clauses adopted by the European Commission / regulation of the UK Secretary of State.
United States of AmericaStandard Contractual Clauses adopted by the European Commission / regulation of the UK Secretary of State Sharing with recipients certified to the DPF
EEAIf you are in the UK, Adequacy 
UKIf you are in the EEA, Adequacy

Subject to certain limitations at law, you may be able to exercise the following rights:  

  • Right to Access: The right to obtain confirmation of whether we are processing personal information about you, access to and a copy of the personal information we are processing about you, and information relating to its processing, including:
    • the categories of personal information being processed; 
    • the purposes of the processing; 
    • the sources of the personal information; 
    • the categories of recipients to whom the personal information have been or will be disclosed; 
    • the envisaged period for which the personal information will be stored, or the criteria used to determine that period;
    • any automated decision-making or profiling performed in connection with your personal information; and 
    • the safeguards relied upon for the transfer of personal information to any third country. 
  • Right of Portability: The right to obtain a copy of the personal information we have collected about you in a structured, commonly used, and machine-readable format, and the right to transmit that personal information to another controller without hindrance. 
  • Right to Rectification: The right to correct or update any personal information about you that is inaccurate or incomplete.
  • Right to Restriction of Processing: The right to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
  • Right to Object to Processing: The right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
  • Right to Withdraw Consent: The right to withdraw your previously provided consent to our processing of your personal information. Please note withdrawing your consent will not affect the lawfulness of our use of your personal information before your consent was withdrawn, nor our processing of personal information pursuant to a different lawful basis for processing. 
  • Right to Erasure: The right to have us erase your personal information if the continued processing of that personal information is not otherwise justified. 

Please note that if the exercise of these rights limits our ability to process personal information, we may not be able to provide our Services to you or otherwise engage with you in the same manner. 

Please submit a request specifying the right you wish to exercise by contacting us at info@commspec.co.

Before processing your request to exercise certain rights (taking into account the confidential nature of any personal information we maintain), we will need to verify your identity and confirm you are accessing our Services or otherwise interacting with us from the EEA or UK. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests submitted to include first and last name, email address, phone number, state of residency and/or the date of your last transaction with us.

You can withdraw your consent to marketing materials by clicking on the unsubscribe link in the footer of our marketing emails or by contacting us at info@commspec.co. We make every effort to promptly process all unsubscribe requests. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to the features of the Services, technical and security notices).

In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity as needed to protect your personal information or locate your information in our systems, or where you are not accessing our Services or otherwise interacting with us from the EEA or UK.  

To exercise your right to withdraw your consent as it relates to the use of automatic data collection technologies (including cookies) that facilitate our online targeted advertising activities, please adjust your cookies preferences in your browser or device accordingly. Please note this preferences tool is website, device, and browser specific, so you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting. In addition, you may follow the steps in Section 8 (Your Additional EEA and UK Privacy Choices) above  to further exercise control over automatic data collection technologies.