Privacy Policy

Your privacy is important to us. As part of our efforts to facilitate and make your experience with the CollabCare Software as user-friendly and enjoyable as possible, we may collect and use certain information you provide to us. This Privacy Policy addresses the collection, use, and disclosure of information that CollabCare may gather during your use of the Software. UNLESS OTHERWISE DEFINED IN THIS PRIVACY POLICY, TERMS USED IN THIS PRIVACY POLICY HAVE THE SAME MEANINGS AS IN THE SOFTWARE END USER LICENSE AGREEMENT.

Please review the entire policy to learn the types of End User information CollabCare gathers, how CollabCare uses that End User information, what End User information is disclosed and to what third parties, and how CollabCare safeguards your End User information.

This Privacy Policy applies only to the CollabCare Software. This Privacy Policy does not apply to any software managed, maintained, and/or hosted by third parties not directly affiliated with CollabCare that you may access, e.g., via a link provided through the Software or our website. CollabCare does not control the privacy policies applicable to other software or websites to which we may provide hyperlinks. We encourage you to learn more about the online privacy and data security policies of third parties directly from such third parties, as their policies may differ from ours.

It is important that you read this Privacy Policy together with the CollabCare Mobile Application End User License Agreement, and all other applicable CollabCare rules and policies so you are fully aware of how and why we are using your data.

I. Information CollabCare Collects

A. Personal Information and Non-Identifying Information

We may ask you for personally identifiable information if, for example, you contact us requesting information or a demonstration of our services. This refers to information about you that can be used to contact or identify you (“Personal Information”). Personal Information includes, but is not limited to, your full name, email address, and any other information that could be used to personally identify you.

We also collect other information that you provide as part of registration and the administration and personalization of your account with us that does not identify you (“Non-Identifying Information”). Non-Identifying Information includes, but is not limited to, individual preferences. Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your gender only or your viewing preferences).

We may also combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other users to attempt to provide you with a better experience, to improve the quality and value of the Software, and to analyze and understand how the Software is used.

B. Usage Data

When you use the Software, our servers automatically record information referred to as “Usage Data.” This Usage Data may include information such as the manufacturer and model of your device; your Internet Service Provider (ISP); your device’s Internet Protocol (“IP”) address (or other device identifier), browser type, and operating system; referring/exit pages; clickstream data; Software access times and dates; information you search for in the Software; and other statistics.

We use this information for technical administration of the Software and attendant services, including to monitor and analyze use of the Software, to increase the functionality and user-friendliness of the Software, and to better tailor the Software to End Users’ needs. Usage Data may be non-identifying or it may be associated with you. Whenever we associate Usage Data with Personal Information, we will treat it as Personal Information.

II. Collection of Information

CollabCare may use a number of different techniques and technologies to collect Personal Information, Non-Identifying Information, and Usage Data. For example, CollabCare may use cookies, log files, clear gifs, pixel tags, embedded scripts, and/or other technology used to monitor your use of the Software

A. Forms

We request certain information from you through the use of forms when you send us correspondence through the Software.

B. Cookies

The Software uses cookies and other technologies to help us understand which parts of the Software are more popular and how much time users spend there. A cookie is a small amount of data that is sent to and stored on your device from our server. Cookies may, for example, allow a user to enter a password less frequently or remember a user’s preferences during an online session.

The Software uses cookies to determine whether an End User is active and for other business purposes. The Software may include first-party cookies (i.e., cookies that send data directly to CollabCare and agents and contractors acting on behalf of CollabCare, including cookies used to monitor, analyze, and administer the Software).

C. Usage Data

Usage Data are collected automatically by our servers. For example, because the Software automatically collects Usage Data for all End Users that use the Software, your use of the Software will be tracked. We may collect and use technical data and related information, including technical information about your device, system and application software, and peripherals, to maintain and support the Software generally.

Additionally, in some of our email messages, CollabCare may use a “click-through URL” linked to content on the Software. When an End User clicks onto one of these URLs, the End User will pass through our server before arriving at the destination Web page. CollabCare tracks this click-through data to help us determine End User interest in certain subject matter and measure the effectiveness of these End User communications. You can avoid being tracked in this way by not clicking text or graphic links in emails from CollabCare.

Finally, we may use clear gifs or pixel tags, which are tiny graphic images, in order: (i) to advise us of what parts of the Software End Users interact with, (ii) to measure the effectiveness of any searches End Users perform, and (iii) to enable us to send emails in a format that End Users can read and tell us whether such emails have been opened in order to ensure us that we are sending messages that are of interest to End Users.

D. Public Communications

Please note that if you use any bulletin board, chat room, comment posting feature, or other public communication service, forum, or feature offered through the Software, or post any information available for viewing by other End Users, any of the information that you share will be visible to other End Users. The information that you make available can be read, used, and collected by other End Users to send you unsolicited messages. CollabCare is not responsible for the manner in which the Personal Information that you decide to share will be used by other End Users.



We will only use your Personal Information when the law permits such use. Most commonly, we will use your Personal Information in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests include:
    • To provide you with information that you requested;
    • To improve our services, to customize your experience, or to serve you specific content that is most relevant to you;
    • To contact you with regard to your requests or use of any use of our services and, in our discretion, changes to any of our services and/or any of our policies;
    • For internal business purposes such as complying with our internal policies;
    • To protect our interests, including establishing, exercising and defending legal rights and claims.
    • For purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your Personal Information other than in certain instances.

We may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your data.


We will get your express opt-in consent before we share your Personal Information with any company outside CollabCare for marketing purposes.


You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some items may become inaccessible or not function properly.

Tracking Technologies

We obtain your consent to our information storage or collection tracking technologies by providing you with transparent information in our Privacy Policy and providing you with the opportunity to make a choice to disable cookies when you first access our software.


We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

We will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent or explaining our legal basis for doing so.

Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


CollabCare’ policy is not to share the End User information it collects with third parties other than as specified below, or where an End User expressly consents to our sharing of certain information with a third party. We may have to share your Personal Information for the purposes set out below. We require third parties to respect the security of your Personal Information and to treat it in accordance with the law. We may share End User information with third parties under the following circumstances:

0. Business Partners and Vendors

We may employ third party companies and individuals for any of the following: to facilitate operation of the Software and attendant services; to provide the Software and attendant services, or portions thereof, on our behalf; to perform related services, including without limitation, maintenance services, database management, fulfillment, web analytics, and improvement of the features or functionality; or to assist us in analyzing how the Software is being used.

1. Promotions

From time to time, we may offer promotions through the Software that require a separate registration. By participating in such a promotion, we will provide you with the official rules for the promotion. Information collected in connection with a promotion will be used consistently with the promotion’s official rules and this Privacy Policy.

2. Business Transfers

As we continue to develop our business, we may buy, sell, or share assets in connection with, for example, a merger, acquisition, reorganization, sale of assets, or bankruptcy. In such transactions, information about End Users generally is often a transferred business asset. In the event that CollabCare itself or substantially all of CollabCare’ assets are acquired, information about our End Users may be one of the transferred assets. If such a change happens to our business, the new owners may use your Personal Information in the same way as set out in this Privacy Policy.

3. Legal Process

Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.

4. Aggregate End User Information

We may release aggregate End User information (without revealing any Personal Information about you) to advertisers and other third parties in order to promote or describe use of the Software.

V. Changing or Deleting Your Information

All End Users who have created an account through the Software may review, update, correct or delete the Personal Information in their registration profile by contacting us. If you completely delete all such information, then your account may become deactivated.

VI. Security

We employ administrative, physical, and electronic measures designed to protect your information from unauthorized access. For example, we use commercially reasonable security measures such as encryption, firewalls, and secure socket layers (SSL) to protect End User information.

We limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.

Please note that no security system is impenetrable. Accordingly, we do not guarantee the security of our databases, nor that information you supply won't be intercepted while being transmitted to us over the Internet or other network. We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.



We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

VIII. Changes To The Privacy Notice

We may, in our sole discretion, update this Privacy Policy periodically without prior notice to you to reflect changes in our information practices or with respect to applicable laws. We will post the updated version on our website and indicate at the top of the Privacy Policy when it was last updated. Please revisit this page periodically to stay aware of any changes to this Privacy Policy. In the event that the modifications materially alter your rights or obligations hereunder, we will make commercially reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification after such material changes are made. Our amended Privacy Policy will automatically take effect upon the date that an update is published. Your continued use of the software after the revised or updated Privacy Policy has become effective indicates that you have read, understood and agreed to the then-current version of the Privacy Policy.

IX. Contacting Us

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please contact us using the details set out below.

Our full details are:

Name of entity: KeyTrust CollabCare
Email address:
Postal address:
Level 9
22 William St, Melbourne
VIC 3000