GamblingLess: In-The-Moment Privacy Policy

Effective Date: 25 October 2024

We take your privacy seriously.

This policy explains:

• What personal information we collect

• How we use your information

• How we share information

• Your rights and choices

• How we protect information we collect

• Other important privacy information

By using our Services, you confirm you have agreed to the Terms of Service and have read and understood this Privacy Policy.

1. What personal information we collect

We collect the following information from or about you.

Account and profile information

We collect some limited personal information about you when you register for an account. This includes your phone number, email address, password. This contact information is collected so that Deakin University can contact you for research purposes. It is stored separately in password protected files on the Cogniss and Deakin University servers to maintain confidentiality.

Information you provide to us

We collect and store basic demographic information including your gender, age, country of residence, postcode, and approximate personal income. There are also a series of questions that need to be answered when you sign up to a research trial including questions about your gambling experiences, urges, and gambling expectancies as well as your confidence to resist gambling urges, your past month gambling and gambling goals.

We also collect and store information you provide us each time you check in such as your gambling urges, confidence resisting urges, gambling expectancies, current gambling goal and any gambling since you last checked in.

Your use of our Services

When you access or use the app, we collect and store certain usage data. This includes the types of content you view or engage with, the frequency and duration of your activities, and your progression through content.

Device information

We collect information from or about the computers, phones, or other devices where you install or access our Services. We may associate the information we collect from your different devices, which helps us provide consistent services across your devices. Some examples of the device information we may collect include:

• Attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers.

• Connection information such as the name of your mobile operator or ISP, browser type, language and timezone, mobile phone number and IP address.

Other

We constantly strive to improve our Services, and often introduce new features that may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy

2. How we use your information

We use the information you provide us in the following ways:

Contact during a research trial. We may use the personal information we collect about you to contact you if you have signed up to a research trial.

Provide and personalise app use. We personalise your app use by using information you provide in check ins to work out if you need help with your gambling in that exact moment, and direct you to particular groups of activities depending on your answers. After you’ve completed an activity in the app, we will check in to see if anything has changed and may recommend that you continue using activities if needed.

Research and Evaluation. We conduct research to test, evaluate, and improve the app, or to develop new, related apps. We will let you know when we are conducting a research trial.

We may also conduct audits and troubleshooting activities.

Publishing research results. Results of research conducted will be published in a summarised format. All personal information is confidential. When we write or talk about the results of research projects, we will not provide any individual, identifying information. We will only report group-level information; that is, by type of app user or by the whole group of app users. This means that no one will be able to identify you as an app user. Reporting may include scientific papers, research reports, and conference and forum presentations.

We process your personal information for the above purposes on the following grounds:

Consent. You have consented to the collection and use of your personal and other information to allow the app to operate effectively and provide a personalised experience as outlined below. You may also have provided consent for your data to be used as part of a research trial. If you have provided consnet for your data to be used in a research trial you can withdraw your consent to your information being used in research any time before we start the analysis of findings using your data by contacting us at contactgamblingless@deakin.edu.au. After this point, we won’t know what data belongs to you and therefore cannot withdraw your data.

Performance of a contract. We need your personal information to provide you with services and products requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you, like the Terms of Service.

Legal obligation. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.

Legitimate interests. We have a legitimate interest in using your personal information in the following cases:

• To analyse and improve the safety and security of our Services - we do this as it is necessary to pursue our legitimate interests in ensuring the platform we use (Cogniss) is secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam and abuse.

• To provide and improve our Services, including any personalized services - we do this as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Users on a sustained basis.

• To conduct and publish research based on the use of this app to better understand the daily experiences of using the app for people wanting to change their gambling. This information will be used to provide more options for support for gamblers in helping them achieve their goals.

• To anonymize and subsequently use anonymized information.

Protecting you and others. All research and evaluations are overseen by The Human Research Ethics Committee at Deakin University and are carried out according to the National Statement on Ethical Conduct in Human Research (2007) produced by the National Health and Medical Research Council of Australia. This statement has been developed to protect the interests of people who agree to participate in human research studies. Research will be monitored on an ongoing basis using established governance processes. These include experienced researchers leading the project, a dedicated project manager, project timelines and budget documentation established. Progress reports are provided to the funding body and the ethics committee on a regular basis.

Details about the ethics pertaining to any current research project including the research ethics number can be found in the Terms of Service. If you have any complaints about any aspect of the project, the way it is being conducted or any questions about your rights as a research participant then you may contact:

The Human Research Ethics Office, Deakin University, 221 Burwood Highway, Burwood Victoria 3125, Telephone: 9251 7129, research-ethics@deakin.edu.au. Please quote project number for any current research trial which can be found in our Terms of Service when a research trial is being conducted

3. How we share information

Your information is collected and stored on the Cogniss platform. It is accessible by Cogniss employees. It is shared with Deakin researchers named in specific research trials for the purposes of conducting the evaluation of the app. This is explained in full in Terms of Service when a research trial is in operation. Your contact information (email, mobile number) and the data you enter into the app will be stored in separate password protected files on the Cogniss and Deakin University servers. Your personal information is not shared in any other way.

Sharing with third-party partners and organisations

We may occasionally share data with other researchers or research organisations for the purposes of conducting new research. This data will be aggregated and de-identified (i.e., all user identifiable information will be removed) to protect your privacy. We do not share any information that personally identifies you

4. Your rights and choices

Data retention

Data is retained on both Cogniss and Deakin University servers. In both cases, your contact information (email, mobile number) and the data you enter into the app will be stored in separate password protected files to maintain confidentiality.

Data is retained on Cogniss servers only as long as necessary to provide you with our Services and for legitimate and essential business purposes, including those described above.

Data is downloaded onto password protected servers at Deakin University for research purposes as outlined in the Terms of Service. Once data is downloaded onto Deakin servers, it is kept for a minimum of five years after the final publication of the evaluation results for any particular study.

Deleting your account

You can close your account at any time. When you close your account, you will no longer be able to access it. Data you have provided will be removed and archived.

If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:

• If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;

• Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,

• Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

Please note that, for technical reasons, there is likely to be a delay in deleting your personal information from our systems when you ask us to delete it.

Rights to access and control your personal data

Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information.

For personal data that we have about you, you may choose to:

• Delete Data: You can ask us to delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).

• Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.

• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).

• Right to Access and/or Take Your Data: In most cases, you can access a copy of your personal data by inputting your unique access code into Cogniss Insights at https://platform.cogniss.com/insights. Alternatively, can ask us for a cop y of your personal data.

You can access, update, change or delete personal information either directly in your account or by requesting us to do so at privacy@cogniss.com.

5. How we protect information we collect

The Cogniss platform maintains administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorised alteration, unauthorised disclosure or access, misuse and any other unlawful form of processing of, the personal information in their possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities.

Data to be used for research purposes is downloaded onto secure Deakin University Servers and retained only on these password-protected Deakin University Servers.

To maintain confidentiality personal information collected (email address, mobile phone number) is kept in separate password protected files in both Cogniss and Deakin servers.

6. Other important privacy information

International data transfers

The app is available on a platform that operates internationally and may transfer your personal information to Australia and third parties in locations around the world for the purposes described in this Privacy Policy. Specifically, Cogniss uses certain vendors in providing our Services. All services either fully comply with GDPR regulations or are to implement it shortly.

• Amazon Web Services – Hosting infrastructure for our Services (Cogniss stores app and user data on servers located in the United States)

• Google G Suite – Email communication with clients

• Google Analytics – Data analytics

Wherever your personal information is transferred, stored or processed by Cogniss, they will take reasonable steps to safeguard its privacy. If you have a complaint about their privacy compliance, please contact them at privacy@cogniss.com.

Please note that the countries where Cogniss operates may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. You agree to this risk when you create a Cogniss account, irrespective of which country you live in. If you later wish to withdraw your consent, you can delete your Cogniss account as described in the ‘Your Rights and Choices’ section.

Changes to this policy

We’ll update this Privacy Policy from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the “Effective Date” at the top of the Privacy Policy. If we make material changes to it or the ways we process personal information, we will notify you before they take effect (by, for example, sending you an email and/or push notification).

We encourage you to check back periodically to review this Privacy Policy for any changes since your last visit. This will help ensure you better understand your relationship with us, including the ways we process your personal information.

How to contact Us

If you have any queries or would like further information about this Privacy Policy, the app or research, please contact the research team on contactgamblingless@deakin.edu.au.

If you have any complaints about any aspect of a current research project, the way it is being conducted or any questions about your rights as a research participant then you may contact:

The Human Research Ethics Office, Deakin University, 221 Burwood Highway, Burwood Victoria 3125, Telephone: 9251 7129, research-ethics@deakin.edu.au. Please quote project number for the current trial which can be found in Terms of Service when a research trial is being conducted.