Headsafe MFG Privacy Notice

Table of Contents


We are Headsafe MFG Pty Ltd (ABN: 93166 929 924). This Privacy Notice explains how we collect, use, maintain and disclose Personal Information which we collect personal information that is provided by you when you:

We take your privacy and data security seriously. We comply with the Privacy Act 1988 (Cth) (Act) and the Australian Privacy Principles.

We have processes and practices in place that respect and protect your personal privacy and dignity.

If you have any questions about this policy, please contact us.

What is the scope of this notice?

This Privacy Notice applies to Personal Information collected by us, except for employee records.

‘Personal Information’ has the meaning given to it in the Privacy Act 1988 (Cth).

In general terms, it is any information that can be used to personally identify you. This includes your name and contact details including phone numbers and email addresses.

If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered Personal Information.

When you were registered on the App, you were asked to consent to us processing your Personal Information. If this did not occur, please contact us immediately.

By registering on the App or the Website, you consent to the collection and use of your Personal Information, including Personal Information you provide in the manner we describe in this Privacy Notice.

What Personal Information do we collect and how do we collect it?

We collect the following Personal Information from you.

  • Your name
  • Your date of birth
  • Your gender
  • Your photo
  • Your email address
  • Your phone number

This information is necessary for us to be able to be able to provide our service, including contacting you regarding this service when we need to. If you would like us to provide this service, you will need to consent to us collecting and processing this information.

Medical information

We collect Medical Information from you through the App. This is information about your health. Medical Information is a type of Personal Information.

The Nurochek device allows doctors to measure your brain patterns to help them assess your brain function.

  • First, it is necessary to take a ‘baseline’ measurement.
  • Then, if you suffer an injury event in the future, a second measurement can be taken after you have suffered that injury.

You may withdraw your consent by contacting us. When you withdraw your consent, we will stop processing any of your Personal Information that we need your consent to process.


We will only collect, use or disclose Personal Information of children with the consent of a parent or legal guardian.

We will stop processing Personal Information if a parent or legal guardian withdraws consent.

We will also stop processing Personal Information if a child withdraws consent given by parent or legal guardian when they are old enough to validly give and withdraw consent.


Our Website makes a record of the users visit and logs anonymous information for statistical purposes. This includes your top-level domain name (for example .com or .au), the date and time of you visit, what pages on the Site you accessed, what search engine and what type of browser you used.


Cookies are unique identification numbers which are placed on your browser. Cookies do not identify you personally, but they may link back to a database record about you.

If you register on our Site, we will link your cookies back to your Personal Information.

We use cookies to monitor usage of the Site, to enable purchases, and to create a personal record of when you visit our Site and what pages you view. Cookies are necessary to enable certain functions on our web site, but if you do not wish us to retain any Personal Information about your visit to our site you can simply delete the cookies on your browser and change the settings on your web browser program.

We use the following cookies:

Name Privacy Notice Purpose
Google Analytics http://www.google.com/intl/en/policies/privacy/ These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.
PayPal https://www.paypal.com/en/webapps/mpp/ua/privacy-full These cookies are collected to maintain your preference selections in between visits to our website.

This cookie collection stores information to help provide you with a better, faster, and safer experience.

How and why do we use your personal information?

We collect, use and disclose your Personal Information so we can:

  • confirm your identity;
  • assess your application;
  • design, manage, price and provide our Platform and related services;
  • manage our relationship with you;
  • minimise risks and identify or investigate fraud and other illegal activities;
  • contact you, for example, when we need to tell you something important;
  • carry out technical analysis to determine how to improve the Platform;
  • improve our service to you and your experience with us;
  • comply with laws and assist government or law.

How do we store your personal information?

We store your information on secured servers on our dedicated hosted servers.

Your Personal Information even if collected by us in Australia may be transferred to and stored in a country that is not Australia (on a temporary or permanent basis).

How do we keep your information safe?

When you log into our Sites or apps, we encrypt your data so that no one else can access it.

We use digital certificates, passwords, and firewalls to prevent unauthorised access to our systems.

We destroy or de-identify your Personal Information when it is no longer required.

We are not responsible for the Privacy Notice of any other site to which the site has a hyperlink. We advise you to look at the Privacy Notice of other sites before disclosing Personal Information.

Why do we disclose your personal information?

Unless there are exceptional circumstances, we will not disclose your Personal Information for a purpose other than those listed here without your consent.

In exceptional circumstances we may need to use or disclose your Personal Information without your consent. This will be limited to protecting the safety of you or another person, or as required by law.

We will disclose Personal Information if our assets and operations are transferred to another party as a going concern.

Service providers

We use a number of third-party service providers.

We may disclose your Personal Information to third parties in accordance with this Privacy Notice and also where it is reasonably necessary in order to enable us to provide our services to you and support your use of the Site, when we are required to do so by law or when you give us permission to do so.

Overseas disclosure

Where we disclose your Personal Information with businesses that are overseas, we make sure there are arrangements in place to protect your Personal Information.

By registering as a user of and accessing our Site, you agree:

  • to and authorise us giving your personal information, in accordance with this Privacy Notice, to a third party who is not in Australia or a third party who may transfer and store outside Australia your Personal Information (Overseas Recipient);
  • that, while we will take reasonable steps to ensure that an Overseas Recipient does not breach the Australian Privacy Principals (APPs), Overseas Recipients are not bound by the APPs and subclause 8.1 of the APPs does not apply to the disclosure of your Personal Information to an Overseas Recipient; and
  • that, if an Overseas Recipient handles your information in breach of the APPs, you will not be able to seek redress under the Act.

Direct marketing

We will use your email address to send you emails to update you about our services. You may opt out of these emails at any time.

We comply with the requirements of the Spam Act 2003 (Cth).

We will contact you to communicate relating to an outstanding request, responding to an email communication and for marketing purposes.

How can you access, correct and update the personal information about you that we hold?

You can access the Personal Information that we hold that is about you. You can request access by emailing us at privacy@nullheadsafe.com. When you request access, we will need to confirm your identity.

Is there a fee?

There is no fee to ask to access the Personal Information, however we may charge a fee to find the Personal Information and put it into an understandable format. This fee will be an hourly charge and any costs for expenses such as photocopying. If you ask to access the Personal Information, we will provide you with details about how much it may cost.

How long will it take?

We will try make your Personal Information available within 30 days. If it is going to take longer, we will let you know.

When we may refuse to give you your personal information

We will not provide you with your Personal Information when you are no longer a user of our Platform or our services or when we cannot confirm your identity.

We will not provide you with your Personal Information where we are required not to be law, or in the context of litigation.

How can you update your personal information?

If we hold Personal Information about you that is out of date or incorrect, you can ask us to update it. We will not charge for this. If we do not think the Personal Information is incorrect, we will explain to you why.

Will this privacy notice be updated?

This Privacy Notice may be amended without notification from time to time.

If you continue to use our Site after the changes are made, then you will be agreeing to the changes.

How can you contact us or make a complaint?

You may want to contact us about the Personal Information we hold about you (including to correct any Personal Information) or to ask a question about our Privacy Notice or to make a complaint related to a breach by us of the Act.

We will treat your queries and complaints confidentially.

Our representative will contact you within a reasonable time after receipt of your query or complaint to discuss your concerns and outline options regarding how they may be resolved.

We will aim to ensure that your query or complaint is resolved in a timely and appropriate manner. You may contact us by email at privacy@nullheadsafe.com.

If you have a complaint about our compliance with the Act and we have not resolved your complaint within 30 days’ after you first notified us of your complaint, you can refer your complaint to OAIC by visiting their site https://www.oaic.gov.au/.

Published: 5th November 2020

Headsafe MFG Pty Ltd

ABN: 93166 929 924

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