Privacy Policy

1. About this Privacy Policy

HappyWink (“HappyWink”, “we”, “us” or “our”) is an online platform designed to help people seeking care and support services connect with suitable independent service providers.

HappyWink is operated by:

• Legal entity: HappyWink
• ABN: 87 661 137 104

This Privacy Policy explains how we collect, hold, use, disclose and protect personal information when individuals use the HappyWink website, platform, user accounts, provider accounts and related services.

We are committed to handling personal information in accordance with applicable Australian privacy laws, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles where they apply to us.

2. Our Role

HappyWink operates as a care-matching and connection platform. We help people seeking care or support identify and connect with independent providers that may be able to meet their needs.

Unless expressly stated otherwise, HappyWink does not itself provide the underlying care or support service and does not employ or control the independent providers available through the platform.

Providers are responsible for determining whether they can provide a requested service and for complying with the laws, registrations, qualifications, insurance, screening and other requirements applicable to their services.

3. Personal Information We May Collect

The information we collect depends on how you use HappyWink.

Care requests

When you submit a care request, we may collect information including:

• whether the care is for you or another person;
• the postcode or general area where care is required;
• how quickly care is required;
• the type of support or service requested;
• how the care or support is funded and how a relevant funding plan is managed;
• additional information you voluntarily include about the request;
• your name, email address and telephone number; and
• information relating to the progress or status of your care request.

You do not need to create a full HappyWink account simply to submit an initial care request. You may browse general website information without identifying yourself. We need sufficient contact and request information to arrange provider responses; if required information is not supplied, we may be unable to process a request.

User accounts and profiles

If you choose to create a HappyWink account or complete a fuller user profile, we may collect additional information such as account and login information; residential or contact address; profile preferences; saved or previous care requests; provider connections; account activity; communication preferences; and other information you voluntarily add to your profile.

Providing information for a full user profile is optional unless particular information is required to use a specific platform feature. A residential address held as part of your HappyWink profile will not automatically be disclosed to providers simply because they have accessed a care opportunity.

Provider information

If you register as a provider, we may collect business or organisation name, ABN, business contact information, contact person details, business address, service areas, services offered, accepted funding types, provider registration status and details, verification information, subscription information, HappyWink Coin balances and activity, care opportunity access and activity, account activity, billing and payment-related information, and communications with HappyWink.

HappyWink verifies an organisation's ABN and, where applicable, claimed provider registration status. Providers remain responsible for ensuring that they maintain all registrations, licences, insurance, worker screening, qualifications and other requirements necessary to lawfully deliver their services.

4. Sensitive Information

HappyWink does not generally require users to provide detailed medical histories, diagnoses or clinical records when submitting a care request. However, information relating to disability, health or care needs may constitute sensitive information under Australian privacy law.

A user may voluntarily include such information in the additional details section of a care request or elsewhere on the platform. We collect sensitive information only where it is reasonably necessary for our activities and we have the individual's valid consent, or where an applicable legal exception permits collection. Where required, our care-request process seeks specific consent to collect and share relevant sensitive information with matched providers.

We encourage users to provide only information reasonably necessary to help providers understand and respond to their care request.

5. Information About Another Person

HappyWink allows a care request to be submitted by the person requiring care or by another person acting on their behalf. If you provide personal information about another person, you confirm that you have appropriate authority or permission to provide that information to HappyWink and to allow us to handle it for the purposes described in this Privacy Policy.

Where a care request relates to a child, the request should be submitted by a parent, legal guardian or another person appropriately authorised to act on the child's behalf.

6. How We Collect Personal Information

We may collect personal information directly from you through the HappyWink website or platform; when you submit a care request, create or update an account, register as a provider, communicate with us, complete verification, purchase or maintain a subscription, respond to surveys, forms or feedback requests, through cookies and similar technologies, and from publicly available or authorised sources where reasonably necessary for verification or operation of the platform.

7. Why We Collect and Use Personal Information

We may collect, hold, use and disclose personal information to operate the HappyWink platform; receive and manage care requests; identify relevant providers; facilitate connections; allow providers to respond to relevant opportunities; manage accounts; enable users to track their journey; verify provider information; manage subscriptions, payments and HappyWink Coins; communicate about platform activity; provide support; manage complaints and disputes; prevent fraud and misuse; maintain system security; improve our services; conduct analytics; comply with legal obligations; and send marketing communications where permitted and appropriately consented to.

8. How Care Request Matching Works

When a care request is submitted, HappyWink may make limited information about the request available to providers that offer the requested type of service within the relevant service area. Before accessing an opportunity, providers see a limited summary of the requested service, general location and funding or plan-management type. This summary does not include the requester's name, telephone number, email address, residential address or optional free-text description.

For example, a provider may initially see: Service: Personal Care; Location: Benalla VIC; Funding: NDIS – Plan Managed.

A provider may use the required number of HappyWink Coins to access an eligible care opportunity. Once a provider accesses it, HappyWink may provide information necessary to contact the requester, including name, telephone number, email address, general location, funding information, requested service information and appropriate additional information voluntarily included with the request.

A residential address stored in a user's full HappyWink profile is not automatically provided to a matched provider. Unless a request is closed earlier, up to five providers may be permitted to access a care request and contact the requester. Once closed, a request will no longer be available for new provider access, although providers who previously received the information may retain it subject to their own legal and privacy obligations.

9. Automated Matching and Recommendations

HappyWink may use automated systems to help identify, filter, rank or recommend providers or care opportunities. These systems may take into account requested service, service location, provider service areas, funding type, provider registration, preferences, availability or eligibility criteria, platform activity and other relevant matching factors.

Automated matching is intended to help connect users and providers efficiently. We may update matching factors and technologies as the platform develops. Where required by applicable privacy law, we will provide additional information about automated decisions that use personal information and could reasonably be expected to significantly affect an individual's rights or interests.

10. Provider Contact

Once a provider has legitimately accessed a care opportunity through HappyWink, the provider may contact the requester directly using the contact information supplied through the platform. Any subsequent arrangement for the delivery of services is generally between the person seeking care and the independent provider.

Providers that receive personal information through HappyWink are responsible for handling that information in accordance with applicable privacy and other laws.

11. Payments, Subscriptions and HappyWink Coins

“HappyWink Coins” means digital platform credits made available to eligible providers through a HappyWink subscription or other permitted purchase or allocation. Providers may use HappyWink Coins to access eligible care opportunities on the platform. HappyWink Coins are platform credits only and are not cryptocurrency, legal tender, stored monetary value or an investment product.

We collect and hold provider subscription details, HappyWink Coin balances, allocations, purchases where offered, and use or adjustment history to administer provider access, transactions and support enquiries. Provider subscriptions may be paid through recurring direct debit or other payment methods made available through HappyWink.

HappyWink uses third-party payment service providers, including Stripe, to facilitate payments. Payment providers may collect and process information necessary to establish payment authorisations, process recurring payments, manage failed transactions, refunds or disputes, and meet legal or financial obligations. HappyWink does not need to directly store complete bank account or payment card details where those details are securely handled by our payment provider. Payment providers may handle personal information under their own privacy policies and terms.

12. Marketing Communications

HappyWink may send operational communications necessary to administer a care request, account, subscription, provider opportunity or other platform service. These communications are separate from optional marketing communications.

Where required, we will obtain consent before sending promotional emails, SMS messages or other electronic marketing. Users and providers may withdraw their marketing consent or unsubscribe using the mechanism in the relevant communication or by contacting us. Unsubscribing does not prevent necessary service, account, security, transaction or care-request communications.

13. Cookies, Analytics and Similar Technologies

HappyWink may use cookies and similar technologies to operate and secure the website, remember preferences, understand how the platform is used, measure performance and improve our services. We may also use analytics, advertising or measurement technologies provided by third parties. As our technology providers and analytics tools are finalised, this Privacy Policy may be updated to provide additional information about those services where required.

14. Disclosure of Personal Information

We may disclose personal information to providers matched with or responding to care requests; technology and hosting providers; payment processors; communications and email service providers; customer relationship management providers; analytics and platform service providers; professional advisers; government agencies, regulators, law enforcement bodies or courts where required or authorised by law; parties involved in investigating fraud, security incidents or misuse; and other parties where you have consented or disclosure is otherwise permitted by law.

We do not sell care seekers' personal information as a general marketing database. Provider access to a care opportunity through HappyWink's HappyWink Coin and subscription system is part of the care-matching service described in this Privacy Policy and is subject to the consent and platform terms applicable to the care request.

15. Overseas Disclosure and Storage

Some third-party technology, cloud, payment, analytics or communications providers used by HappyWink may store or process information outside Australia. The countries involved depend on the service providers and infrastructure used by HappyWink.

Where required by law, HappyWink will take reasonable steps in relation to overseas disclosures of personal information. As our technology infrastructure is finalised, we may update this Privacy Policy with further information about relevant overseas locations.

16. Security

HappyWink takes reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure. Measures may include appropriate access controls, authentication, secure technology infrastructure, monitoring, staff or contractor controls, backups and other technical and organisational safeguards appropriate to the information being handled.

No internet-based system can be guaranteed to be completely secure. Users should also take reasonable steps to protect their account credentials and notify HappyWink if they suspect unauthorised access.

17. Data Breaches

HappyWink maintains processes for responding to suspected or confirmed data breaches. Where a data breach is likely to result in serious harm and notification is required under applicable Australian law, HappyWink will take appropriate steps to assess the incident and notify affected individuals and relevant authorities as required.

18. How Long We Keep Information

HappyWink retains personal information only for as long as reasonably necessary for the purposes for which it was collected, including providing and administering the platform; maintaining accounts; managing care requests, provider relationships and verification; maintaining transaction and subscription records; resolving complaints and disputes; preventing fraud or misuse; complying with legal, accounting and regulatory obligations; and establishing, exercising or defending legal rights.

As an operational guideline, care-request information may generally be retained for up to 12 months after the request has been closed or expired, unless there is a reason to retain it for longer or a shorter period is appropriate. When we no longer need personal information for a permitted purpose, we will take reasonable steps to destroy or de-identify it unless a legal recordkeeping requirement or other applicable exception requires retention.

19. Accessing and Correcting Your Information

You may request access to personal information HappyWink holds about you and request correction of information that is inaccurate, out of date, incomplete, irrelevant or misleading. Where account functionality permits, some information may be reviewed or updated directly through your account. For other requests, use the contact details below.

We may need to verify your identity before processing an access or correction request. There may be limited circumstances in which access cannot be provided. Where required, we will explain the reason.

20. Closing an Account or Care Request

Users may be able to close care requests through available platform functionality or by contacting HappyWink. Closing a care request prevents new providers from accessing that opportunity but does not necessarily require immediate deletion of information already held by HappyWink or previously disclosed to providers.

Users may also request closure of their HappyWink account. We may retain certain information following account closure where reasonably necessary or required by law, including information relating to transactions, disputes, fraud prevention, complaints or legal obligations.

21. Children

HappyWink may facilitate care requests concerning individuals under 18 where the request is submitted by a parent, guardian or another appropriately authorised person. HappyWink is not intended to enable children to independently enter into provider arrangements where they do not have legal capacity to do so. We may take additional steps to confirm authority or consent where reasonably necessary.

22. Emergency Situations

HappyWink is not an emergency service. If you or another person is in immediate danger or requires urgent emergency assistance, call 000. A care request submitted through HappyWink should not be used as a substitute for emergency medical, police, fire or crisis services.

23. Complaints About Privacy

If you have concerns about how HappyWink has handled your personal information, please contact us first so we can investigate and respond.

Privacy contact: HappyWink
Email: hello@happywink.com.au

We may ask you for sufficient information to understand and investigate the complaint. We will acknowledge the complaint, investigate the relevant circumstances and provide a response explaining our findings and any proposed resolution. We aim to respond within 30 days; if more time is needed, we will explain the delay and expected response timeframe.

If you are not satisfied with our response, or we have not responded within 30 days, you may be able to complain to the Office of the Australian Information Commissioner (OAIC) or another relevant regulator.

24. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to the HappyWink platform, our technology, our provider and matching processes, legal or regulatory requirements, or our information-handling practices. The current version will be published on the HappyWink website with its effective or last-updated date. Where a change materially affects how we handle personal information, we may take additional reasonable steps to notify affected users.