NIGEL (ChatBot) - Privacy Policy

The "ITHEUM", "CAREVIEW", "NIGEL" (ChatBot) & "Red Heart Challenge" product range is owned and operated by the Australian Register company Pauls & Mark Pty Limited (ABN 39 155 728 564). All references to the term “Application” in the scope of this document relates directly to the NIGEL (ChatBot) product.

NIGEL is the ChatBot Service provided by the ITHEUM platform to coach users who opt into Health and Wellness Programs that are built on top of the ITHEUM Platform. This privacy statement (“Privacy Statement”) applies to the treatment of personally identifiable information submitted by, or otherwise obtained from, you in connection with NIGEL (“Application”). By using or otherwise accessing the Application, you acknowledge that you accept the practices and policies outlined in this Privacy Statement.

1. WHAT CHANNELS DOES APPLICATION OPERATE OVER?

NIGEL communicates with registered users via the following channels.

  1. SMS - The registered users opt-in to have SMS messages sent to them. NIGEL can then send and receive chat messages from the user until:
    1. The user Opts out of being contacted via SMS.
    2. The user Completes a Health & Wellness Program they signed up for.
    3. The user Deletes their account from the ITHEUM Platform - see “What happens to a user’s data when an account is deleted?” section below
  2. Telegram - The registered users opt-in to have Telegram chat messages sent to them. NIGEL can then send and receive chat messages from the user until:
    1. The user Opts out of being contacted via Telegram.
    2. The user Completes the Health & Wellness Program they signed up for.
    3. The user Deletes their account from the ITHEUM Platform - see “What happens to a user’s data when an account is deleted?” section below
  3. Facebook Messenger - The registered users opt-in to have Facebook Messenger chat messages sent to them. NIGEL can then send and receive chat messages from the user until:
    1. The user Opts out of being contacted via Facebook Messenger.
    2. The user Completes the Health & Wellness Program they signed up for.
    3. The user Deletes their account from the ITHEUM Platform - see “What happens to a user’s data when an account is deleted?” section below

2. WHAT HAPPENS TO A USER’S DATA WHEN AN ACCOUNT IS DELETED?

Once an account is deleted by a User, we DO NOT persist any data in any medium or form. We destroy the account data from the database, all cache stores, data buckets and all backups. This process normally takes 14 days to complete.

3. WHAT PERSONAL INFORMATION DOES THE APPLICATION COLLECT?

We collect the following types of information from our users:

3.1. Personal Information You Provide to Us:

As part of your interactions with NIGEL we DO NOT request and store any specific information about you. NIGEL is the ChatBot of the ITHEUM platform (https://itheum.com) and as such if you join any Health and Wellness Program build on top of the ITHEUM platform (for e.g. Red Heart Challenge - redheartchallenge.com) we only collect information in order to create your account directly on ITHEUM. The information we collect as part of that process is mentioned specifically in the ITHEUM Privacy Policy located here (https://itheum.com/privacypolicy)

3.2. Personal Information Collected Automatically:

Depending on the “Channels” that NIGEL uses to communicate with a User, the following information is collected:

  1. SMS:
    1. We DO NOT collect any specific information from you during conversations over SMS. We only use the Mobile number you used to sign up to your central ITHEUM account for communication.
    2. We DO NOT store any copies of the SMS messages sent between both parties.
  2. Telegram:
  3. We receive and store only ONE piece of information from you during your interactions with NIGEL, this information is the “chat_id”, which is a unique identifier that identifies your Telegram account and lets our Telegram Bot @NigelBot send your messages.
    1. We DO NOT collect any other details from your Telegram Account.
    2. We DO NOT store any copies of Chat messages sent between both parties.
  4. Facebook Messenger:
  5. We receive and store only ONE piece of information from you during your interactions with NIGEL, this information is the “PSID” (Page Scoped ID), which is a unique identifier that identifies the interactions between your Facebook Account and the Facebook Page @nigelfromitheum (https://www.facebook.com/nigelfromitheum/).
    1. We DO NOT collect any other details from your Facebook Account.
    2. We DO NOT store any copies of Chat messages sent between both parties.

4. HOW DOES THE APPLICATION USE THE INFORMATION IT COLLECTS?

NIGEL uses the information described in this Privacy Statement (i) internally, to communicate with and coach you through the Health and Wellness Programs you signed up for via the ITHEUM Platform. We will never send any promotional material or messages that are not related to the tasks you have to complete as part of your ITHEUM program.

5. WILL THE APPLICATION SHARE ANY OF THE PERSONAL INFORMATION IT RECEIVES?

We DO NOT rent nor sell your personal information to anyone without your consent. You will be notified when your personal information may be shared with third parties, and you will be able to prevent the sharing of this information.

6. CONDITIONS OF USE.

If you decide to use or otherwise access the Application, your use/access and any possible dispute over privacy is subject to this Privacy Statement and our ITHEUM Platform Terms of Use, including limitations on damages, arbitration of disputes, and application of State of NSW (Australia) law.

7. THIRD PARTY APPLICATIONS/WEBSITES.

The Application may permit you to link to other applications or websites. Such third party applications/websites are not under Pauls & Mark Pty Limited’s control, and such links do not constitute an endorsement by Pauls & Mark Pty Limited of those other applications/websites or the services offered through them. The privacy and security practices of such third party application/websites linked to the Application are not covered by this Privacy Statement, and Pauls & Mark Pty Limited is not responsible for the privacy or security practices or the content of such websites.

8. 3RD PARTY TECHNOLOGY PROVIDERS.

The Application uses Developer SDKs (Software Development Kits) and Programming Tools (Libraries) provided by 3rd Party Technology Providers in order to provide messaging functionality to users. We use the Twilio platform (https://www.twilio.com/) for SMS functionality, the Telegram API (https://core.telegram.org/api) for Telegram messaging and the Facebook Messenger Developer Tools Platform (https://developers.facebook.com/docs/messenger-platform) for Facebook Messaging functionality. Such third party Technology Providers and their platforms are not under Pauls & Mark Pty Limited’s control and the privacy and security practices of such third party Technology Providers are not covered by this Privacy Statement, and Pauls & Mark Pty Limited is not responsible for the privacy or security practices of the 3rd Party Technology Providers.

9. CAN CHILDREN USE THE APPLICATION?

Our site and the services available through Pauls & Mark Pty Limited are not intended for children under the age of 18. Pauls & Mark Pty Limited does not knowingly or specifically collect information about children under the age of 18 and believes that children of any age should get their parents’ consent before giving out any personal information. We encourage you to participate in your child’s web experience.

10. CHANGES TO THIS PRIVACY STATEMENT.

Pauls & Mark Pty Limited may amend this Privacy Statement from time to time. Use of information we collect now is subject to the Privacy Statement in effect at the time such information is used. If we make changes in the way we use personal information, we will notify you by posting an announcement on our Site or sending you an email. Users are bound by any changes to the Privacy Statement when he or she uses or otherwise accesses the Application after such changes have been first posted.

11. QUESTIONS OR CONCERNS.

If you have any questions or concerns regarding privacy of the Application, please send us a detailed message at info@itheum.com. We will make every effort to resolve your concerns.


Effective Date: June 1, 2018

Last Updated Date: June 29, 2018