Two Grains Pty Ltd Privacy Policy

We understand that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our mobile application Services to you. In this Privacy Policy we, us or our means TwoGrains Pty Ltd (ABN 46 639 936 093).

Types of information 

Personal information: is information or an opinion, whether true or not and whether recorded in a  material form or not, about an individual who is identified or reasonably identifiable. 

Sensitive information: is a sub-set of personal information that is given a higher level of protection.  Sensitive information means information relating to your racial or ethnic origin, political opinions,  religion, trade union or other professional associations or memberships, philosophical beliefs, sexual  orientation or practices, criminal records, health information or biometric information.  

The information we collect 

Personal information: The types of personal information we may collect about you include:

  • your name; 
  • your contact details, including email address, and/or telephone number;   your preferences and/or opinions;  information you provide to us through customer surveys; 
  • details of services we have provided to you through the App, including topics you have  selected, plans and documents you have created, meetings you have scheduled, and  whether concerns of yours were resolved or unresolved;  
  • your geo-location data, device and network information, statistics on page views and  sessions, acquisition sources, search queries and/or browsing behaviour; 
  • information about your access and use of our Services; 
  • additional personal information that you provide to us, directly or indirectly, through  your use of our Services, associated applications, and/or accounts from which you  permit us to collect information; and 
  • any other personal information requested by us and/or provided by you or a third party.

Sensitive information: We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.

How we collect personal information 

We collect personal information in a variety of ways, including: 

  • Directly: We collect personal information which you directly provide to us, including when you register for an account, and when you upload information into the App.  
  • Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our App or request help from us about the  App.  
  • From third parties: We collect personal information from third parties, such as employers when they ask us to invite you to use the App, details of your use of our App from our analytics and marketing providers.  

Collection and use of personal information 

Personal information: We may collect, hold, use and disclose personal information for the following  purposes: 

  • to enable you to access and use our Services, including to provide you with a login; 
  • to provide our Services to you, including returning data owned by the employer to the  employer; 
  • to contact and communicate with you about our Services; 
  • for internal record keeping and administrative purposes; 
  •  for analytics, market research and business development, including to operate and  improve our Services; 
  • for advertising and marketing, including to send you promotional information about our  products and services and information that we consider may be of interest to you; 
  • to comply with our legal obligations and resolve any disputes that we may have; and 
  • if otherwise required or authorised by law.

Disclosure of personal information to third parties 

We may disclose personal information to: 

  • third party service providers for the purpose of enabling them to provide their services,  to us, including (without limitation) IT service providers, data storage, web-hosting and  server providers, maintenance or problem-solving providers, marketing or advertising  providers and professional advisors; 
  • our employees, contractors and/or related entities; 
  • our existing or potential agents or business partners; 
  • anyone to whom our business or assets (or any part of them) are, or may (in good faith)  be, transferred; 
  • courts, tribunals, regulatory authorities and law enforcement officers, as required or  authorised by law, in connection with any actual or prospective legal proceedings, or in  order to establish, exercise or defend our legal rights; and
  • any other third parties as required or permitted by law, such as where we receive a  subpoena. 

Overseas disclosure: Where we disclose your personal information to third parties listed above,  these third parties may store, transfer or access personal information outside of Australia.  

Relationship between us, your employer and your information: In general, your personal information stored on the App will not be disclosed to your employer except as required by law, with your consent, or once your employment ends and the data stored on the App is returned to your employer for its records. However, your employer will receive reports and analytics regarding your use of the App. Through the dashboard available in our mobile application, your employer and its chosen administrators will have access to high level information about cases within your organisation which means, the topic name of the case, its status (for example whether a meeting has been held),  the initiator of the case, the participant and the case result (being “open” or “closed”).

Your rights and controlling your personal information 

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this  Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services. 

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.  

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication. 

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. 

Correction: If you believe that any information we hold about you is inaccurate, out of date,  incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date,  incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. 

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you,  in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. You also have the right to contact the relevant privacy authority.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference,  loss and unauthorised access, modification and disclosure. 

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.  

Links to other websites 

Our Services may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy. 


We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy  Policy on our mobile application. We recommend you check the Privacy Policy in them mobile application regularly to ensure you are aware of our current Privacy Policy

For any questions or notices, please contact our Privacy Officer at: 

TwoGrains Pty Ltd ABN 46 639 936 093 


Last update: 12 May 2021