Privacy Policy
PRIVACY POLICY
OBJECTS
This Privacy Policy sets out our practices in relation to the collection, use, disclosure and handling of Personal Information.
In order to provide you with the best service we may ask you to provide us with Personal Information from time to time. We respect your Personal Information, and your privacy is important to us. We are committed to maintaining the highest standards to protect your Personal Information.
We comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). The Privacy Act and the APPs govern the way in which we must manage your Personal Information, and this Privacy Policy sets out our practices in relation to the collection, use, disclosure and handling of Personal Information.
This Privacy Policy also applies to all of our employees, agents, contractors, affiliates and any the related parties in relation to the collection, storage, use and disclosure of Personal Information in the Practice.
This Privacy Policy should be read in conjunction with the terms and conditions for the Website which are available at [insert website address] (Terms and Conditions). Any person using the Website should familiarise themselves with the Terms and Conditions and Privacy Policy of this Website, and ensure they review it from time to time.
In this Privacy Policy:
Health Information has the meaning set out in Section 6FA of the Privacy Act;
Personal Information has the meaning set out in Section 6 of the Privacy Act, and for the purposes of this Privacy Policy, includes Sensitive Information;
Practice means the medical practice operated by us;
Sensitive Information has the meaning set out in Section 6 of the Privacy Act;
Services means the services provided on the Website and through the Practice, being medical and health services;
us, we, and our means OTP HEALTH PTY LTD ACN 673 117 550 its employees, agents, contractors, affiliates and any other related parties;
Website means our website located at www.wombat.health; and
you and your refers to anyone who visits and/or uses the Website and/or is provided the Services.
OPERATION OF OUR POLICY
You will be made aware when any Personal Information is required that may allow us to identify or contact you.
Personal Information will usually be requested when you register for a particular Service with us. By consenting, either expressly or impliedly, to us processing your Personal Information, you will be deemed to have read and accepted the terms of this Privacy Policy.
We will not process your Personal Information, unless we have your actual or deemed consent.
Your Personal Information will only be used in accordance with this Privacy Policy.
You are free at any time to opt out of receiving information from us at the end of each communication.
COLLECTION OF PERSONAL INFORMATION
The Personal Information that we may collect and hold includes (but is not limited to):
full name;
mailing or street address;
email address;
telephone number;
date of birth;
gender; and
credit card and/or bank account information,
The Sensitive Information that we may collect and hold includes (but is not limited to) your Health Information such as:
medical information including medical history, medications, allergies, adverse events, immunisations, social history, family history and risk factors;
your Medicare number (where available) for identification and claiming purposes;
healthcare identifiers; and
health fund details.
By providing us with your Sensitive Information, you hereby consent to the collection, use and disclosure of the Sensitive Information if it is reasonably necessary for one or more of our functions or activities connected with the Services.
We may also collect some information that is not Personal Information because it does not identify you or anyone else. For example, we may collect aggregated information about how users use our Website.
We will collect Personal Information directly from you unless it is unreasonable or impracticable to do so. We will only ask you to provide information that is relevant to the Service that you have requested or to enable us to respond to your enquiry.
When collecting Personal Information from you, we may collect it at various stages, including (but not limited to):
when you engage us to provide the Services to you;
when you contact us via our social media pages;
when you contact us with an enquiry or complaint in relation to our Services;
when authorised people provide us with your Personal Information on your behalf;
when you attend one of our events;
through your access and use of our Website; and
when you apply for a job with us.
We may also collect Personal Information from third parties including data analysis agencies.
COLLECTION OF ANONYMOUS INFORMATION
In order to measure the success of our online advertising we may use pixels, or transparent GIF files, to establish which of our online adverts successfully bring people to our Website. The GIF files are provided by third parties who provide us with online advertising analysis. This system places a cookie on your browser when you enter our Website via online advertisements allowing us to see which online advertisements bring us the most visitors to our Website. Most web browsers automatically accept cookies but you can change your browser to reject them. It is still possible to access our Website without having cookies enabled.
The information collected on our behalf is anonymous and does not personally identify you, which, for statistical purposes includes:
your server address;
your top level domain name (e.g. .com, .gov, .au, etc.);
the date, time and length of your visit to the Website;
the pages you accessed;
the previous website you visited;
the type of browser you are using; and
the protocol version used (e.g. HTTP, FTP).
PURPOSES FOR COLLECTING, HOLDING, USING AND DISCLOSING YOUR PERSONAL INFORMATION
We may use Personal Information about you so that we can provide you with a high quality of customer service.
We collect, hold, use and disclose your Personal Information for the following purposes:
to provide the Services to you and to send communications to you;
to answer enquiries and provide information or advice about existing and new Services;
to advise you if we relocate;
to advise you if our Terms and Conditions or Privacy Policy have been updated or amended;
to assess the performance of the Website and to improve the operation of the Website;
to assess our customer service and to improve the Services;
to conduct business processing functions including providing Personal Information to our related bodies corporate, contractors, service providers or other third parties;
for administrative, marketing (including direct marketing and marketing research), planning, service development, quality control, human resources, educational and research purposes;
to provide your updated Personal Information to our related bodies corporate, contractors or service providers;
to update our records and keep your contact details up to date;
to process and respond to any complaint or enquiry made by you; and
to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country.
We may contact you regarding anything set out in the above by e-mail, post or telephone.
We may also collect Personal Information about third parties from you, such as Personal Information about your family members, so that we can provide Services to those third parties. If you provide Personal Information about a third-party individual to us, you must ensure that the third-party individual is aware of this Privacy Policy, understands it and agrees to accept it. If you provide Personal Information about a third-party individual and that individual does not have the capacity to understand and agree to these terms (for example, a minor), we require a parent or guardian to acknowledge and agree to this paragraph. The acknowledgement will be through the acceptance of the Terms and Conditions.
From time to time we may use the information you give us for marketing purposes. Other than as required by law, or as set out in this Privacy Policy, we will not disclose information about you to any third party without your consent. Your Personal Information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy. We will not use your Personal Information for any purpose for which you would not reasonably expect us to use your Personal Information. Additionally, we will not disclose your Sensitive Information without your consent, unless there is a need to disclose such information in accordance with the Privacy Act, or to comply with any other regulatory requirement.
We will immediately remove your Personal Information from our database if requested by you. We will do this in accordance with our policy on destroying Personal Information (see Destruction of Information), in order to keep your information secure.
Where possible, we will give you the option of not identifying yourself or of using a pseudonym. We may not always be able to interact with you in this manner, especially where it is required by law to identify you before providing certain information. In general, we will not be able to assist you anonymously or where you are using a pseudonym when it is impractical or we are required or authorised by law or a court/tribunal order to deal with you personally.
DIRECT MARKETING
By accepting the Terms and Conditions and providing us with your Personal Information, you consent to us sending you direct marketing communications by any of the methods listed above (see Purposes for Collecting, Holding, Using and Disclosing your Personal Information). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt out of receiving marketing communications from us by contacting us (see contact details below) or by using opt out facilities provided in the marketing communications, and we will then ensure that your name is removed from our mailing list.
Please note that by opting out of receiving marketing communications, you may still receive communications from us (such as invoices and notices) in relation to the Services you have purchased from us.
DISCLOSURE TO OVERSEAS RECIPIENTS
We may disclose your Personal Information to our related bodies corporates, contractors, third party suppliers, service providers, government and quasi-governmental organisations, prospective purchasers of part or whole of our business and stock exchanges located overseas for the purposes listed below (see Disclosure of Personal Information).
DISCLOSURE OF PERSONAL INFORMATION
We may disclose your Personal Information to:
our employees, related bodies corporate, contractors or service providers for the purposes of operating our Website and Practice, fulfilling requests by you, and to otherwise provide Services to you including, without limitation, suppliers and manufacturers, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, archivists and professional advisors such as accountants, solicitors, business advisors and consultants;
suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes;
government and regulatory bodies and law enforcement agencies;
third parties that are based overseas (including India, Pakistan, Malaysia and the Philippines) to provide general business and administrative services, including (but not limited to) customer service and medical transcription services; and
any other organisation for any authorised purpose with your express consent, including your insurers and your solicitors.
We may combine or share any information that we collect from you with information collected by any of our related bodies corporate.
Except as set out in this Privacy Policy, we will only disclose Personal Information with your consent or as required or allowed to do so by law.
By accepting the Terms and Conditions, agreeing to the Privacy Policy and providing us with your Personal Information, you consent to the disclosure of your Personal Information to overseas recipients. If you consent to the disclosure of your Personal Information to overseas recipients, you acknowledge and understand that:
your Personal Information may be transferred to a recipient located in jurisdictions that do not have data protection laws as comprehensive as those in Australia;
we will take reasonable steps to ensure that your Personal Information is handled in accordance with the Privacy Act and the APPs; and
notwithstanding the foregoing, we are not required to ensure or procure that those overseas recipients handle that Personal Information in compliance with the Privacy Act and the APPs, nor will APP 8 under the Privacy Act apply to such disclosure; and
we disclaim all responsibility and liability associated with such disclosure, and you will not have a remedy under Australian law.
ACCESS TO PERSONAL INFORMATION
We require accurate Personal Information about you to ensure you receive the best possible service from us.
You will be able to access Personal Information that we hold about you if it can be readily retrieved, subject to some exceptions allowed by law. Where we hold information that you are entitled to access, we will try to provide you with a suitable means of accessing it (for example, by mailing or emailing it to you).
To request access to your Personal Information, please contact us in writing. We may charge you a reasonable fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge you for simply making the request and will not charge for making any corrections to your Personal Information.
There may be instances where we cannot grant you access to the Personal Information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. In these instances, we will provide written reasons for any refusal.
UPDATING PERSONAL DETAILS
We take reasonable steps to ensure that your Personal Information is up-to-date whenever we collect it or use it. This may include, for example, using data obtained from third parties to verify the accuracy of your Personal Information.
If you find that current Personal Information we hold about you is inaccurate, incomplete or out-of-date, please contact us immediately and we will take reasonable steps to correct it.
INABILITY TO COLLECT PERSONAL INFORMATION
If you do not provide us with the Personal Information described above (see Collection of Personal Information), some or all of the following may happen:
we may not be able to provide the requested Services to you, either to the same standard as if we did have access to Personal Information, or at all;
we may not be able to process any third party discounts or benefits;
we may not be able to notify you of any updates to our Privacy Policy and/or Terms and Conditions;
we may not be able to provide you with information about Services that you may want, including information about discounts, sales or special promotions; or
we may be unable to tailor the content of our Website to your preferences and your experience of our Website may not be as enjoyable or useful.
SECURE STORAGE OF PERSONAL INFORMATION
We take reasonable steps to ensure we protect any Personal Information that we hold from misuse, loss and unauthorised access, modification and disclosure.
Your Personal Information may be stored in hard copy documents and electronically.
We maintain physical and electronic security over our paper and electronic data storage. We also maintain computer and network security. For example, we use firewalls (security measures for the Internet) and other systems such as user identifiers and passwords to control access to computer systems.
Although we take reasonable steps to maintain the security of our Internet connections, for reasons outside of our control, information transmitted to us over the Internet may not be absolutely secure. We assume no responsibility for disclosure of data due to errors in transmission.
If we become aware that any of your Personal Information has been accessed by an unauthorised party (Data Breach), we will notify you of the Data Breach within 72 hours of us becoming aware of such breach.
DESTRUCTION OF INFORMATION
If the Personal Information we collect is no longer needed for any purposes and we are not required by law to retain it, we have procedures in place to ensure that any document or record containing your personal or health information is disposed of in a manner that preserves your privacy.
We will immediately remove your Personal Information from its database if requested by you.
THIRD PARTY WEBSITES
Our Website may contain links to other mobile applications or websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party mobile applications or websites and we are not responsible, or in any way liable, for the privacy policies or the content of any third party mobile applications or websites. Third party mobile applications or websites are responsible for informing you about their own privacy practices.
We take precautions to protect your Personal Information collected through the Website, but in the event that our system is infiltrated by unauthorised third parties, we will not be liable for any resulting misuse of Personal Information.
INDEMNITY
Whilst we will use all reasonable endeavours to safeguard your Personal Information, we cannot guarantee that your Personal Information will be protected against unauthorised access, misuse or disclosure. We do not accept any liability for the improper actions of unauthorised third parties.
We also assume no responsibility or liability for third parties such as advertisers or other entities who utilise banner advertisements and links from our Website. If you click through a banner, advertisement, or link and submit your information to a third party, you will be subject to the privacy policies of that third party.
We will ensure that all employees and contractors are bound by a confidentiality agreement requiring that they do not use or disclose your Personal Information in a manner contrary to this Privacy Policy.
We retain your Personal Information in line with relevant legislation and for as long as the information is relevant to our business purposes as set out above (see Collection of Personal Information) or until you request that we remove the information by contacting us.
You agree to defend, indemnify, and hold harmless us, our officers, directors, employees, agents, subcontractors, licensors, and suppliers, from and against all claims, actions, demands, liabilities and settlements, arising in connection with your use of the Website and/or the Services or your breach of the Terms and Conditions.
CHANGES TO PRIVACY POLICY
All information which is held by us is governed by the latest version of this Privacy Policy at all times. We may change this Privacy Policy at any time without notice. We will use reasonable endeavors to let you know as soon as reasonably practicable after our Privacy Policy has changed.
COMPLAINTS
If you believe that your privacy has been breached, please contact us immediately using the contact information below and provide details of the incident so that we can investigate it.
We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint and undertake our own thorough investigation into such breach. We will attempt to confirm as appropriate and necessary with you, your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will investigate your complaint and advise you of the outcome of our investigations in writing.
If you feel we have failed to deal with your complaint in a satisfactory manner, you can make a complaint about the handling of your Personal Information by us to the Office of the Australian Information Commissioner (Australia) (https://www.oaic.gov.au).
CONTACT US
If you have any questions or suggestions regarding this Privacy Policy, or any concerns or a complaint relating to your Personal Information, please contact us via the contact page on this website.