1. Policy statement
We understand that information about you and your health is personal. We support your privacy and are committed to ensuring our collection and handling of your personal information complies with all applicable legislation including the Privacy Act 1988 (Cth) ("Privacy Act"), Australian Privacy Principles ("APPs") and other relevant local laws and regulations.
The health information that we receive and/or create about you that identifies you personally and relates to your past, present, or future health, treatment, or payment for healthcare services, may be protected health information under the provisions of the Privacy Act, health records legislation applicable in your State, and for customer records transferred overseas and maintained by us offshore, through the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the Health Information Technology for Economic and Clinical Health Act (“HITECH Act”).
2. Collection of Information
2.1 What is personal and health information?
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.
Sensitive information is a subset of personal information and includes health information, which is information about the physical, mental or psychological health of an individual, a disability of an individual, a health service provided to an individual including information about the individual's expressed wishes about health care and any information collected to provide a health service.
2.2 Information we collect from your use of the Services
We collect personal and health information about you in order to provide you with the Services. If you choose not to provide any of the information we seek to collect, we may be unable to provide you with the Services, or the Services we do provide may not suit your requirements.
The types of personal and health information we may seek to collect for the Services include the following:
- Contact Information. This includes your name, email address, mailing address and phone number so that we can contact and identify you.
- Demographic Information. This includes your gender and date of birth where considered necessary in order to provide you with the Services.
- Health Information. It is necessary that you provide us with requested background health information, including a history of medical and dental care to enable us to provide you with appropriate and quality Services as well as ongoing information about your health so that we can continue to provide quality Services.
- Financial Information. We may collect one or more of the following in order to process payment for the Services – insurance provider information, payment card numbers, bank account number, bank routing number.
2.3 Information we collect from your use of the Site
We also collect personal information about you when you use our Site, including, but not limited to the following:
- Account Information. When you register with us using the Site to create an account and become a registered user, you will need to provide us with certain personal information to complete the registration, including the categories of contact and financial information described above.
- Device Information. We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Site. For example, we may collect and analyse information such as (a) IP addresses, geolocation information (as described in the next section below), unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Site; and (b) information related to the ways in which you interact with the Site, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Site, the frequency of your use of the Site, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
- Location Information. We may collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Site), and may use that information to customize the Site with location-based information, advertising, and features. For example, if your IP address indicates an origin in Sydney, the Site may be personalised with Sydney-specific information and advertisements. In order to do this, your location information may be shared with our agents, vendors or advertisers. If you access the Site through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
2.4 Cookies and other electronic technologies
For more information on cookies, visit http://www.allaboutcookies.org.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject cookies; however, our Services may not function properly if you do so.
If you are interested in more information about interest-based advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link or TRUSTe’s Advertising Choices Page to opt-out of receiving tailored advertising from companies that participate in those programs.
Please note that even after opting out of interest-based advertising, you may still see Company’s advertisements that are not interest-based (i.e., not targeted toward you).
We may also use the tools outlined below in order to better understand users. As we adopt additional technologies, we may also gather additional information through other methods.
- Web Beacons: “Web Beacons” (a.k.a. clear GIFs or pixel tags) are tiny graphic image files imbedded invisibly in a web page or email that may be used to collect anonymous information about your use of our Site, the websites of selected advertisers, and the emails, special promotions or newsletters that we send you. The information collected by Web Beacons allows us to analyse how many people are using the Site, using the selected advertisers’ websites or opening our emails, and for what purpose, and also allows us to enhance our interest-based advertising.
- Website Analytics: We may use third-party website analytics services in connection with the website, including, for example, to register mouse clicks, mouse movements, scrolling activity and text that you type into the website or mobile application. These website analytics services generally do not collect personal information unless you voluntarily provide it and generally do not track your browsing habits across websites which do not use their services. We use the information collected from these services to help make the website easier to use.
- Mobile Device Identifiers: Mobile device identifiers are data stored on your mobile device that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of personal information (such as media access control, address and location) and traffic data. Mobile device identifiers help Company learn more about our users’ demographics and internet behaviours.
We are committed to providing you with meaningful choices about the information collected on our Site for third-party purposes, and that is why we provide above the Network Advertising Initiative’s “Consumer Opt-out” link, Digital Advertising Alliance’s Consumer Opt-Out Link, and TRUSTe’s Advertising Choices page. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations and solutions.
For more information about DNT signals, visit http://allaboutdnt.com.
2.5 Information from Third Parties
We will always endeavour to collect personal information directly from you, however in some cases we may need to obtain additional information about you from third parties such as our partners, your health providers, or others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.
Where requested by you and if it is practicable and lawful to do so, you may interact with us anonymously or using a pseudonym. For example, if you contact us with a general question and do not wish to be identified, we will not record your name unless we need it to adequately handle your question.
On some occasions, however, if you do not provide the personal information we request, we may not be able to provide you with the requested Services.
Company does not knowingly collect or maintain personally identifiable information from persons under 18 years of age without verifiable parental consent, and no part of the Services are directed at persons under 18. If you are under 18 years of age, then please do not use the Services. If Company learns that personally identifiable information of persons less than 18 years of age has been collected without verifiable parental consent, then Company will take the appropriate steps to delete this information if requested by you. To make such a request, please contact us at email@example.com.
3. Use of Information
We use the information that we collect for the following purposes:
- For the primary purposes for which you provided the information, for example to seek or receive the Services or to use or interact with us through the Site or otherwise;
- For other secondary purposes related to those primary purposes, including:
- to contact you when necessary or requested;
- to fulfill your purchase from us, including, to process your payments, communicate with you regarding your purchase or provide you with related customer service;
- to provide, maintain, administer, improve, or expand the Services, perform business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
- to customize and tailor your experience of the Services;
- to send mobile notifications (you may opt-out of this service)
- to improve our Services by tracking and analysing trends and usage, better understand who uses the Services and how we can deliver a better user experience.
- For marketing and advertising purposes, either with your consent or:
- to personalize your interactions with us by informing you of products, programs, events, services, and promotions of Company, our affiliates, our partners and/or third parties that we believe may be of interest to you (you may opt out of this service);
- to send emails and other communications that display content that we think will interest you and according to your preferences (which you may opt out of); and
- to send you news and information about our Services (which you may opt out of);
- For other purposes required or permitted under the Australian Privacy Principles or other laws, including;
- To prevent, detect, and investigate security breaches, fraud, and other potentially illegal or prohibited activities;
- To enforce the legal terms that govern your use of the Services; and
- To protect our rights or property.
- For any other purpose for which you have provided your consent.
4. Sharing of Information
- With dental providers, in connection with the Services you request;
- With third parties to provide, maintain, and improve our Services, including service providers who access information about you to perform services on our behalf;
- With our professional advisers, including lawyers, accountants and auditors or in connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, bankruptcy, divestiture or dissolution of all or a portion of our business (but only under non-disclosure and confidentiality agreements and protections);
- With government agencies, regulatory bodies and law enforcement agencies, or other similar entities if we believe that disclosure is reasonably necessary:
- to comply with any applicable law, regulation, legal process or governmental request;
- to lessen or prevent a serious threat to life, health or safety;
- to enforce applicable user agreements or policies;
- to protect the security or integrity of our Services; or
- to protect us, our users or the public from harm or illegal activities; and
- Otherwise, with your consent.
We may also share aggregated, non-personally identifiable information with third parties.
5. Cross-border disclosure
For any transfer of your information overseas, we take steps to ensure that the protection of your personal information is acknowledged and respected, however note that privacy and data protection regulations differ between different jurisdictions and may not offer the same level of regulatory protection as available in Australia under the Privacy Act and APPs. If you wish to discuss or require further information, please contact us using the contact details at the end of this policy.
6. Other sites
Our Services may contain links to other websites and those websites may not follow the same privacy practices as the Company. We are not responsible for the privacy practices of third party websites. We encourage you to read the privacy policies of such third parties to learn more about their privacy practices.
We take reasonable measures, including administrative, technical, and physical safeguards, to help protect personal information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure and so while we strive to protect your personal information, the Company cannot ensure or warrant the security of any information you transmit to us or from our online products or services, and you do so at your own risk.
8. Contacting us
8.1 How to request access or correction
You may request to access, update or correct information that Company holds about you at any time or by emailing us at firstname.lastname@example.org.
8.2 How to lodge a complaint
If wish to make a complaint about how the Company has collected or handled your personal or health information, you can make a complaint in writing be email to the address set out at the end of this policy. We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.
If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner ("OAIC") via the OAIC website, www.oaic.gov.au.