THERATRAK – PRIVACY POLICY
This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our website and mobile application (Site). In this Privacy Policy we, us or our means Theratrak Pty Ltd ABN 95 623 821 250.
Personal information
The types of personal information we may collect about you include:
your name;
images of you;
your contact details, including email address, mailing address, street address and/or telephone number;
health information;
your age and/or date of birth;
your credit card details;
your demographic information, such as postcode;
your preferences and/or opinions;
details of products and services we have provided to you and/or that you have enquired about, and our response to you;
your browser session and 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 Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
additional personal information that you provide to us, directly or indirectly, through your use of our Site, associated applications, associated social media platforms 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.
We may collect these types of personal information directly from you or from third parties.
Collection and use of personal information
We may collect, hold, use and disclose personal information for the following purposes:
to enable you to access and use our services, Site, associated applications and associated social media platforms;
to store the records in our database in order to send home program information to users;
to contact and communicate with you;
for internal record keeping and administrative purposes;
for analytics, market research and business development, including to operate and improve our services, Site, associated applications and associated social media platforms;
to offer additional benefits to you;
for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
to comply with our legal obligations and resolve any disputes that we may have; and
to consider your employment application.
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, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
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;
credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
third parties, including agents or sub-contractors, who assist us in providing information, products or services to you. This may include parties located, or that store data, outside of Australia; and
third parties to collect and process data, such as Instabug, Google Analytics and Mixpanel or other relevant businesses.
By providing us with personal information, you consent to the disclosure of your personal information to third parties who reside outside Australia and acknowledge that we are not required to ensure that those third parties comply with Australian privacy laws.
How we treat personal information that is also sensitive information
Sensitive information is a sub-set of personal information that is given a higher level of protection under the Australian Privacy Principles. 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 type of sensitive information we may collect about you includes:
Health information about patients;
Professional associations or memberships of users; and
Professional registration identifiers of users.
We will not collect sensitive information about you without first obtaining your consent.
Provided you consent, your sensitive information may only be used and disclosed for purposes relating to the primary purpose for which the sensitive information was collected, including:
Providing services for a purpose that is directly related to the primary purpose for which the sensitive information was collected;
Communication between treating clinicians (users) about a patient’s case;
Verification of users credentials and qualifications; and
Data analytics purposes.
Sensitive information may also be used or disclosed if required or authorised by law.
Your rights and controlling your personal information
Choice and consent: Please read this Privacy Policy carefully. By providing personal information to us, you consent to us collecting, holding, using and disclosing 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 your use of this Site or the products and/or services offered on or through it.
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.
You warrant that where data contains any third party personal information of a patient, in order to post, upload, publish, transmit, store or otherwise use or disclose such personal information via the services, you, as required by applicable law, have:
● provided a consent form to such patient, or their guardian; and
● obtained the requisite consent; and
● only to the extent necessary will you disclose data to other registered health practitioner(s) involved in the management of a particular third party case to which that data relates.
Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.
Access: You may request details of the personal information that we hold about you. An administrative fee may be payable for the provision of such information. In certain circumstances, as set out in the Privacy Act 1988 (Cth), we may refuse to provide you with personal information that we hold about you.
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 correct any information found to be inaccurate, incomplete, misleading or out of date.
Complaints: If you believe that we have breached the Australian Privacy Principles and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. 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 to deal with your complaint.
Unsubscribe: To unsubscribe from our e-mail 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.
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 the personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
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. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.
Cookies and web beacons
We may use cookies on our Site from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our Site with personal information, this information may be linked to the data stored in the cookie.
We may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see https://policies.google.com/technologies/partner-sites or any other URL Google may use from time to time.
Links to other websites
Our Site 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.
Amendments
We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our Site. We recommend you check our Site regularly to ensure you are aware of our current Privacy Policy.
For any questions or notices, please contact our Privacy Officer at:
Theratrak Pty Ltd: ABN 95 623 821 250
Email: [admin@theratrak.co]
Last update: 2 July, 2018
