Privacy Policy

6 July 2020

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 platform (Platform). In this Privacy Policy we, us or our means Medinet Australia Pty Ltd ACN 610 094 712.

Our Privacy Policy has recently changed.  Please review its terms carefully.

Personal information

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

  • your name;
  • your contact details, including email address, mailing address, street address and/or telephone number;
  • your age and/or date of birth;
  • your demographic information, such as postcode;
  • your preferences and/or opinions;
  • information you provide to us through customer surveys;
  • details of 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 Platform, including through the use of Internet cookies, your communications with our Platform, 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 Platform, 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.

Personal information is defined in the Privacy Act 1988 (Cth) as information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable. Please note that personal information is distinct from commercially sensitive information such as medical Practitioner lists or pricing information. If we collect any commercially sensitive information from you, we deal with this information as set out in our Terms and Conditions. 

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 Platform, associated applications and associated social media platforms;
  • to enable you to use our platform, available on the Platform, to find and connect with Practitioners available to provide services to you;
  • 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 Platform, 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
  • to comply with our legal obligations and resolve any disputes that we may have.

How we treat your 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 but is not limited to health information, such as details of any current or previous medical conditions, copies of previous health records, your Medicare number, prescription information, tests results or scans.

We will not collect sensitive information about you without first obtaining your 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:

  • to connect you with medical Practitioners, using our platform;
  • to assist you with your inquiries, including to be connected with a medical Practitioner;
  • to assist a medical Practitioner in determining whether she or he can provide services to you; and/or
  • providing services for a purpose that is directly related to the primary purpose for which the sensitive information was collected.

If we have de-identified your sensitive information, such that you are no longer identifiable from it, we may also be use that de-identified sensitive information   for the purpose of analysing trends and conducting research/publication, including by disclosing that de-identified sensitive information to third parties.   Sensitive information may also be used or disclosed if required or authorised by law.

How we treat your identification information

Identification information is a term defined in the Privacy Act 1988 (Cth), and includes details such as your full name, your date of birth or your current or last known address.  We treat your contact details, such as your telephone number and your email address, the same way we treat identification information.

We will never disclose:

  • identification information about you;
  • your telephone number; or
  • your email address,

to a third party, other than:

  • medical practitioners, for the purposes of providing you with services through the Platform;
  • other third party service providers to whom disclosure is necessary to provide you with services through the Platform, such as IT, data storage, web-hosting and server providers;
  • our employees, contractors and/or related entities, to the extent necessary to provide you with our services and access to our Platform;
  • payment systems operators, including but not limited to Commonwealth Bank of Australia, but only to the extent required to make payment;
  • our professional advisers, such as our solicitors;
  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred, on the condition that they handle your personal information in accordance with this Privacy Policy;
  • credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you; and
  • 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.

Disclosure of personal information (that is not sensitive personal information or identification information) to third parties

For all other personal information that is not sensitive personal information or identification information described in preceding sections of this Privacy Policy, you consent to us disclosing that personal information without any additional prior written consent to the following third parties and for the following purposes:

  • third party service providers for the purpose of enabling them to provide their services to Medinet;
  • medical practitioners, for the purposes of providing you with services through the Platform;
  • other third party service providers to whom disclosure is necessary to provide you with services through the Platform, such as IT, data storage, web-hosting and server providers;
  • our existing or potential agents or business partners;
  • third parties to collect and process data, such as Google Analytics or other relevant businesses. This may include parties that store data outside of Australia.
  • medical practitioners, for the purposes of providing you with services through the Platform;
  • other third party service providers to whom disclosure is necessary to provide you with services through the Platform, such as IT, data storage, web-hosting and server providers;
  • our employees, contractors and/or related entities, to the extent necessary to provide you with our services and access to our Platform;
  • payment systems operators, including but not limited to Commonwealth Bank of Australia, but only to the extent required to make payment;
  • our professional advisers, such as our solicitors;
  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred, on the condition that they handle your personal information in accordance with this Privacy Policy;
  • credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you; and
  • 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.

Where we disclose your personal information to third parties, including medical Practitioners, we will request that the third party handle your personal information in accordance with this Privacy Policy.

Please note that we treat personal information that is sensitive personal information, and personal information that is identification information, differently. If we collect:

  • sensitive personal information from you, we only deal with this sensitive personal information as outlined in the clause ‘How we treat personal information that is also sensitive information’ above; and
  • Identification information from you, we only deal with this sensitive personal information as outlined in the clause ‘How we treat personal information that is also identification information’ above.

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 Platform and our ability to connect you with a specialist doctor.

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: 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 Platform 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 Platform with personal information, this information may be linked to the data stored in the cookie.

We may use web beacons on our Platform 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.

Links to other websites

Our Platform 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 Platform. We recommend you check our Platform regularly to ensure you are aware of our current Privacy Policy.

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

Medinet Australia Pty Ltd ACN 610 094 712

Email: feedback@medinet.com.au

Last update: 6 July 2020