Last Updated: August 2018
Ausmed Education Pty Ltd (ABN 33 107 354 441) ( Ausmed, we or us) is an Australian proprietary company registered in Victoria, Australia. Our offices are located at Level 1, 171 La Trobe Street, Melbourne, Victoria, 3000, Australia. Ausmed is the data controller and we are responsible for your personal data.
Our pledge to your privacy
We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) ( Privacy Act). The Australian Privacy Principles are designed to protect the confidentiality of information and the privacy of individuals. The Australian Privacy Principles regulate the way personal information is collected, used, disclosed and managed by us. You can obtain more information about the Australian Privacy Principles from the Office of the Australian Information Commissioner at www.oaic.gov.au.
Use of the Websites is governed by our Website Terms and Conditions We invite you to also read our Website Terms and Conditions, which you can access by clicking the link available in the Ausmed website footers, or which you can obtain by contacting Ausmed directly.
1. What is personal information / personal data?
Personal information / personal data is generally information or an opinion relating to an identified, or reasonably identifiable, individual.
The type of personally identifiable information / personal data we collect from you or third parties, may include:
- Identity Data which may include your first name, maiden name, last name, username, marital status, title, date of birth, gender and visual images.
- Contact Data which may include your billing address, delivery address, email address and telephone numbers.
- Financial Data which may include your bank account and payment card details.
- Transaction Data which may include details about payments between us and other details of purchases made by you, as well as details of services we have provided to you or that you have enquired about, and our response.
- Technical Data which may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data which may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses, professional information including, but not limited to, designation, registration status, endorsements and current employer, and any additional personal information that you provide to us directly or indirectly through your use of our Websites, associated social media platforms or accounts from which you permit us to collect information.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
What non-identifiable information do we collect?
The type of personally non-identifiable information and information obtained from third parties we collect may include:
- IP address;
- cookie information (see item 10. below for more detail);
- log files;
- domain names; and
- your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and browsing behaviour. This is collected to enable us to better serve your needs.
3. Sensitive information / sensitive data
Some of the information we collect may be 'sensitive information' or 'sensitive data', including information or an opinion about, racial or ethnic origin, membership of a professional or trade association or membership of a trade union (which is also personal information) that is also personal information, among other things. We collect this information in order to maximise the goods / services we provide to you via the Websites.
We may only use and disclose your sensitive information / sensitive data for the primary purpose for which it was collected, or for reasonably expected secondary purposes which are directly related to the primary purpose, or for purposes to which you have consented and in other circumstances authorised by the Privacy Act or GDPR (eg where required or authorised by law to be disclosed, or where disclosure is necessary to prevent a threat to life, health or safety).
Under the GDPR, we require your explicit consent for processing sensitive data, so when you submit your details, we will ask you to confirm your consent to this processing.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
4. Use of personal information / personal data
Personal information is collected for a range of reasons across our Websites. This may include registering for an educational event, subscribing to and using Ausmed services and commenting on content.
We will only use your personal information / personal data when legally permitted. The most common uses of your personal information / personal data are as follows:
- to perform the contract between us;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- to comply with a legal or regulatory obligation.
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a new customer||(a) Identity, (b) Contact||Performance of a contract with you|
|To provide you with the goods and services available on the Websites||(a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications, (f) Technical||(a) Performance of a contract with you, (b) Necessary to comply with a legal obligation, (c) Necessary for our legitimate interests to keep our records updated and to understand how customers use our products/services|
|To process and deliver your order including: (a) Manage payments, fees and charges, (b) Collect and recover money owed to us||(a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications||(a) Performance of a contract with you, (b) Necessary for our legitimate interests to recover debts owed to us|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications||(a) Performance of a contract with you, (b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business|
|To administer and protect our business and our Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity, (b) Contact, (c) Technical||(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, (b) Necessary to comply with a legal obligation|
|To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising||(a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications, (f) Technical||Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical, (b) Usage||Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile||Necessary for our legitimate interests to develop our products/services and grow our business|
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at firstname.lastname@example.org.
You will receive marketing communications from us if you have:
- requested information from us or purchased goods or services from us; or
- if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
- in each case, you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or OR by emailing us at email@example.com at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at firstname.lastname@example.org.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
5. Disclosure of your personal information
We do not sell or license your personal information to third parties.
- persons authorised by you in writing to receive information held by us or identified by us at the time the information is requested from you;
- external service providers that provide services to us;
- as part of any investigation into you or your activities where we reasonably believe that disclosure is necessary to the police, any relevant authority or enforcement body, or your internet service provider or network administrator;
- to credit reporting agencies and courts, tribunals and regulatory authorities where you fail to pay for goods or services provided to you;
- 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; and/or
- as required or permitted by any law (including the Privacy Act).
If you are accessing the Websites whilst in the European Union: Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria. Many of our third parties service providers are based outside the EEA, so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
- If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. Ausmed App
All information documented along with any attached files that relate to your personal use of the Ausmed App is private. This private information is not viewed for any purpose except to fix technological issues that may arise from time to time. In order to improve the functionality of the Ausmed App, big data (which refers to many people’s inputs into the Ausmed App) may be statistically analysed for patterns of use and behaviours. Big data is always analysed in a de-identified format which ensures there is no breach of personal privacy.
We do not sell any part of your personal information for use by other service providers.
7. Third party service providers and links to other websites
However, we do engage Google and other third party providers to assist with analytics in relation to the Websites (for example, tracking and reporting to Ausmed traffic to the Websites, and how users engage with the Websites).
We also engage third party service providers for storage of data via cloud storage.
8. How do we protect your personal information?
Ausmed takes reasonable measures (physical, organisational, managerial and technological) to safeguard against unauthorised access of your personal information, to safely store your personal information and to protect your personal information from modification or disclosure.
Some of the measures we take are:
- limiting physical access to our premises;
- requiring any third party providers to have acceptable security measures to keep personal information secure;
- having in place and regularly reviewing our internal policies and procedures specifically related to use of personal information and data;
- providing regular education to our staff in regard to privacy; and,
- ensuring our staff contracts include appropriate confidentiality restrictions.
Due to the nature of our service we may be required to store the details of your credit card. Ausmed works to protect the security of your credit card information when processing payments. We do this by using SSL encryption software. We encourage all users and subscribers of our services to protect themselves against unauthorised access to their account and to keep their login details confidential. We recommend that you log out when you have finished using our Websites.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Log Files
When you visit the Websites we automatically log information about your computer, such as the IP address, browser type and access times. We utilise this information to conduct site performance evaluations, to see where visitors are coming from and to keep track of how people use our Websites. This data helps us to determine what content our subscribers find most appealing so that we can maximize your enjoyment of our Websites.
Users who do not register or log in as subscribers may browse the Websites without providing any personally identifiable information. However, users' non-personally identifiable information may nevertheless be tracked for the purposes outlined above.
10. Cookies and web beacons
Cookies are small text files that are often created when you visit a website, and which are stored in the cookie directory of your Internet-accessing device. A cookie may be created when you visit us. We may use either or both permanent cookies and session cookies. The permanent cookie stores a random number on your computer to help us count the number of times you return to our Websites. The session cookie lets us know which pages within our Websites you visit. Permanent cookies do not expire when you leave our Websites and may be used on subsequent visits to the Websites. Session cookies expire when you leave our Websites or switch off your computer.
You can set your browser not to accept cookies. You should read the information that came with your browser software to see how you can turn off the automatic download feature, should you so wish. Please be aware that depending on which cookies you block, the Websites may stop working or you may not be able to fully access all features and / or the features may not work correctly.
We may use web beacons on our Websites from time to time. Web beacons or clear.gifs are small pieces of code placed on a web page to monitor visitors' behaviour and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit the page or to deliver a cookie to the browser of a visitor viewing that page.
We may use Google Analytics and other third parties to collect and process data.
11. How can you control the collection, disclosure and use of your personal information / personal data?
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
12. How can you make a complaint about Ausmed's collection, disclosure and use of your personal information?
If you are in the European Union, you are entitled to bring a complaint through your country’s supervisory authority.
If you are outside of the European Union, you are also entitled to bring a complaint through the Office of the Australian Information Commissioner ( www.oaic.gov.au).
13. How can you update and access your personal information?
If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us. We rely upon customers advising us when their personal information changes. We will respond to any request within a reasonable time. We will endeavour to promptly correct any information found to be inaccurate, incomplete or out of date.
Use of our products, services and Websites may require you to create an account. After creating an "Ausmed" account you may correct or update your personal information by clicking on the 'Log In (sign in)' link found on the Websites. The changes you make will be reflected in our databases instantly. If you wish to deactivate your account or if you think we hold other information about you not accessible via logging in, please contact our office from the contact information available on the 'contact us' page of our Websites.
14. Choice and Consent
15. Your provision of third party information
If you provide us with third party personal information then you warrant to us that you have the third party's consent to provide this information.
16. How does Ausmed communicate with you?
From time to time we may send out email messages alerting you that products and services are available, to remind you to provide feedback, to provide feedback to you or for promotional offers. In addition, you will receive communication from us: 1) if you contact us for a particular reason; 2) to receive your orders; or 3) should we need to contact you for administrative purposes, such as winning a contest or participating in research which you have agreed to. Ausmed's emails may also contain promotional materials from Ausmed.
17. How can you opt out of Ausmed emails?
18. Do we disclose your personal information to overseas recipients?
As a general rule, Ausmed does not use or disclose your personal information to overseas recipients. However, Ausmed may disclose your personal information to overseas recipients for the purposes of providing services or products to you.
19. When do we delete your personal information?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. Additionally, we may have to keep basic information about our customers for other legal, compliance and insurance-related reasons.
In some circumstances you can ask us to delete your data: see above for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
If you do not request for us to delete your personal information, but we decide that we no longer require it and we are not legally required to retain it, we will take reasonable steps to destroy or permanently de-identify your personal information.
20. Your feedback is always welcome
Ausmed Education Pty Ltd (ABN 33 107 354 441)
Level 1 / 171 La Trobe Street
Melbourne, VIC, 3000
Phone: +61 1300 287 633
Fax: +61 (03) 9326 8179
© 2019 Ausmed Education Pty Ltd. All Rights Reserved.