Last Updated: January 2024
Ausmed Education Pty Ltd (ABN 33 107 354 441) (Ausmed, we, our 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 the personal information we collect.
· uses a website owned or controlled by Ausmed, including our websites at www.ausmed.com, www.ausmed.co.nz, www.ausmed.co.uk, www.ausmed.com.au, or our smartphone application 'Ausmed CPD' (Ausmed App) (together the Websites); and
· contacts us or otherwise engages or interacts with us, including our contractors, suppliers, potential employees and employees.
Ausmed provides a cloud-based platform available through the Ausmed Websites for users to access the Ausmed products and services (Products).
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.
Personal information / personal data is generally information or an opinion relating to an identified, or reasonably identifiable, individual (Personal Information).
The type of personally identifiable information / Personal Information 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 Products we have provided to you or that you have enquired about, and our response.
● Technical Data which may include your login data (ie. username and password), 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 our Websites.
● Profile Data which may include your login data, 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 and Products.
● Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
The type of personally non-identifiable information and Personal Information we collect from you or third parties may include:
● IP address;
● cookie information (see item 11 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.
Can you remain anonymous or use a pseudonym?
Generally speaking, we do not allow you to use a pseudonym or to otherwise remain anonymous, as this is impractical for our business purposes.
We also note that if you do not provide us with some or all of the Personal Information we request, we may not be able to provide you with the relevant Products. This may also have an effect on whether we can begin or continue a relationship with you, and whether you can use or access our Products.
Some of the information we collect may be 'sensitive information' (AU) or 'special category personal data' (EU/UK), 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), and in relation to employees, we may collect your tax file number, superannuation information and qualifications, among other things. We collect this information in order to maximise the Products we provide to you via the Websites.
We may only use and disclose your sensitive information / 'special category personal data for the main purpose for which it was collected, or for reasonably expected secondary purposes which are directly related to the main purpose, or for purposes to which you have consented and in other circumstances authorised by the Privacy Laws (eg where required or authorised by law to be disclosed, or where disclosure is necessary to prevent a threat to life, health or safety).
4. How do we collect and store Personal Information?
We collect your Personal Information during the course of providing our Products to you. This includes, without limitation, when you use our Website to request, purchase or order our Products (including by completing forms on our Website), when you create an account with us, when you use our Products or otherwise via customer enquiries and communications.
Generally, we collect your Personal Information directly from you or automatically through your use of our Products with your consent but we may also collect your Personal Information from other people or organisations if you have given your consent to them or when other users of our Products provide information about you when they submit content when using our Products. For example, a team member may upload content about you. We also receive your email address from other users when they provide it in order to invite you to access the Products. Similarly, an administrator may provide your contact information when they designate you as the billing or technical contact on your organisation’s account or when they designate you as an administrator.
Generally, we store Personal Information in local servers situated in Australia.
5. Use of Personal Information
Personal Information is collected and held for a range of reasons across our Websites. We generally only collect or hold your Personal Information where it is reasonably necessary for our business functions or activities. This may include registering for an educational event, creating an account, subscribing to and using Ausmed Products and commenting on content.
We will only use your Personal Information when legally permitted. The most common uses of your Personal Information and why we need it are as follows:
● to perform the contract between us;
● where it is necessary for our legitimate business interests (or those of a third party); or
● to comply with a legal or regulatory obligation.
Purposes for processing your Personal Information
Set out below is a description of the ways we intend to use your Personal Information and the legal grounds on which we will process such information. We have also explained what our legitimate business interests are where relevant.
We may process your Personal Information for more than one lawful ground, depending on the specific purpose for which we are using your information. Please email us at email@example.com you need details about the specific legal ground we are relying on to process your Personal Information where more than one ground has been set out in the table below.
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 Products 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 business interests to keep our records updated and to understand how customers use our Products
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 business interests to recover debts owed to us
(a) Identity, (b) Contact, (c) Profile, (d) Marketing and Communications
(a) Performance of a contract with you, (b) Necessary to comply with a legal obligation, (c) Necessary for our legitimate business interests to keep our records updated and to study how customers use our Products
To administer and protect our business and our Websites (including maintaining records and databases, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications, (f) Technical
(a) Necessary for our legitimate business 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 comply with the law and exercise our legal rights including exercising rights we may have (a) under law or a contract between us and you, or between us and a third party, and (b) in connection with legal claims, compliance, regulatory, and audit functions, and (c) in connection with the acquisition, merger or sale of a business
(a) Identity, (b) Contact, (c) Financial, (d) Transaction
(a) Necessary for our legitimate business interests for running our business, (b) Necessary to protect our legal rights, interests and the interests of others, (c) Necessary to comply with a legal obligation
Secondary Purposes (any purpose related to the Main Purposes that could be reasonably anticipated at the time your Personal Information was collected)
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
Necessary for our legitimate business interests to study how customers use our Products, to develop them and grow our business
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 business interests to study how customers use our Products, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our Website, Products, marketing, customer relationships and experiences
(a) Technical, (b) Usage
Necessary for our legitimate business interests to define types of customers for our Products, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about Products that may be of interest to you
(a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile
Necessary for our legitimate business interests to develop our Products and grow our business
Where we are required to collect Personal Information by law, or under the terms of the contract between us and you do not provide us with that information when requested, we may not be able to carry put some or all of the Main Purposes such as performing the contract (for example, to deliver Products to you). If you don’t provide us with the requested information, we may have to cancel a Product you have ordered but if we do, we will notify you at the time.
In addition to the Main and Secondary Purposes, we may use or disclose your Personal Information for any purpose to which you otherwise agree (including as disclosed to you in an information collection statement at the point where we collect your Personal Information) or any other purpose required or authorised by law (including the Privacy Laws).
Generally, we do not rely on consent as a legal ground for processing your Personal Information, other than in relation to sensitive information / special category personal data or sending marketing communications to you via email or text message. You have the right to withdraw consent at any time by emailing us at firstname.lastname@example.org.
If we collect sensitive information / special category personal data from you, then you agree that it is reasonably necessary for us to do so for the relevant Main and Secondary Purposes set out in the table above.
You will receive marketing communications from us if you have:
● requested information from us or purchased Products 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 by emailing us at email@example.com at any time.
Where you opt out of receiving our marketing communications, we may still contact and communicate with you in relation to any of the other Main Purposes.
We will only use your Personal Information for the Main 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 Main Purpose. If you wish to find out more about how the processing for the new purpose is compatible with the Main Purpose, please email us at firstname.lastname@example.org.
If we need to use your Personal Information for a purpose unrelated to the purpose for which we collected the information, we will notify you and we will explain the legal ground of processing.
We may process your Personal Information without your knowledge or consent where this is required or permitted by law.
We do not sell or license your Personal Information to third parties.
● Ausmed group entities, our business partners, suppliers, and subcontractors who help us provide our Products, for example, providers of payment services and IT services (including hosting);
● 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, including our legal representatives and other professional advisers;
● as required by law or part of any investigation into you or your activities or us and our activities where we reasonably believe that disclosure is necessary to regulators, 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 Products 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 Laws).
If you are accessing the Websites whilst in the European Union or UK: Countries outside of the European Economic Area (EEA) and the UK do not always offer the same levels of protection to your Personal Information, so European and UK laws have prohibited transfers of personal data outside of the EEA and UK respectively unless the transfer meets certain criteria. Many of our third party service providers are based outside the EEA and the UK, so their processing of your Personal Information will involve a transfer of data outside the EEA or UK as appropriate.
Whenever we transfer your Personal Information out of the EEA or UK, 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 Information to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or UK; or
● Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the relevant EU or UK authority which give Personal Information the same protection it has in Europe or the UK; or
● 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 or UK.
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.
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.
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, whether such Personal Information is in hard copy or electronic form.
Some of the measures we take are:
● limiting physical access to our premises;
● storing the Personal Information in secure systems accessible only to authorised staff;
● 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 Products 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 Products 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 Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know such information. They will only process your Personal Information 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.
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.
Visitors who do not register or log in as users 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.
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 our Websites. 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.
We may also use social media buttons and/or plugins on our Websites that allow you to connect with your social network in various ways. For these to work, the social media sites including Google+, Facebook, X, Instagram, YouTube, Instagram and Linkedin, will set cookies through our Websites which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.
Under certain circumstances, you have rights under Privacy Laws in relation to your Personal Information. These include the right to:
● Request access to your Personal Information.
● Request correction of your Personal Information.
● Request erasure of your Personal Information.
● Object to processing of your Personal Information.
● Request restriction of processing your Personal Information.
● Request transfer of your Personal Information.
● Right to withdraw consent.
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org.
You are responsible for ensuring that your Personal Information is accurate, current and complete and we encourage you to contact us to update your Personal Information if it changes. 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 users 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. Alternatively, where you have created an "Ausmed" account, you may yourself 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 us.
You will not have to pay a fee to access your Personal Information (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 Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information 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.
If you choose to limit the Personal Information we process about you we may not be able to communicate with you or fulfil our Main Purposes outlined above. This may include limiting or ceasing your use of our Products, or otherwise ceasing to provide you with our Products. Further, if fulfilling a request in relation to amending or deleting your information would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep, we may not be able to fully meet your request.
Where you have requested us to manage your information in some way, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honoured or the dispute is resolved, provided your administrator does not object (if applicable).
13. How can you make a complaint about Ausmed's collection, disclosure and use of your personal information?
If you are in the European Union or UK, you are entitled to bring a complaint through your country’s supervisory authority.
If you are outside of the European Union or UK, you are also entitled to bring a complaint through the Office of the Australian Information Commissioner ( www.oaic.gov.au).
If you provide us with third party Personal Information then you warrant to us that you have the third party's consent to provide their information.
From time to time we may send out email messages alerting you that Products 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.
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 service providers for the purposes of providing Products to you.
We will only retain your Personal Information 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 Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information 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 Personal Information: see above for further information. In some circumstances we may anonymise your Personal Information (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.
Our Products are not designed for and are not marketed to people under the age of 16 (“minors”).
We do not knowingly collect or solicit Personal Information from anyone under the age of 16 years of age or knowingly allow such persons to use our Products (including by registering an account). If we become aware that we have collected Personal Information from a person under the age of 16 years without parental consent, we will take all reasonable steps to delete that information.
21. 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