Privacy Policy

1. INTRODUCTION

2. PERSONAL INFORMATION WE COLLECT

1. We collect personal information about you from our interactions with you including through our Websites,  Platform, third parties such as HealthEngine, telephone conversations with us, e-mails, chat and written and  verbal communications.
2. The types of personal information we may collect and hold vary  depending on the nature of our interaction with you and may include: 
   • identifying and contact information such as your name, address, contact number and email;
   • health information such as information about your past,  present or future health, the provision of telehealth services to you,  and the provision of pharmacy scripts, pharmacy items and referrals.  This may be information you provide to us via the Platform, the Websites  or information provided by a Partner Doctor or Partner Provider through  the Platform in the course of delivering services to you;
   • other types of sensitive information  such as your gender at birth and whether you are of Aboriginal or Torres Strait Islander descent; and 
   • government identifiers such as Medicare numbers and individual healthcare identifiers.
   • We may also collect de-identified  information via cookies on the Websites. This information includes your  browser type, operating systems and other websites visited. This  information does not include any of your personal information and will  not be used to link back to you individually.
3. We may collect personal information about a range of individuals including: 
   • patients; 
   • your next of kin or carer (Representative);
   • healthcare providers including Partner Doctors and Partner Providers;
   • job applicants, employees and contractors of OnlineDoc; and
   • third parties providing a service to OnlineDoc.
4. If you are a patient, we primarily collect personal information about you from: 
   • you, when you use the Platform and/or the Websites;
   • you, when you contact us (whether by telephone, email, chat or through the Platform or Websites);
   • any person who, on your behalf and with your consent, provides information about you such as your Representative; and
   • any Partner Doctor or Partner Provider from whom you obtain services through the Platform.
5. If you engage with us as a Partner Doctor or Partner Provider, we  may also collect personal information about your skills, qualifications  and experience. Further details of this will be outlined in the  Contractor Agreement or other agreements we have with you upon  registering as a Partner Doctor or Partner Provider with OnlineDoc.
6. We may also collect personal information about you from third fcparties such as from Google, Facebook and Apple if you use these  platforms to login to the Platform.

3. PURPOSES FOR WHICH WE COLLECT, HOLD, USE AND DISCLOSE YOUR PERSONAL INFORMATION

1. We collect, hold, use and disclose personal information for a range of purposes including the following: 
   • to communicate with you;
   • for record keeping purposes;
   • to provide to you the functionality of  the Websites and the Platform (e.g. if you are a patient, to connect you  to a Partner Doctor or Partner Provider through our Platform);
   • to enable a Partner Doctor or Partner Provider to provide healthcare services through the Platform; 
   • as required for delivery of the  services provided through our Platform (but not by us) to you, including  sharing of your address and phone number with third party providers for  the purposes of parcel delivery and tracking;
   • as required for the ordinary operation of our Platform and Websites;
   • to manage our relationship with you, and to review, develop and improve our services to you and your experience with us;
   • to inform you about important matters relating to the Platform, the Websites or your personal information;
   • for market research;
   • to invoice and process any fees payable in relation to the services rendered through the Platform or Websites;
   • for quality assurance and training purposes and as may be required by our insurers;
   • to enable us to comply with laws and  assist government or law enforcement agencies where we are required and  authorised to do so;
   • where there is a serious and imminent  threat to an individual’s life, health, or safety; or a serious threat  to public health or public safety; and
   • for any purpose disclosed to you or required or authorised by or under law.
   • Our range of products and services and our functions and activities may change from time to time.
   • If you provide your email address, telephone and/or  mobile phone number, you also consent to us using your email address,  telephone and/or mobile phone number to contact you (including by  telephone call, SMS or email) for any of the above purposes.
2. If you are a patient, your health information collected by us will only be used or disclosed: 
   • to enable a Partner Doctor or Partner Provider who is providing services to you through the Platform to provide those services;
   • to third party suppliers and service  providers, and other providers for the operation of our Platform,  Websites and/or our business or in connection with providing our  products and services to you (including for the purposes of delivering  goods to you);
   • to those who work for us (whether as an employee or a contractor), our officers and related bodies corporate;
   • to payment systems operators (e.g.  merchants receiving card payments, PayPal) and organisations who carry  out credit, fraud and other security checks;
   • to your Representatives and specific  third parties authorised by you to receive health information held by us  (such as your nominated doctor who you would like to share your health  information with);
   • should a Partner Doctor form the  professional opinion that a patient is at imminent risk of harm,  including self-harm, and where it is consistent with his or her  professional and ethical obligations to do so, to contact emergency  services (such as an ambulance service) to request a welfare check or  similar intervention;
   • to any relevant government authority, where we reasonably believe that such disclosure is necessary;
   • to any entity with which we merge (or  proposed to merge), or by which we are acquired (or proposed to be  acquired) or to which we may sell all or part of our business and  assets; and
   • to enable us to comply with laws and  assist government or law enforcement agencies where we are required and  authorised to do so.
3. If you do not provide us with personal information about you that we  request, we may not be able to provide you with the products services  you request.
4. We may de-identify, use and retain your personal information  (excluding any eScript data) to conduct analysis on how the Platform,  Websites and services are being used and to develop and enhance our  Platform, Websites and services.

4. INFORMATION SHARING

1. We share your personal  information with our related bodies corporate (as defined in the  Corporations Act 2001 (Cth)) to enable us to conduct our business and  provide the Platform, Websites and our services.
2. We also share your personal information with third parties, including: 
   • persons or organisations engaged by us  to assist us in carrying out the above purposes such as data storage  providers, IT support providers, payment systems operators, providers of  targeted online advertising and delivery partners; and 
   • Partner Doctors and Partner Providers  who provide services to you through the Platform, to enable them to  deliver the products and services that you request from them through the  Platform.
3. We do not share your personal information with other healthcare  providers or pharmacists who are unconnected to the Platform, without  your explicit consent.
4. For the purpose of complying with our financial audit obligations,  we are required to divulge limited personal information about you to our  financial auditors. Wherever possible, personal information used for the purpose of our financial audit is anonymised.
5. In addition to the above, if you are a patient, please refer to  section 3.2 of this privacy policy for further information in relation  to whom we may disclose your health information.
6. We require Partner Doctors and Partner Providers who provide services through the Platform to take reasonable steps to protect personal information from unauthorised loss or unauthorised access or  use. Those Partner Doctors and Partner Providers may be required to take  further steps to protect personal information under the professional  regulations applicable to them.
7. You acknowledge and agree that, should we sell, merge or otherwise change control of our business, our company, the Platform or the Websites to a third party, we shall be permitted to disclose your  personal information to the third party without giving notice or seeking  prior consent from you. We shall also be entitled to assign the benefit  of any agreements we have with you to the third party.
8. We may disclose de-identified information to third parties for the purposes of reviewing the quality of services delivered and conducting  clinical research.

5. STORAGE OF PERSONAL INFORMATION

1. In order to help prevent unauthorised  access, use or disclosure, we have put in place reasonable physical,  electronic and managerial procedures to help safeguard and secure the  personal information we collect.
2. We store the personal information we  collect and use Transport Layer Security (TSL) to provide users secure  and private access. Presently our intention is to store personal  information collected by us on servers located in Australia. As such, we  are unlikely to disclose your personal information overseas. By using the Platform, you consent to our storing your personal information in this manner.
3. We take reasonable steps to protect your personal information, including the following: 
   • Password protection: You are required  to set up a secure password to use the Platform. The Platform does not  permit automatic log-ins without that password. If you need to change  your password, we use authentication methods to make sure it is you.
   • Secure storage and handling: We use a  combination of firewall barriers, encryption techniques, data  segregation techniques, backup and authentication procedures to help  maintain the security of the Platform and to protect your account and  your personal information.
   • Interoperability: We comply with robust interoperability requirements that aim to protect the flow and transfer of your data.

6. COOKIES AND TRACKING TECHNOLOGY

1. In common with many other website  operators, we may use a standard technology called ‘cookies’ on our  Websites. Cookies are small pieces of information that are stored by  your browser on your computer’s hard drive and they are used to record  how you navigate the Websites on each visit.
2. Cookies that are used in any part of  our Websites will not be utilised for collecting personally identifiable  information and will only be used for internal management purposes.
3. Most browsers automatically accept  cookies, but you can usually change your browser to prevent cookies  being stored. Please note, if you do turn cookies off this will limit  the service that we are able to provide to you. 

7. MARKETING AND PROMOTIONS

1. When you sign up to use the Platform,  and unless you subsequently opt out, you consent to us using your personal information for marketing and promotion purposes. 
2. If you consent to us using your personal information for these purposes, we may, from time to time, send  you information in relation to products, services or other offers we  think may be of interest to you, including to tell you about the  services we offer on the Platform and the products and services offered  by third parties. We will contact you via the preferred communication method you nominate through the Platform.
3. We use third party vendor remarketing services including such as Google’s ‘Customer Match’ and Facebook’s  ‘Custom Audience’ to display ads. This means if you have provided us  with your contact details, unless you opt-out of receiving direct  marketing from us, we may upload these to third party vendors who  perform remarketing services on our behalf.
4. We do not sell or disclose your information to third parties to market their products or services to you.
5. You can opt out of marketing  communications at any time by using the unsubscribe facility in the  relevant message or contacting our privacy officer using the contact  details set out at the start of this privacy policy.

8. YOUR RIGHTS

1. Your rights in relation to the personal information held by us about you include: 
   • Access: You can request a copy of your  information, and to ask for it in a format that can be easily reused or  transferred to another person or trusted healthcare provider.
   • Correct/Update: You can ask us to update or correct your information.
   • Complain: You can express your concerns  or complaints to us about your privacy or the way we are handling your  personal information. We take your concerns seriously and will consider  or investigate your complaint and endeavour to respond to your complaint  within 14 days.
   • Closing your account: If you would like to close your Personal  Account or Family Account, please email us at admin@onlinedoc.com.au. If you request that  your Personal Account or Family Account be deleted, the details you have  provided and all information relating to your Personal Account or  Family Account will be archived and stored securely by OnlineDoc for up to 7 years. Depending on the timing of your request for deletion  of data, our ability to comply with such requests may be limited by  local law, in accordance with Health Records Act 2001 (Victoria),  Principle 4 Data Security and Data Retention.
2. We will generally provide you with access to your personal  information if practicable, and will take reasonable steps to amend any  personal information about you which is inaccurate or out of date. In  some circumstances and in accordance with applicable privacy laws, we  may not permit you access to your personal information, or may refuse to  correct your personal information, in which case we will inform you  about the reason for this decision.
3. If you are not satisfied with the way we handle your query or handle  your personal information (including our response to your request to  access or correct your personal information), you have a right to lodge a  complaint with the Office of the Australian Information Commissioner  (OAIC) by visiting the OAIC website. If your complaint relates to the  handling of your health information and you reside in  New  South Wales, Victoria or the Australian Capital Territory, you can lodge a  complaint with the relevant State/Territory health complaints  commissioner.
4. To exercise any of your rights in relation to your personal  information, please contact our privacy officer using the contact  details provided at the start of this privacy policy.
5. If you provide personal information to us about a third party (such  as your directors, employees or someone you have business dealings with)  you must ensure that you are allowed to give that information to us and  that we are allowed to collect that information.

9. GENERAL

1. This privacy policy is effective from December 2023. As this privacy policy is updated from time to time, to obtain a  copy of the latest version at any time, you should visit our Websites.  Your continued use of the Websites and the Platform after changes are published constitutes your acceptance of the modified terms of this  privacy policy.