Current as at: 7th February 2017
OUR COMMITMENT TO YOUR PRIVACY
Palladium PrivatePty Ltd ACN 165 649 463 (“we”, “us”, “our”) developed and continues to provide certain programs to individuals as part of a holistic solution for people suffering from depression, anxiety and addiction. We respect your privacy and believe thatthe responsible use of personal information collected byus is critical to our business objectives and reputation.
We are committed to complying with the Australian Privacy Principles (APPs) when collecting, using, disclosing, securing and providing access to personal information. The APPs are contained in the Commonwealth Privacy Act 1988 (the Privacy Act) andgovern how organisations such as ours handle personal information.
WHAT IS PERSONAL INFORMATION?
For the purpose of the APPs:
(a)Personal information is any information, including any opinion, about an identified individual, or an individual who is reasonably identifiable:
i) Whether the information or opinion is true or not; and
ii) Whether the information or opinion is recorded in material form or not.
(b)Sensitive information is personal information, which is given a greater level of protection under the APPs,such as information about your health, criminal records, your religious beliefs or affiliations or political opinions. We only collect such information where we are permitted to do so under the APPs and if such information is nec-essary to provide our services to you or where we are required to collect this information by law.
HOW DO WE COLLECT PERSONAL INFORMATION?
We collect personal information in a number of different ways, including directly from you, through online dealings, through correspondence including application forms, and specific information request forms and from third parties such as your doctors, medical advisors, agents or representatives. Personal Information may initially be collected verbally over the phoneor in person, by use of paperforms or online. In general, you can browse our websites without telling us who you are or revealing any personal information about yourself.
“Cookies” (small text files placed on your computer when you first visit our website) are used on some parts of our website. Most browsers now recognise when a cookie is offered and permit you to refuse or accept it. If you are not sure whether your browser has this capability, you should check with the software manufacturer, your company’s technology help desk or your internet service provider.
Cookies are primarily used to enhance your online experience and are not used to track the navigational habits of identified visitors, unless we obtain your permission to do so. If you visit our website to read or download information much of the information we do collect is statistical only (for example the domain from which you access the internet, the date and time it is lawful and reasonable to do so, you can remain anonymous or use a pseudonym if you wish, however it may reduce the type and quality of services we will be able to provide.
WHY DO WE COLLECT PERSONAL INFORMATION?
The reason we collect personal information is so that we can provide you with our services, manage our relationship with you, communicate with you effectively and identify which of our services may meet your requirements, if any.
We may also collect personal information for marketingpurposes, statistical analysis, dealing with enquiries or complaints, maintaining records and accounts payments.
We may also collect personal information for purposes of developing a mailing list. If we do so, when we use that personal information, we will offer people on the list an opportunity to be removed from our mailing list, or to ‘opt out’ from receiving further contact be it by mail or electronically.
HOW IS PERSONAL INFORMATION USED?
The personal information collected from you by us is generally used to:
- provide you with our services (including use of sensitive information for establishing and maintaining your program and arranging your stay at Palladium Private);
- make contact or payment for supplies or services you may provide;
- help us develop, improve, manage and administer all of the services we provide to you;
- ensure that our business systems are functional and reliable;
- conduct marketing activities including market research;
- notify you of services, special offers, opportunities, products or benefits which we offer or any of our strategic partners offer;
- investigate, respond to or defend claims made against, or involving, us;
- meet our legal obligations.
If at any time you do not wish to be notified about our products or services please let us know. Our contact details are below.
WILL PERSONAL INFORMATION BE GIVEN TO ANYONE ELSE?
We do not share personal information with third parties except as necessary to provide our products or services or as required by law or other legal processes or with your consent, and we never sell your personal information.
In the circumstances described below, personal information may be disclosed outside of our organisation.
Personal information collected by us may be disclosed to our affiliates, contractors or other business partners to support our customer relationship with you.
If we disclose personal information to third party contractors under outsourcing or contracting arrangements, we take steps to ensure that those contractors:
comply with the APPs when they handle your personal information; and
are authorised only to use personal information in order to provide the services or to perform the functions required by us.
(b) Disclosures required by law
Personal information collected by us may be disclosed if it is required to do so by law, or if the disclosure is permitted under the Privacy Act.
We do not give, sell, rent or trade personal information to or with third parties for use in marketing or solicitation.
(c) Overseas Transfer
We use internet service providers that have servers located in Australia. However we may in the future use internet service providers that may have servers located overseas, including cloud service providers. This means that your personal information supplied to us online, for example through email, our website or our social media sites, may sometimes be transferred overseas. If you elect to provide personal information to us through any of our online services you are deemed to consent to the possible overseas transfer of such information.
Apart from the above we will only transfer your personal information overseas if:
(a) we are required to do so by law;
(b) we reasonably believe that the recipient will be required to uphold privacy principles which are similar to the APPs;
(c) you have consented to the transfer;
(d) it is not practical to obtain your consent or the transfer is for your benefit and your consent is likely to be giv-en;
(e) the transfer of the information is necessary for the performance of a contract between you and us; or
(f) we have taken reasonable steps to ensure that your personal information will not be held, used or disclosed by the overseas recipient which does not comply with the Privacy Act and/or the APPs.
ACCESS AND CORRECTION
We take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date.
Under the Privacy Act, you have a right to seek access to information which we hold about you (although there are some exceptions to this). You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date.
If you wish to exercise your right to seek access to the personal information that we hold about you, we ask thatyou contact us (details below), to explain how we will handle your access request.
We will assume (unless you tell us otherwise) that your request relates to our current records about you. These current records will include personal information about you which is included in our databases and in paper files, and which may be used by us on a day to day basis. To provide you with access to ‘current’ personal information, us would ordinarily provide you with a print-out of the relevant personal information from our databases, or with photocopies of records which are held only on paper files. If personal information about you (for example, your name & address details) is duplicated across different databases, we will generally provide you with one printout of this information, rather than multiple printouts. Ordinarily, we will not charge you for the cost of providing this type of access to these records.
For legal and administrative reasons, we may also store records containing personal information in our archives. In some circumstances, it may not be possible to access or delete all such records due to back up processes we adopt. However you may still seek access to the records held by us which are not current records, but if you do so, we may charge you for the cost of providing this access.
If you are of the view that personal information about you is not accurate, complete or up to date, please update your recordby providing us with your request for correction in writing (contact details below).
Our policy is to consider any requests for correction in a timely way.
IS PERSONAL INFORMATION STORED SAFELY?
We take reasonable physical, electronic and administrative steps to ensure the security of personal information held by it from such risks as loss or unauthorised access, destruction, use, modification or disclosure.
Our personnel who have access to personal information have been trained to maintain the security of such information.
Unfortunately, no data transmission over the Internet or any wireless networkcan be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that:
(a) there are security and privacy limitations of the Internet which are beyond our control;
(b) the security, integrity and privacy of any and all information and data exchanged between you and us through our website cannot be guaranteed; and
(c) such information and data may be viewed or tampered with in transit by a third party.
OTHER ONLINE PRIVACYISSUES
If you are not satisfied with how we handled your complaint, you can lodge a complaint with us or with the Office of the Australian Information Commissioner at:
Telephone 1300 363 992 (or +61 2 9284 9749 if calling from outside Australia).
TTY 133 677 (then ask for 1300 363 992)
Post GPO Box 5218 Sydney NSW 2001
Facsimile +61 2 9284 9666
by telephone: +61754943495
by e-mail: firstname.lastname@example.org
by letter: Palladium Private Pty Ltd,PO Box 990 Maleny QLD 4552
Please include your name, address and/or email address when you contact us so that we can respond to you.