Infant Sleep Australia & Sombelle & Melbourne Infant Sleep PTY LTD - Privacy Policy
Dr Fallon Cook and Dr Laura Conway trading as Infant Sleep Australia and Sombelle and Melbourne Infant Sleep PTY LTD ABN 33 651 359 821 (“Infant Sleep Australia”, “Sombelle”, “Melbourne Infant Sleep” “us”, “we”, “our”), complies with the Privacy Act 1988 (Cth) (“Privacy Act”) and the applicable Privacy Principles in the Privacy Act when handling personal information, together with the Health Records (Privacy and Access) Act 1997 (ACT) (“Health Records Act”) and the applicable Privacy Principles in the Health Records Act when handling health information.
Personal Information
By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.
Personal information includes information about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information.
Collection
We collect personal information for the purposes of delivering our products and services. We may collect information through our Websites located at http://www.infantsleep.com.au and http://www.melbourneinfantsleep.com (“Website”), or in the course of providing our Services in person, verbally and/or in writing from time-to-time.
We collect Personal Information:
· from our Clients – about themselves and their children, when they register an enquiry, request an appointment, attend an appointment, complete a form or otherwise in the course of providing our Services at any other time from time-to-time;
· when we receive enquiries through the Website and when the Website is otherwise accessed or used;
· when we receive enquiries via email;
· when we write notes during the course of providing our Services;
· from third party service providers – when they are engaged to supply Services to us (such as professional services), provide information to us or invoice us for the provision of services.
The kind of Personal Information we may collect will depend on who you are (e.g. a Client parent of a child, or third party service provider) and the nature of your interaction with us. Some Personal Information we collect may also include health information. Health information includes any information collected about your health or disability, and any information collected in relation to a health service you have received (“Health Information”), including information about your medical conditions or allergies/intolerances, medical history including injuries.
If you do not provide us with all the information we request, we may not be able to deliver our Services.
Consent
By engaging us or registering your details on our Website, and/or using our Website or supplying information or documents to us or otherwise engaging our Services, you freely give your specific and informed consent to us collecting, using and disclosing your Personal Information (including Health information) for the purposes specified in this Privacy Policy.
Use
We may use information collected to provide our Services, operate the Website, send you our newsletter, respond to feedback and complaints, communicate with third party service providers, develop new Services, or if needed to enforce our Agreement with you. If you are a third-party service provider, we will use your Personal Information to email you to accept your offer to provide Services, correspond with you in relation to the provision of Services and to pay your invoices.
In all cases, unless you have opted out, you consent to us using your Personal Information (excluding Health Information) for direct marketing purposes by us alone in order to tell you about our Services. We may contact you by mail, telephone, email or SMS to market our products and Services. We will always give you the opportunity to opt out of receiving any future direct marketing correspondence.
We will only use your health information with your consent, for the primary purpose for which it was collected, or as permitted by the Health Privacy Principles.
Disclosure and sharing
You expressly agree that we may disclose your information to third parties for purposes associated with your purchase of our Services and to third party service providers we engage to help us deliver our Services and for our own marketing purposes. We will only disclose your information to additional third parties with your consent or if permitted or authorised to do so by law. We agree only to use data processers who provide sufficient guarantees and that they will implement appropriate technical and organisational measures to protect the rights of the data subject, and only to third parties who agree to comply with this Privacy Policy.
We will only use your health information with your consent, for the primary purpose for which it was collected, or as permitted by the Health Privacy Principles.
Data security, protection and quality
We will protect the information we collect and hold from misuse, loss and interference and from unauthorised access and modification, and to make sure it is accurate, complete and up-to-date when we collect, use or disclose it.
We have procedures of monitoring the security and safety of data as well as procedures in place for dealing with any data breaches, and the associated requirements of notifying you and appropriate authorities where that data security of your information is breached.
To assist us, please ensure you provide us with your correct details, and let us know if you believe the information we have about you is inaccurate, incomplete, out of date or misleading (and we will take reasonable steps to correct the information). We may take steps to destroy or permanently de-identify information when it is no longer needed for any purpose for which it may be used or disclosed.
Your right to erasure
The right to erasure (which encompasses the ‘right to be forgotten’) gives you a right to require us to delete your Personal Information in certain circumstances, and/or to return it to you including, but not limited to where your information is no longer necessary for the purpose for which it was collected, or where you withdraw your consent and there is no other legal ground for processing your data. If you wish to have your information erased and/or returned to you please notify us at info@infantsleep.com.au.
Cookies
We may use “cookies”; technology to store data on your computer using the functionality of your browser. Many Websites do this because cookies allow the Website publisher to do useful things like find out whether the computer visited a Website before.
You can modify your browser to prevent cookie use – but if you do this our service (and our Website) may not work properly. The information stored in the cookie is used to identify you. This enables us to operate an efficient service and to track the patterns of behaviour of visitors to our Website.
In the course of serving advertisements to our Website (if any), third-party advertisers or ad servers may place or recognise a unique cookie on your browser. The use of cookies by such third-party advertisers or ad servers is not subject to this Privacy Policy, but is subject to their own respective privacy policies.
We use Google Analytics to better understand how you use our website. You can read more about Google’s use of your information here: https://policies.google.com/privacy?hl=en.
We use remarketing and retargeting when we advertise online. Third party vendors including Google, Bing, Facebook, and Instagram, use cookies and/or device identifiers to serve ads based on your visits to our website. Third party vendors show our ads across the internet.
You can opt out of Google’s use of cookies or device identifiers by visiting Googles Ad Settings: http://www.google.com/settings/ads
You can opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page: https://thenai.org/opt-out/. You can control the use of device identifiers by using your device’s settings https://support.google.com/ads/answer/1660762#mob
Access, correction and complaints
You can request, and we will provide you with access to, and a copy of any information we hold about you (subject to any applicable legal exceptions). Please also let us know if you have any concerns or complaints about the way we are handling your information so we can address them. Requests should be submitted by email to info@infantsleep.com.au.
Where our records are found to be inaccurate, or if you wish to modify the information we hold about you, we will promptly make these changes on the basis of the further information you provide.
Transfer in certain circumstances
If there is a sale, merger, consolidation, change in control, transfer of substantial assets, reorganisation or liquidation of us then, in our sole discretion, we may transfer, sell or assign information collected to one or more relevant third parties, subject always to this Privacy Policy.
Changes to this Privacy Policy
This Privacy Policy forms part of our Terms and Conditions and therefore the agreement between you and us (either in your capacity as a patient or a third-party service provider). We may, from time to time, amend this Privacy Policy, in whole or part, in our sole discretion. Any changes to this Privacy Policy will be effective immediately upon the posting of the revised Privacy Policy on the Website. Depending on the nature of the change, we may announce the change on the Website homepage or by email (if we have your email address). However, in any event, by continuing to use the Website and/or our service following any changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Privacy Policy, as amended from time to time, in whole or part, you must terminate your use of the Website and inform us immediately prior to any further receipt of our Services.
Contact us
If you have any questions about this Privacy Policy, or if you wish to request access to your information, correct or update you details or raise any privacy concerns you may have, please contact us at info@infantsleep.com.au.
For further information on your privacy rights go to: www.privacy.gov.au.