PRIVACY POLICY

Wattle Health Australia

ABN:77 150 759 363

  1. Purpose

1.1 Wattle Australia Limited ABN 77 150 759 363 (Company) recognises the importance of privacy. This Privacy Policy explains how the Company will collect, hold, use, disclose, protect and otherwise handle your personal information.

 

  1. What personal information does the Company collect?

2.1 Personal information is information or an opinion about an identified individual or an individual who is reasonably identifiableyou from which you can be reasonably identified. The Company collects personal information so that it can conduct its business functions, market and sell its products and services, administer your investment in the Company, provide facilities and services that you request and comply with its legal obligations. In most cases, if the Company does not collect your personal information, it may not be able to provide you with these services or to effectively conduct its relationship with you.

 

2.2 In the course of providing you with products and services the Company may collect and hold personal information about you that may include (but is not limited to):

 

(a) your name;

 

(b) address and other contact details, including email address;

 

(c) date of birth;

 

(d) tax file number (TFN);

 

(e) banking and/or credit card details;

 

(f) information about the Company’s employees, including tax file numbers, social security numbers and similar information;

 

(g) occupation and employment details including employment status and any previous work experience;

 

(h) information from or in connection with your resume or job application if you apply for a position with the Company; and

 

(i) publicly available information from your social media accounts and profiles.

 

2.3 The Company is authorised to collect tax file numbers (TFNs) by the Income Tax Assessment Act 1936 (Cth). It is not compulsory for you to provide your TFN for the Company’s products and services, but if you do not, taxation law may require additional deductions to be made from amounts payable to you.

 

2.4 Generally, the Company will not collect sensitive information about you (such as your race or ethnic origin, political beliefs or religion). If the Company needs sensitive information, it will ask your consent when it collects this information (unless an exemption applies or otherwise permitted or required by law).

 

  1. How does the Company collect and hold your personal information?

Collecting information

 

3.1 How the Company collects your personal information will largely depend on whose information it is collecting and the nature of the Company’s interaction with you. If it is reasonable and practicable to do so, the Company will collect personal information directly from you.

 

3.2 The Company collects and records personal information about individuals such as:

 

(a) the Company’s customers, potential customers and their representatives;

 

(b) the Company’s suppliers and potential suppliers and their representatives, directors, partners, proprietors and shareholders;

 

(c) contractors and subcontractors and potential contractors and subcontractors and their representatives in relation to providing goods and services to the Company;

 

(d) the Company’s employees past and present, including applicants;

 

(e) the Company’s investors and shareholders; and

 

(f) any other person who comes into contact with the Company.

 

3.3 Depending on how you choose to interact with the Company, the Company may collect your personal information when you contact the Company or its service providers by telephone, by email, through the Company’s website or when you complete a form or document and provide it to the Company; when you provide the Company, or offer or apply to supply the Company, with goods or services; when you visit premises from which we operate; when you (or your employer) provide that information to the Company in the course of conducting or administering the Company’s relationship with you, or when you are carrying out activities in connection with the Company’s business operations; when you submit a job application to the Company; where you otherwise contact the Company including by email, social media, post or in person; or where the Company is otherwise required or authorised by law to do so.

 

3.4 The Company may also collection information about you from other people (e.g. a third-party administrator) or independent sources, publicly available sources of information, or the Company’s related entities. For example, the Company may collect personal information about you from its services providers, including the Company’s share registry, Computershare Limited. However, the Company will only do so where it is not reasonable and practicable to collect the information from you directly. Where the Company has collected your information from a third party, such personal information will be held, used and disclosed by the Company in accordance with this Privacy Policy.

 

3.5 When the Company engages with you multiple times over a short period in relation to the same matter, the Company may not provide you with a separate notice about privacy each time it engages with you.

 

3.6 When you provide the Company with personal information you consent to the use, disclosure and handling of your personal information in accordance with this Privacy Policy.

 

Collecting information from visits to the Company’s website

 

3.7 The Company (or third party service providers who assist the Company in operating the Company’s website at [insert URL], including its subdomains and any other website the Company operates from time to time (collectively the Website)) may collect information based on how you use its website. The Company uses various technological methods from time to time to track the visiting patterns of individuals accessing the Website, including but not limited to the methods that are more specifically set out below in this Privacy Policy, and which includes the use of ‘cookies’, web beacons and other similar technologies to collect non-identified/anonymous information about the users of the Website such as the number of visitors, the number of pages viewed and the internet advertisements which bring visitors to the Website. This information is collected to analyse and improve the Website, its marketing campaigns and to record statistics on web traffic. No attempt is made by the Company to use this information to personally identify you.

 

3.8 Google Analytics: The Company may use Google Analytics to help analyse how you use the Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated is used to create reports about the use of the Website. Google will store this information. If you do not want your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout

 

3.9 Click Stream Data: When you read, browse or download information from the Website, the Company or its internet service provider may also collect information such as the date, time and duration of a visit, the pages accessed, the IP address of your computer, and any information downloaded. This information may be used for statistical, reporting and website administration, maintenance and improvement purposes.

 

3.10 Cookies: As described above, the Website may use ‘cookies’ from time to time. Cookies are small text files that are transferred to a user’s computer hard drive by a website for the purpose of storing information about a user’s identity, browser type or website visiting patterns. Cookies may be used on the Website to monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used. The Company may use this information to enhance the content and services offered on the Website. Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using. If you access the Website or click-through to the Website from a link in an email the Company sends you, a cookie may be downloaded onto your computer’s hard drive. Cookies may also be used for other purposes on the Website. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. If you disable the use of cookies on your web browser or remove or reject specific cookies from the Website or linked sites then you may not be able to gain access to all of the content and facilities in those websites.

 

3.11 Web beacons: Web beacons are images that originate from a third party site to track visitor activities. The Company uses web beacons to track the visiting patterns of individuals accessing the Website.

 

3.12 Third party content (eg social media links): Some of the content on the Website includes applications made available by third parties, such as social media buttons or links that allow you to share content or links to the Website through the relevant third party platforms. These third party applications themselves may facilitate collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. The Company’s website may also contain links to other websites. The Company does not share your personal information with those websites, and the Company is not responsible for the technical operation of these applications or websites, or the collection and use practices of the relevant third parties. Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your personal information.

 

Storage and security of your personal information

 

3.13. The Company aims to keep your personal information secure. Any personal information that is collected via the Website or which is held on the Company’s computer systems is protected by safeguards including physical, technical (firewalls, SSL encryption etc) and procedural methods.

 

3.14 If the Company finds that it no longer requires or has no further need for your personal information the Company may de-identify it or remove it from the Company’s systems and destroy all record of it.

  1. How does the Company use and disclose your personal information?

4.1 The Company may collect, hold, use or disclose your personal information so that it can conduct its business functions and activities, operate its business efficiently, market and sell its products and services, administer your investment in the Company and provide facilities and services that you request.

 

4.2 The Company may also collect, hold, use or disclose your personal information to:

 

(a) consider any concern or compliant that you raise against the Company or to manage any legal action between you and the Company;

 

(b) prevent or investigate any actual or suspected fraud, unlawful activity or misconduct;

 

(c) identify you or establish your tax status under any Australian or foreign legislation;

 

(d) comply with any relevant laws, regulations, codes or practice and court orders;

 

(e) collect and process payments;

 

(f) help the Company to manage and enhance products or services it provides to you;

 

(g) help the Company manage and enhance goods and services it procures from its suppliers and subcontractors;

 

(h) manage and administer any account you hold with us;

 

(i) promote and market the Company’s products and services to you;

 

(j) provide you with information that the Company believes may be of interest to you or that you may be interested in receiving, including advertising material, regarding the Company, its clients, and its business partners;

 

(k) conduct research for the purposes of improving existing products or services or creating new products or services;

 

(l) help the Company research the needs of its customers to enable it to market its products and services with a better understanding of your needs and the needs of customers generally;

 

(m) provide for the safety and security of workers and onsite visitors;

 

(n) manage business support purposes including maintenance, backup and audit;

 

(o) help the Company manage and respond to a general or specific shareholder enquiry;

 

(p) process share applications and service shareholders’ needs;

 

(q) provide facilities and services a shareholder may request;

 

(r) carry out appropriate administration in relation to the Company’s shareholders and its share registry;

 

(s) analyse the Company’s shareholder base and for product development and planning; or

 

(t) process any job application submitted by you.

 

4.3 Marketing: The Company may also use your personal information to identify a product or service that may be of interest to you. You consent to the Company using your personal information for sending you information, including promotional material, about the Company or its products and services, as well as the products and services of the Company’s related entities and third parties, now and in the future. You also consent to the Company sending you such information by means of direct mail, email, SMS and MMS messages. If at any time you no longer wish to be notified about other services or promotions, please either click on the ‘Unsubscribe’ or subscription preferences link in a direct marketing email that you have received from the Company (if applicable) or contact the Company. Privacy specific contact details are included at the end of this Privacy Policy.

 

4.4 The Company reserves the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but it has no obligation to monitor the use of the Website or to retain the content of any user session.

 

4.5 The Company may otherwise collect, use or disclose your personal information where the collection, use or disclosure is:

 

(a) in accordance with this Privacy Policy or any agreement you enter into with the Company; or

 

(b) required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).

 

  1. How is personal information disclosed to others (including overseas disclosure)?

5.1 The Company does not sell, rent or trade personal information to, or with, third parties.

 

5.2 In some circumstances your personal information may be disclosed to the Company’s related entities, to third parties that provide products or services to or through the Company, or to service providers that perform a range of services on behalf of the Company including:

 

(a) mailing houses and printing companies, and other representatives, agents or contractors appointed by the Company in the ordinary operation of its business to assist it in providing goods or services or administering its business (such as for marketing, planning and product or service development);

 

(b) professional service providers and advisors who perform functions on the Company’s behalf, such as auditors and solicitors;

 

(c) registry providers (including Computershare Limited);

 

(d) information technology vendors;

 

(e) other consultants; and

 

(f) medical providers including medical and rehabilitation practitioners for assessing insurance claims.

 

5.3 The Company may also disclose your personal information to its Website host or software application providers in certain limited circumstances, for example when the Website experiences a technical problem or to ensure that it operates in an effective and secure manner.

 

5.4 As the Company continues to develop its business, the Company may buy, merge or partner with other companies or businesses, and in so doing, acquire customer information. In such transactions, personal information may be among the transferred assets. Similarly, in the event that a portion or substantially all of the Company’s business or assets are sold or transferred to a third party, the Company may also disclose customer or shareholder information including your personal information to a purchaser or potential purchaser in connection with the sale or potential sale of the Company, its business or any of its assets, including in insolvency.

 

5.5 In some circumstances, personal information may be disclosed to third parties in jurisdictions including Australia. Generally, the Company does not send or disclose your personal information to overseas recipients. However, in certain circumstances, some of your personal information may be disclosed, transferred, stored, processed or used outside of Australia by the Company or by its third party service providers. This may happen if:

 

(a) the Company’s offices or related entities are overseas;

(b) the Company outsources certain activities overseas;

(c) transactions, information, services or products have an overseas connection; or

(d) the Company’s computer systems including IT servers are located overseas.

 

5.6 You consent to the collection, use, storage, and processing of your personal information outside of Australia as set out in this Privacy Policy.

 

 

5.8 The Company may also disclose your personal information to law enforcement agencies, courts or where the government requires certain information about you to be included in the Company’s registers which are able to be accessed by the public.

 

  1. How you may access or correct your personal information

6.1 You may contact the Company to request access to the personal information that it holds about you at any time. Depending on the nature of the request, the Company may charge for providing access to this information, however such charge will not be excessive. You may also ask the Company to correct information about you that you may believe is inaccurate, incomplete or out of date.

 

6.2 The Company takes reasonable steps to ensure that any personal information it collects and uses is accurate, complete and up-to-date. To assist the Company in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to the Company to keep it true, accurate, current and complete. Please contact the Company using the contact details below if any of the personal information that the Company holds about you is not correct or complete, or if you wish to request access to the personal information which the Company holds about you. The Company will need to verify your identity before giving you access to, or correct, your personal information. It would assist the Company to ensure it properly understands your request, and allow the Company to respond more promptly, if requests are made in writing and include as much detail as possible.

 

6.3 In certain circumstances, the Company may not be able to correct or provide you with access to your personal information. In these circumstances, the Company will generally write to you to explain and provide the reasons why, although there may be some circumstances where the Company does not provide reasons where allowed by law.

 

  1. How you may complain if you have concerns about how the Company has managed your personal information

7.1 If you have a complaint related to how the Company has managed your personal information, please contact the Company using the contact information below. The Company may ask you to place your concerns in writing in order for it to fully understand and investigate the issues you have raised. The Company will acknowledge any complaint in writing within 7 business days and make every effort to resolve your issue within a reasonable time of it being notified.

 

  1. How to contact us

8.1 If you have any questions about this Privacy Policy, if you wish to complain about how the Company handled personal information about you or if you wish to access or correct your personal information, or if you wish to opt out of direct marketing, please contact the Company’s Privacy Officer at:

 

Privacy Officer

Accounts@wattlehealth.com

1300 88 79 69

 

  1. Changes to the Company’s privacy policy and information handling practices

9.1 This Privacy Policy is subject to change at any time. Please check the Company’s Privacy Policy on its website www.wattlehealth.com.au regularly for any changes. The Company will notify you of any changes to its Privacy Policy. By continuing to use the Company’s services you will be deemed to have accepted any changes to its Privacy Policy.

 

This Privacy Policy was last updated on [9 July 2019].