Effective from 7 October 2019
eMedici will collect, use and disclose your personal information to personalise our services for you and to promote the business and services of eMedici, its clients, customers and partners.
This document explains how personal information is collected, used and disclosed and how to access, correct or complain about the handling of personal information. Please note that eMedici will process your data in Australia where privacy laws may differ to where you are located.
What information do we collect?
Information gathered during registration: When you sign up for our Services, or register to use our platform, we collect and process certain personal information and data on you which includes:
If you are an individual: information relating to your industry and operations, profession and specialties, education and qualifications, contact details including your name (first, last and middle name, where applicable), phone number, address, city, state, zip/postal code, country, email address, and date of birth, profile data (including password and username, log-ins), technical data (IP address, browser type, other technology on the device used and usage data), including on the frequency of your use of our platform and website. We also collect marketing and communications data, including your preferences for receiving marketing and related communications from us.
If you are an organisation: certain data (which is not personal data) in order to provide our services to you and your users, including your business or company name, and payment information. If you are an individual representative of an organisation with whom we engage in offering and providing our services, we will also collect your contact details and marketing and communications’ preferences.
We may collect personal information through various means, including our website(s), social media pages, phone calls with you, forms completed by you or other correspondence with you. In some circumstances, we collect information about you from publicly accessible sources, such as LinkedIn and Facebook.
Usage Data: We may collect information about the services you use and how you use them and/or the platform. This usage data and information may include:
- Device-specific information: such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number. We may associate your device identifiers or phone number with your account. We also automatically collect your browser type and browser software version to optimise the presentation of the platform to your platform and to maintain a record of your activity on the platform.
- Log information: when you use our services or view content provided by us, we may automatically collect and store certain information including:
- details of how you used the service, such as search queries
- Internet Protocol (IP) address including a log file of IP addresses that access the platform. We may also collect IP address and other system information for purposes of statistical analysis and to maintain the trust and security of the platform. We will not use IP addresses or other system information to identify a user unless we determine, in our sole discretion, that it is necessary to improve our services or to enforce compliance with our policies or agreements with users to protect our service, platform, customers, users and others. Notwithstanding this, we gather only that information that is reasonably necessary for us to operate and improve the platform and otherwise conduct our business. We use commercially reasonable efforts to ensure our collection of information does not interfere with the operation or security of your system.
- device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
- Location information: when you use a location-enabled service or device, we may collect and process information about your location. We may also use various technologies to determine location, such as sensor data from your device and IP addresses. We may collect this data in order to pre-complete forms for you, and to allow relevant suggestions of our services.
- Local storage: we may collect and store information, including personal information, locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
- Cookies and anonymous identifiers: we may use various technologies to collect and store information when you visit our platform, including cookies, which are a small text file containing small amounts of information which is downloaded to/stored on your computer (or other internet enabled devices, such as a smartphone or tablet) when you visit a website. Cookies may collect personal information about you. Cookies help us remember information about your visit to our website, like your country and other settings. Cookies allow us to understand who has seen which webpages and possibly advertisements, to determine how frequently particular pages are visited and to determine the most popular areas of our website. They can also help us to operate our website more efficiently and make your next visit easier.
- We may send one or more cookies or anonymous identifiers to your device. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our website for any of your future visits to the website.
What we use your personal information for?
We use the personal information we collect from your use of our services, from information you enter on the platform, and information gathered during registration for a number of purposes, including to:
- enable us to provide, maintain, protect and improve the services and our products offered to you, to operate our business and develop new services, and to help us protect you and the platform;
- offer you specific and relevant information – like educational recommendations – in connection with the provision of our services;
- assist you in pursuing connections or interactions with other users as part of our services;
- comply with our legal responsibilities and assist governments and law enforcement agencies or regulators;
- support our internal business purposes (including administration, planning and software and content development);
- based on your preferences, issue marketing materials, including promotions to you; and
- contact you to inform you about updates to the Platform and Services and provide information relating to transactions you may conduct on the Platform.
We may use your personal information to send you direct marketing communications about the services or our related services. This may be in the form of email, post, SMS, telephone or targeted online advertisements. This may also include email communications, including information that we think may be of interest to you, and information on upcoming changes or improvements. When you receive any permitted electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication or by contacting us at email@example.com. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email). You can also change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser.
Accessing, correcting and updating your personal information
To request access to personal information we hold about you, please contact us. If that information is incorrect, out of date or incomplete, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes.
When requesting access or changes to your personal information, we may ask you to verify your identity before we act on your request. There are some circumstances in which we are not required to give you access to your personal information. We may reject requests that are unlawful, frivolous, vexatious, unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing existing practices), that we believe risk the privacy, health or safety of others, or would be otherwise be extremely impractical (for example requests concerning information on our backup systems or unique ID data on users).
Where we provide information access and correction, we will do so for free, except where in our opinion it would require a disproportionate effort or cost for us to do so. We may require you to meet our reasonable costs in providing you with access including for photocopying and postage. Where you correct, update or otherwise provide personal information, you represent to us that the information you provide to us is, having regard to the circumstances, accurate, up to date and complete, having regard to the purposes of the disclosure, and not misleading or deceptive. We will respond to any requests to change your personal information within a reasonable timeframe and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up-to-date and complete.
Information we share / disclose to other parties
Third Party Service Providers: We provide your information to Third Party Service Providers to help manage our business and deliver services which broadly include:
- IT service providers who help manage our IT and back office systems including the hosting and storage of personal data;
- Messaging service providers;
- Email validation;
- Security and performance service providers;
- Customer relationship management, support requests and invoicing; and
- Internal communication systems providers.
Some of these providers use ‘cloud based’ IT applications or systems, which means that your personal data will be hosted on their servers, but under our control and direction.
We request all our third party service providers to respect the confidentiality, privacy and security of personal data and our contracts with them include obligations for them to comply with applicable privacy laws and to use any personal information we share with them solely for the purpose of providing services to us.
For legal reasons: we may share or limit access to your personal information if we have a good-faith belief that access, use, preservation or disclosure of, or restriction therefrom, the information is reasonably necessary to comply with any applicable legal, regulatory or other administrative or governmental process, enquiry or action, enforce any agreement with you or investigate any potential breach, detect, prevent, or otherwise address any potential fraud, security or technical issues, or protect against potential harm to the rights, property or safety of our users, us or the public. We may also disclose personal information where we are required to do so by applicable laws.
Restructure of our Business: If we are involved in or contemplate a merger, acquisition, asset sale, corporate restructure or other similar transaction, we may disclose certain information regarding the platform and the services, which may include personal information, to potential purchasers or investors for our legitimate business purposes. We will do so subject to acceptable confidentiality obligations being granted to us.
Anonymised/ Aggregated Information: We may use and disclose to any person any de-identified information (not personally identifiable on its own or in combination with any other information held by us) we obtain from users’ use of the platform, including statistical information of your use of our services which is in aggregated and anonymised form.
Your personal information may be disclosed, transferred to or processed outside of your country of residence including to Australia, New Zealand, the United States, Europe and Asia Pacific.
How long do we keep your personal information?
We will retain your personal information for as long as is reasonably necessary for the purposes for which we collect this information. In some limited circumstances we may retain your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements. In specific circumstances we may also retain your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings. We aim to maintain our services in a manner that protects information from accidental or malicious destruction.
We recognise our responsibility to protect the personal information that you entrust to us. We take security very seriously and work together with you, developers and external security experts to design security into our products from the ground up (including through implementing privacy by design and security by design measures). We store most information about you in computer systems and databases operated by either us or our external cloud service providers. Some information about you may be recorded in paper files that we store securely. As the transmission of information across the internet is not completely secure we cannot guarantee the security of your information transmitted to our website and issues can arise.
Enforcement and complaints
If you have a complaint regarding this policy or any breach of applicable privacy laws, please contact us immediately to register your complaint and let us know what we can do to resolve it. If we do receive your formal written complaint, we will aim to respond to your complaint within a reasonable time and do everything reasonably practicable to resolve the complaint with you. We hope it won’t ever come to this, but if you’ve already contacted us and feel that your complaint cannot be resolved between us, you can contact the relevant local data protection supervisory authority. In Australia, this is the Office of the Australian Information Commissioner (OAIC). We will work with the appropriate regulatory and supervisory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal information that we cannot resolve with you directly. Please note, you may choose to contact us in relation to a particular matter on an anonymous basis or using a pseudonym and, unless it is impracticable for us to do so or we will not be able to respond reasonably to your complaint, we will attempt to resolve your enquiry on such basis.
If you’ve got any questions or issues with your information, please contact us at: eMedici: C/- Waye-Harris Lawyers, 167 Flinders Street, Adelaide SA 5000 or Email: firstname.lastname@example.org