1. ABOUT THIS POLICY______________________________________________________________
1.1 Virtue Health Australia Pty Ltd trading as Virtue Vax ACN 967 432 404 (“us”, “we”, or “our”) and our related bodies recognise the importance of your privacy and respects your right to control how your personal information is collected and used.
1.3 Virtue Vax provides mobile workplace vaccination and education services.
“Personal Information” means any information that may identify you, or by which your identity might be reasonably determined. The information you provide us may include, amongst other things, your name, address, email address, and phone number.
“Sensitive Information” means any information about an individual’s racial or ethnic origin, political opinions, memberships of a political organisation, religious belief or affiliation, philosophical belief, membership of a professional or trade association, membership of a trade union, sexual preference or practices, criminal record or health information.
“Identifier” is a unique number assigned to an individual to identify uniquely the individual. Identifiers include Medicare Numbers and Tax File numbers.
“Customer” means a customer of Virtue Vax who is a user of the Site and a subscriber of the Services.
3. TYPES OF PERSONAL INFORMATION WE MAY COLLECT___________________________________
- your contact details including your name, email address and contact phone number;
- your business or company name;
- your payment and billing information, which we use to bill you for the Services and to process your payments, including credit card details;
- details regarding conversations we have had with you; and
- other information relevant to you that relates to the Company.
- In order to provide out services to you, we may collect Sensitive Information about you such as your health and vaccination history. We will only collect your Sensitive Information with your consent.
- We also collect information about our Customers’ use of the Services, including their order and billing history, Services usage and other information.
- We automatically collect through our Site and Services, information that is often not personally identifiable, such as the website from which visitors came to our Site, IP address, browser type and other information relating to the device through which they access the Site. We may combine this information with the Personal Information we have collected about Customers.
4. HOW WE USE PERSONAL INFORMATION ____________________
4.1 Personal information collected by us will generally only be used or disclosed for the purpose it was collected. We may from time to time use personal information for another purpose where it would be reasonably expected by you or if allowed by law, including:
- to efficiently and effectively maintain your account and contact details
- to provide our products and Services to Customers, including to generate aggregate reports for Customers about Service usage;
- to respond to requests or inquiries from Customers, to communicate with Customers about their accounts or orders, and for similar customer-service-related purposes;
- to process Customer payments and to assess charges for our Services;
- to effectuate or enforce a transaction or agreement with a Customer;
- to tailor the information we send or display to Customers, including to market our Services or opportunities to attend events or seminars;
- to analyse Services or internal operations;
- to provide Customers with information about our company or Services that we believe may be of interest, including to send marketing and promotional e-mails;
- to improve our Site, offerings or Services and to better understand how Customers access and use our Site and Services, on an aggregated and individualized basis;
- where disclosure or its use is required or authorised by law;
- to administer our Site and keep it safe and secure;
- in the ongoing administration of the shareholder register;
- in preparation and distribution of the statements for handling mail;
- in the process of procuring advice from legal and accounting firms, auditors, contractors, consultants and other advisors;
- to provide you with notices required under legislations, including but not limited to the Corporations Act 2001 (Cth);
- any other purpose for which you have consented.
- The information you give us is used to provide you with a product or service and/or to fulfil your order. Sharing of information will be limited to partners or third parties who are integral to the order fulfilment process. We may also use aggregated or non-personally identifying information about Customers or [End Users] for market analysis, research, marketing or other purposes.
5. ACCESS AND ACCURACY __________________
- Subject to exceptions allowed by law, you have the right to access personal information we hold about you and to seek its correction. Please contact us (at our contact details provided below) to request access to your information, or if you have a complaint concerning your information privacy.
- We may decline a request to access or correct personal information where allowed under the Australian Privacy Principles and use reasonable endeavours to provide you with our reasons in writing.
- Depending on the circumstances, we may charge you reasonable costs for providing access to your personal information. There is no fee for lodging a request for access.
6. HOW WE STORE PERSONAL INFORMATION _____________
- We will take reasonable steps to protect your personal information from misuse, loss, unauthorised access and modification or disclosure. If we no longer require the use of your personal information, we will take reasonable steps to destroy or permanently de-identify it.
- The internet is not always a secure environment. If you use the Internet to send us any information, it is sent at your own risk. Our websites may contain links to other websites. We are not responsible for the privacy practices or the content of such other websites.
- Personal information may be stored electronically through third party data centres, which may be located overseas, or in physical storage at our premises or third party secure storage facilities.
7. HOW WE DISCLOSE PERSONAL INFORMATION______ _ _____
- We may disclose any of the Personal Information we collect or receive through our Site and Services as follows:
- Our employees and related bodies corporate;
- to our contractors or third party service providers who provide services or perform functions on our behalf;
- our professional advisors and agents
- payment systems operators such as merchants or third party payment providers;
- in response to a subpoena or other legal process by a governmental entity or third party, or if otherwise required by law;
- to protect or enforce our rights or property;
- in the event of the sale or dissolution (bankruptcy) of assets, in whole or in part, of Virtue Vax or any of its affiliates; and
- In addition, we may share aggregate or non-personally identifying information with selected third parties for marketing, advertising, research or other purposes.
- We will not disclose, sell, share or trade your Personal Information to any third parties unless we first receive your consent.
- We may be required to provide Medical History to other medical service providers, such as your General Practitioner, Nursing staff or other specialist service providers. We will only supply this information with the consent of the patient and where it is necessary for the patient’s treatment.
- We are required by law to report adverse immunisation events. In the unlikely event you experience an adverse reaction to an immunisation, we will disclose your Personal and Sensitive Information to the reporting body.
8. IDENTIFIERS ________________
We will not adopt as our own any identifier of you, or use or disclose an identifier of you which has been assigned by a government agency, unless allowed by the National Privacy Principles set out in the Act.
9. CAREER APPLICATIONS ______________
Employment applications and resumes collected by us are safely and securely stored and only used for the purposes for which it was collected.
10. COOKIES, WEB BEACONS and ANALYTICS _____________
- A cookie is a text file that a website transfers to your computer’s hard drive for record-keeping purposes. Cookies help us gather and store information about visitors to our websites and are intended to improve your website browsing experience whilst ordering. Our cookies assign a random, unique number to each visitor’s computer. They do not contain information that would personally identify the visitor, although we can associate a cookie with any identifying information that is or has been provided by a Customer while visiting our Site.
- Web beacons are tiny graphics with a unique identifier, similar in function to cookies that are used to track the online movements of Web users. In contrast to cookies, which are stored on your computer’s hard drive, Web beacons are embedded invisibly on webpages and may not be disabled or controlled through your browser.
- We may also engage third parties, including Google Analytics, to track and analyse Site activity on our behalf. To do so, these third parties may place cookies or web beacons to track user activity on our Site. The information generated by these cookies (including your truncated IP address) is transmitted to and stored by Google, and other third party providers, on servers in the United States. Google will use this information for the purpose of evaluating your, and other users’ use of our website, mobile website, compiling reports for us on website activity and providing other services relating to website activity and internet usage.
- We use the data collected by such third parties to help us administer and improve the quality of the Site and to analyse usage of the Site.
11. THIRD-PARTY LINKS_______________
12 DIRECT MARKETING MATERIALS ______________
We may send you direct marketing emails and information about products and services that we consider may be of interest to you. These communications will only be sent via email and in accordance with applicable marketing laws, such as the Spam Act 2004 (Cth) as you consented to upon registering for our Services. If, at any time, you would like to stop receiving these promotional emails, you may follow the opt-out instructions contained in any such email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails or promotions from us, we still may send you email about your account, your account or any Services you have requested or received from us, or for other customer service purposes. We do not provide your personal information to other organisations for the purposes of direct marketing.
13. CONSENT TO TRANSFER INFORMATION OUTSIDE AUSTRALIA _________
We may disclose your personal information to organisations in other countries. Recipients may include:
- Anyone that you have consented for us to disclose personal information to;
- Our related entities, employees or officers;
- External service providers that may assist us in our business providing administration, information technology or other services;
- External service providers, if necessary for us to provide you with requests products or services;
- Cloud providers and storage, data processors; and
- Any other person or entity required by law.
14. SECURITY __________________
We take appropriate measures to keep your Personal Information secure. We hold your Personal Information in a combination of hard copy and electric files. We use commercially reasonable physical, technical and administrative measures to protect the security of the Personal Information that we collect or receive, including, where appropriate, password protection, encryption, and SSL to protect our Site and the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Despite taking appropriate measure to protect personal information used and collected by us, please be aware that no data security measures can guarantee 100% security all of the time. We cannot guarantee the security of any information transmitted to us via the internet and such transmission is at your risk.
You are solely responsible for the maintaining the secrecy of any passwords and other account information pertaining to our Platform, apps or services.
15. ACCESS TO AND CORRECTION OF YOUR INFORMATION ___________
You can access and/or correct your Personal Information we hold about you at any time by contacting us at [email protected] We encourage you to contact us in order to keep your Personal Information up to date.
We will update your Personal Information within a reasonable time and may need to charge an appropriate fee to cover the costs of responding to your request, for example, where Personal Information is held in security. We may deny access to Personal Information if required by law or where the information may relate to existing or anticipated legal proceedings.
17. COMPLAINTS OR ENQUIRIES ________________
PO Box 4492
or, at [email protected]
If you are not satisfied with our response you are entitled to contact the Federal Privacy Commissioner, by phoning 1300 363 992 or writing to the Director of Complaints, Office of the Federal Privacy Commissions, GPO Box 5218, Sydney NSW 1042.