Privacy Policy

This privacy policy (hereinafter "Privacy Policy") deals with the protection of Your privacy while You use Our website which is hereinafter referred to as "the Product" and which is located at: www.hydralyfe.com.au. This policy also refers to how Hydralyfe Pty Ltd ("Hydralyfe", "we", "us", or "our") collects, uses, discloses, and protects your personal information when you access or use any of our services. This includes, but is not limited to, telehealth consultations, in-clinic consultations and treatments, digital platforms, booking systems, communications, and any related clinical, wellness, or patient-support services (collectively referred to as "our Services").

We are committed to the protection of Your privacy while You use the Product or engage our Services.

This Privacy Policy only applies to the Product and our Services. The Product may contain links to other websites or applications, but if that is the case, the Privacy Policy does not apply to any of those linked websites or applications.

We gather certain information from users of the Product and when you engage with our Services, so this Privacy Policy explains what information we collect, how we use it, and your rights in relation to it.

By continuing to use the Product and engage with our Services You acknowledge that You have had the chance to review and consider this Privacy Policy, and You acknowledge that You agree to it. This means that You also consent to the use of Your information and the method of disclosure as described in this Privacy Policy. If You do not understand the Privacy Policy or do not agree to it then please do not use the Product. Please note that for sensitive information, including health information, we will seek Your explicit consent at the point of collection (for example, through our intake forms, consent forms, or prior to a consultation). Your continued use of the website alone does not constitute consent to the collection of Your health or sensitive information.

DEFINITIONS

"Company IP" includes, but is not limited to, the contents, layout, design, colours, appearance, graphics and imagery of the Website, Content and Materials as well as all copyrights, trademarks, trade secrets, patents and other intellectual property contained in the Product, Content and Materials.

"Content" means any content, writing, images, audiovisual content or other information published on the Product.

"Effective Date" means the date that this Privacy Policy comes into force.

"Goods" means any or all goods provided by or on the Product.

"Items" means any and all of the Product, Goods, Services, Content and Materials collectively.

"Materials" means any materials, information or documentation that We may provide to You in connection with Your use of the Goods or Services or Product including documentation, data, information developed by Us or owned by Us, and other materials which may assist in Your use of the Goods or Services or Product.

"Parties" means both You (the user of the Product and our Services) and Us (the owner of the Product and our Services) collectively.

"Personal Information" has the meaning given in section 6(1) of the Privacy Act 1988 (Cth). It means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

"Privacy Policy" means this privacy policy.

"Product" means the website including all pages, all sub pages, all blogs, all forums, all other connected pages and all other connected internet content whatsoever, the home page or main page of which is located at: www.hydralyfe.com.au

"Sensitive Information" has the meaning given in section 6(1) of the Privacy Act 1988 (Cth). It includes health information, genetic information, biometric information, and information about an individual’s racial or ethnic origin, political opinions, membership of a political, professional or trade association or union, religious beliefs or affiliations, philosophical beliefs, sexual orientation or practices, or criminal record.

"Services" means any or all services provided by Hydralyfe or on the Product. This includes, but is not limited to, telehealth consultations, in-clinic consultations and treatments, digital platforms, booking systems, communications, and any related clinical, wellness, or patient-support services.

"Third Party Links" means links or references to websites other than the Website, to content other than the Content or to materials other than the Materials, none of which are controlled by Us.

"Third Party Service Provider" means a third party, separate from Us or Our company but which provides services that assist Us in serving You. This may include but is not restricted to web hosting, IT services, security services, payment processing, deliveries, customer service, order fulfilment or other services.

"Us", "We", "Our", "the Company" or "the Owner" refers to Hydralyfe Australia PTY LTD.

"Us", "We", "Our", "the Company" or "the Owner" also includes any employees, affiliates, agents or other representatives of Hydralyfe Australia PTY LTD.

"You" or "Your" refers to the user of the Website.

"Your Content" means any Content posted to or added to the Website, Content or Materials by You or by somebody authorised by You or doing so on Your behalf.

INTERPRETATION

In this Privacy Policy, unless the context otherwise requires, the following rules of interpretation shall apply:

Words referring to one gender include every other gender.

Words referring to a singular number include the plural, and words referring to a plural include the singular.

Words referring to a person or persons include companies, firms, corporations, organisations and vice versa.

Headings and titles are included in this Privacy Policy for convenience only and shall not affect the interpretation of this Privacy Policy.

Each Party must, at its own expense, take all reasonable steps and do all that is reasonably necessary to give full effect to this Privacy Policy and the events contemplated by it.

Any obligation on a Party not to do something includes an obligation not to allow that thing to be done.

ANONYMITY AND PSEUDONYMITY

In accordance with Australian Privacy Principle 2, You have the right to interact with Us anonymously or by using a pseudonym where it is practicable for Us to deal with You in that way.

You may browse the Product, access general information about our Services, and make general inquiries without identifying yourself.

However, it may be impracticable for Us to deal with You anonymously or pseudonymously in certain circumstances, including but not limited to:

• When You engage our clinical or telehealth Services, as identification is required for patient safety, clinical record-keeping, and regulatory compliance.
• When You make a purchase or financial transaction.
• When identification is required or authorised by Australian law or a court or tribunal order.

Where anonymity or pseudonymity is not practicable, We will only collect the minimum Personal Information necessary to provide the relevant service or fulfil the relevant function.

TYPE OF INFORMATION AND HOW IT IS COLLECTED

When You use the Product or Our Services, We may collect information from You through automatic tracking systems (such as information about your browsing preferences).

In addition, We may collect information that You volunteer to Us (such as information that You provide during a sign up process or at other times while using the Product or our Services).

In order to access all of the features of the Product, You are required to register as a user. During the registration process, We collect some of Your Personal Information, in the following manner:

We will not collect information that identifies You personally, except when You specifically volunteer that information to Us.

The information that We will collect from You at registration includes: name, email address, contact number, address, date of birth. We only collect Personal Information that is reasonably necessary for, or directly related to, one or more of our functions or activities.

By undergoing the registration process You consent to Us collecting Your Personal Information, including the Personal Information described in this clause. You also consent to Us collecting any other Personal Information as well as storing, using or disclosing Your Personal Information in accordance with this Privacy Policy. For the collection of Sensitive Information, including health information, We will obtain Your explicit, informed consent prior to collection, separate from this general consent.

In order to access some specific features of the Product and to engage with our Services, You are required to provide some Personal Information. During this process, We collect some of Your Personal Information, in the following manner:

We will not collect information that identifies You personally, except when You specifically volunteer that information to Us when using specific Product or Service features. These specific features might include, but are not limited to:

• making purchases
• Completing service intake and consent forms
• Completing consultations with our staff
• receiving notifications by text message or email about events and promotions
• receiving general emails from Us
• commenting on Our content such as blogs, articles, photographs or videos, or participating in Our forums, bulletin boards, chat rooms or other similar features
• participating in surveys

In addition to any Personal Information that You are required to provide in order to access these additional Product and Service features, in some cases You may be required to provide more specific information. For example, in order to make purchases, You may need to provide credit card information, billing information and postal addresses.

Collection of Health Information

As a telehealth provider, we may collect health information about you whilst delivering Services only where You have provided Your explicit consent or where a permitted health situation exists under section 16B of the Privacy Act 1988 (Cth). Health information is classified as Sensitive Information under the Privacy Act and is subject to additional protections. We will only collect the minimum amount of health information necessary to provide a health service to You.

This specific health related information might include, but is not limited to:

• Medical history, health status and clinical notes
• Medication and supplement use
• Treatment history and prescriptions
• Test results, pathology information, and diagnostic data
• Telehealth consultation details (audio, video, or written)
• Symptoms, adverse reactions, allergies
• Lifestyle, nutrition, and substance-use history (where clinically relevant)
• Delivery preferences

Consequences of Not Providing Personal Information

If You choose not to provide certain Personal Information, We may not be able to provide some or all of our Services to You. For example:

• If You do not provide identification and contact details, We may be unable to register You as a user or process transactions.
• If You do not provide health information, We may be unable to provide clinical or telehealth services safely or at all.
• If You do not provide payment information, We may be unable to process purchases.

We will inform You at the point of collection if the provision of certain Personal Information is required and the consequences of not providing it.

Unsolicited Personal Information

If We receive Personal Information that We have not requested or solicited (unsolicited information), We will, within a reasonable period, determine whether We could have collected the information under this Privacy Policy. If We determine that We could not have collected it, and the information is not contained in a Commonwealth record, We will destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so.

From time to time We may request information from You to assist Us in improving Our Product, Goods, Services, Content or Materials. For example, We may ask You to answer some questions about Your demographics, Your shopping preferences, or Your other preferences in relation to the Product.

COOKIES

Cookies are small files stored on Your computer or mobile device which collect information about Your browsing behaviour.

Cookies do not access information which is stored on Your computer.

Cookies enable us to tailor our configurations to Your needs and preferences, in order to improve Your user experience.

Most internet browsers accept cookies automatically, although You are able to change Your browser settings to control cookies, including whether or not You accept them, and how to remove them. You may also be able to set Your browser to advise You if You receive a cookie, or to block or delete cookies. However, if You do this, You may be prevented from taking full advantage of the Product.

Third parties who advertise on the Product may use cookies in order to learn about Your browsing preferences and to present relevant advertisements to You. Cookies enable these advertisers to recognise Your computer each time You are sent an advertisement. It allows them to compile information about where You saw their advertisement, and to better target their advertisements. You may notice these targeted advertisements on the Product or on other websites that You visit. We do not control the cookies that may be used by these third party advertisers. This Privacy Policy only addresses Our use of cookies and does not address the use of cookies by any of these third party advertisers. For information about the use of cookies by these third party advertisers you will need to consult their privacy policies or cookies policies respectively.

HOW YOUR INFORMATION IS STORED

Please note that no systems involving the transmission of information via the internet, or the electronic storage of data, are completely secure. However, we take the protection and storage of Your Personal Information very seriously. We take all reasonable steps to protect Your Personal Information.

We use appropriate physical, digital, managerial and security systems to store Your Personal Information and to protect it against unauthorised access, destruction or disclosure. In accordance with Australian Privacy Principle 11, Our security measures include both technical measures (such as encryption, access controls, firewalls, and secure data storage) and organisational measures (such as staff training, access policies, and regular security reviews). 

DATA RETENTION AND DESTRUCTION

We will retain Your Personal Information only for as long as it is needed for the purposes for which it was collected, or as required by applicable law. When Personal Information is no longer needed for any purpose for which it may be used or disclosed under the Australian Privacy Principles, We will take reasonable steps to destroy it or ensure that it is de-identified.

Retention Periods

The retention period for Your Personal Information will depend on the type of information and the purpose for which it was collected. General guidance on our retention periods includes:

• Health and clinical records: retained for a minimum of 7 years from the date of last entry for adults, or until a minor patient turns 25 years of age (whichever is longer), in accordance with applicable state and territory health records legislation.
• General account and transaction records: retained for the period required by applicable tax and corporate law (generally 5–7 years).
• Marketing and communication preferences: retained until You withdraw Your consent or opt out.
• Website usage data and cookies: retained in accordance with our cookie settings and typically for no longer than 12 months.

Where We are required by law to retain Personal Information for a specified period, We will retain it for that period even if it is no longer needed for our operational purposes.

Destruction and De-identification

When Personal Information is due for destruction, We will take reasonable steps to securely destroy or permanently de-identify it. Secure destruction may include secure digital deletion, degaussing, or physical destruction of storage media. De-identified information may be retained for research, statistical analysis, or service improvement purposes where it can no longer be used to identify any individual.

NOTIFIABLE DATA BREACHES

In accordance with Part IIIC of the Privacy Act 1988 (Cth), We are required to notify the Office of the Australian Information Commissioner (OAIC) and affected individuals in the event of an eligible data breach.

An eligible data breach occurs when there is unauthorised access to, unauthorised disclosure of, or loss of, Personal Information held by Us, and this is likely to result in serious harm to any of the individuals to whom the information relates.

If We become aware of a suspected or actual eligible data breach, We will:

• Promptly assess whether the breach is likely to result in serious harm to affected individuals.
• If serious harm is likely, notify the OAIC and affected individuals as soon as practicable.
• Include in the notification a description of the breach, the types of information involved, and recommendations about the steps individuals should take in response.
• Take all reasonable steps to contain the breach and mitigate any harm.

THIRD PARTIES

We may provide some of Your Personal Information from time to time to Third Party Service Providers so that they can help us to serve You via the Product. In particular, We may use Third Party Service Providers to assist with information storage (such as cloud storage).

We may provide some of Your Personal Information to Third Party Service Providers for the purpose of analysing data or tracking usage. For example, We may use these services to find out where page requests come from, dates and times of page requests, details of any website that referred You to the Product and other details about Your usage of the Product. This information enables Us to understand patterns of usage of the Product, and to improve the Product.

We may use Third Party Service Providers to host the Product. If this occurs, that Third Party Service Provider is likely to have access to some of Your Personal Information.

We may use Third Party Service Providers to fulfil orders in relation to the Product or our Services.

We may allow third parties to advertise on the Product. These third parties may use cookies in connection with their advertisements (see the "Cookies" clause in this Privacy Policy).

For Your information, some of Our Third Party Service Providers may be located outside Australia and may not be subject to Australian privacy laws. The countries or regions in which our Third Party Service Providers may be located include: United States of America, Canada, Singapore  European Union, United Kingdom.

Before disclosing Your Personal Information to an overseas recipient, We will take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to that information. We acknowledge that under section 16C of the Privacy Act 1988 (Cth), We remain accountable for any acts or practices of the overseas recipient that would breach the Australian Privacy Principles, as if those acts or practices had been carried out by Us.

Your Personal Information will not be sold or otherwise transferred to other third parties without Your approval.

Notwithstanding the other provisions of this Privacy Policy, We may provide Your Personal Information to a third party or to third parties in order to protect the rights, property or safety, of Us, Our customers or third parties, or as otherwise required by law.

We will not knowingly share Your Personal Information with any third parties other than in accordance with this Privacy Policy.

If Your Personal Information might be provided to a third party in a manner which is other than as explained in this Privacy Policy, You will be notified. You will also have the opportunity to request Us not to share that information.

RELATED ENTITIES

We may share Your Personal Information, including Personal Information that identifies You personally, with any of Our parent companies, subsidiary companies, affiliates or other trusted related entities. Trusted related entities include:

• Treating practitioners and clinicians involved in the delivery of services that you engage Hydralyfe to deliver to you
• Laboratories, pharmacies, and diagnostic partners
• Partner clinics that will be involved in the delivery of services to you
• IT and cloud service providers
• Payment processors
• Regulatory bodies, if legally required

However, We only share Your Personal Information with a trusted related entity if that entity agrees to Our privacy standards as set out in this Privacy Policy.

Please note that the sharing of Sensitive Information (including health information) with related entities is limited to circumstances that are directly related to the primary purpose for which the information was collected (such as the delivery of health services), or where We have Your explicit consent, or where otherwise permitted by the Australian Privacy Principles.

COMBINING INFORMATION

We may combine, link or aggregate some of Your information in order to obtain a better understanding of Your requirements. This may enable Us to better design the Product or our Services and may also assist with Our business or administration requirements.

We may also share aggregated information with third parties. Where information is aggregated, We will take reasonable steps to ensure that it is de-identified so that it is no longer about an identifiable individual.

HOW YOUR INFORMATION IS USED

We use Your Personal Information to help us improve your experience with Our Product. In accordance with Australian Privacy Principle 6, We will only use or disclose Your Personal Information for the primary purpose for which it was collected, or for a secondary purpose that You would reasonably expect, and that is related to the primary purpose. For Sensitive Information (including health information), any secondary purpose must be directly related to the primary purpose of collection.

Use of General Personal Information

We may use Your general Personal Information (such as name, contact details, and account information) for the following purposes:

• Providing customer service to You.
• Order fulfilment (including payments).
• Verifying Your identity.
• Advising You about updates to the Product or related Items.
• Marketing and advertising to You, including both direct and indirect marketing and advertising about products that may interest You, where You have consented or would reasonably expect to receive such communications.
• Market research, product development, personalisation, and determining the value and effectiveness of our products and services.
• Complying with legal obligations.

Use of Health and Sensitive Information

We may use Your health information and other Sensitive Information only for the following purposes, which are directly related to the provision of health services:

• Providing telehealth services, medical care, and clinical support.
• Providing treatment recommendations.
• Coordinating care with other clinicians, pharmacies, or laboratories involved in Your treatment.
• Quality assurance and clinical safety reviews.
• Preparing consolidated clinical reports with the assistance of AI tools, using de-identified information, for review by a qualified clinician (see the "Use of Artificial Intelligence and Automated Tools" section below for further details).
• Staff training where information is de-identified.
• Complying with legal and regulatory obligations (including mandatory reporting requirements).
• As otherwise authorised by the Australian Privacy Principles, including in a permitted health situation under section 16B of the Privacy Act 1988 (Cth).

We will not use Your health information or other Sensitive Information for marketing, advertising, product development, data-driven decision making, or any other purpose that is not directly related to the provision of health services, unless We have obtained Your explicit consent to do so.

USE OF ARTIFICIAL INTELLIGENCE AND AUTOMATED TOOLS

How We Use AI Tools

We may use artificial intelligence (AI) and automated software tools to assist in the delivery of our Services. These tools are used for administrative and operational purposes only, such as collating and consolidating client information into structured reports for review by a qualified clinician. Our AI tools do not make clinical decisions, diagnoses, or treatment recommendations. All clinical decisions are made by qualified healthcare practitioners who review the outputs of any automated process.

De-identification of Your Information

Before any of Your information is provided to an AI tool for processing, We take reasonable steps to de-identify it so that the information can no longer be used to identify You. De-identification involves removing or altering personal identifiers such as Your name, contact details, date of birth, and any other information that could reasonably be used to identify You. The AI tool receives and processes only de-identified information.

We regularly assess and manage the risk of re-identification in accordance with guidance issued by the Office of the Australian Information Commissioner (OAIC), recognising that information which is not personal information in isolation may become personal information if combined with other data.

Human Oversight

All outputs generated by AI tools are reviewed by a qualified clinician before being used in connection with Your care. The AI tool is used solely to assist with the preparation and formatting of information; the clinical interpretation and any decisions based on that information are made by a human practitioner.

Accuracy and Limitations

AI tools may produce outputs that are inaccurate, incomplete, or that do not fully reflect the source information. In accordance with Australian Privacy Principle 10, We take reasonable steps to ensure the accuracy of any information used in connection with Your care. This includes clinician review of all AI-generated outputs before they are relied upon. We do not use AI-generated outputs as the sole basis for any decision that could significantly affect Your rights or interests.

Your Rights

You have the right to ask Us whether AI tools have been used in the preparation of reports or other materials relating to Your care. You may also request a copy of any report prepared with the assistance of AI tools, subject to the access provisions set out elsewhere in this Privacy Policy. If You have concerns about our use of AI tools, You may raise them with Us using the contact details at the end of this Privacy Policy or through our complaints process.

GOVERNMENT RELATED IDENTIFIERS

In accordance with Australian Privacy Principle 9, We will not adopt, use, or disclose a government related identifier of an individual unless the adoption, use, or disclosure is reasonably necessary for Us to verify Your identity, to fulfil Our obligations to a government agency, or as required or authorised by Australian law or a court or tribunal order.

Government related identifiers that We may handle in the course of providing our Services include, but are not limited to:

• Medicare numbers
• Individual Healthcare Identifiers (IHIs) under the Healthcare Identifiers Act 2010 (Cth)
• Department of Veterans’ Affairs (DVA) numbers
• Pension or concession card numbers

We will not use any government related identifier as our own identifier for You, and We will take reasonable steps to protect government related identifiers from misuse, loss, and unauthorised access.

QUALITY OF PERSONAL INFORMATION

In accordance with Australian Privacy Principle 10, We will take reasonable steps to ensure that the Personal Information We collect, use, and disclose is accurate, up-to-date, complete, and relevant, having regard to the purpose for which it is collected or used.

For health information, data quality is particularly important as inaccurate or incomplete information may affect the safety and quality of clinical care. We may periodically ask You to verify or update Your Personal Information to ensure its accuracy.

We encourage You to contact Us if You become aware that any of Your Personal Information held by Us is inaccurate, out-of-date, incomplete, or irrelevant, so that We can take steps to correct it.

VULNERABLE USERS

We may collect information from specific categories of users who may be particularly vulnerable, including: elderly, chronic conditions, hardship.

Information collected from vulnerable users in accordance with this clause is collected for the purpose of helping us to improve the Product, our Services and Your user experience.

Information collected from vulnerable users in accordance with this clause, is collected, used and if applicable, disclosed, in accordance with the general provisions of this Privacy Policy.

We recognise that vulnerable users may require additional safeguards and consideration. In relation to vulnerable users, We will:

• Take additional care to ensure that consent is informed, voluntary, and given with full understanding of its implications.
• Provide information in a manner that is accessible and easy to understand.
• Apply additional protections to the handling of their Personal Information where appropriate.
• Ensure that our staff are trained to identify and respond appropriately to the needs of vulnerable users.

MERGER, RESTRUCTURE OR SALE OF OUR BUSINESS

Part or all of Our business may be merged, restructured or sold including but not limited to through an ordinary sale of business or of stock, a corporate reorganisation, a change in control, bankruptcy or insolvency proceedings.

In the event that such a merger, restructure or sale occurs as described in the preceding sub-clause hereof, We may transfer Your Personal Information, including personally identifiable information, as part of that merger, restructure or sale. Any receiving entity will be required to handle Your Personal Information in accordance with the Australian Privacy Principles and the commitments made in this Privacy Policy.

INFORMATION YOU RELEASE

You acknowledge and agree that if You publish or submit Personal Information in publicly accessible sections of the Product (such as forums, bulletin boards, chat rooms, or other similar sections), then You are solely responsible for the release of that Personal Information and We are not liable or responsible in relation to the release of that Personal Information.

EMAIL OPT IN/OUT

If You receive an email from Us in relation to the Product and would prefer not to receive such correspondence in the future, You may follow the instructions in the email to opt out of future correspondence. You may also contact Us, using the details at the bottom of this Privacy Policy, in order to opt out of future correspondence. We will make all reasonable efforts to promptly comply with Your requests. However, You may receive subsequent correspondence from Us while Your request is being handled.

The right to opt out applies to all forms of direct marketing communications from Us, including email, SMS, telephone, and targeted digital advertising. You may opt out at any time by contacting Us using the details at the bottom of this Privacy Policy or by using the unsubscribe mechanism in the relevant communication.

We will not use Your health information or other Sensitive Information for direct marketing purposes.

ACCESSING, UPDATING AND CORRECTING YOUR PERSONAL INFORMATION

You have the right to request access to any of Your Personal Information which We are holding.

You have the right to request that any of Your Personal Information which We are holding be updated or corrected.

In order to request access, an update or a correction to Your Personal Information, you may contact us using the details at the end of this Privacy Policy.

Access Requests

We will respond to access requests within a reasonable period, which in most cases will not exceed 30 days from the date of Your request. If We anticipate that a longer period will be required, We will notify You of the expected timeframe and the reasons for the delay.

In limited circumstances, We may refuse to grant access to Your Personal Information. These circumstances include where access would pose a serious threat to the life, health, or safety of any individual, where access would have an unreasonable impact on the privacy of other individuals, where the request is frivolous or vexatious, where the information relates to existing or anticipated legal proceedings, or where access would be unlawful. If We refuse access, We will provide You with written reasons for the refusal and the mechanisms available to You to make a complaint.

We will not charge You for making a request for access. However, if reasonable, We may charge a fee for providing access that is not excessive and that reflects the cost of retrieving and providing the information.

Correction Requests

If We are satisfied that Your Personal Information is inaccurate, out-of-date, incomplete, irrelevant, or misleading, having regard to the purpose for which it is held, We will take reasonable steps to correct it. We will respond to correction requests within a reasonable period.

If We refuse to correct Your Personal Information, We will provide You with written reasons for the refusal. You may then request that We attach a statement to the information noting that You consider it to be inaccurate, out-of-date, incomplete, irrelevant, or misleading. We will take reasonable steps to attach such a statement in a way that makes it apparent to users of the information.

In the case of health records, We acknowledge that clinical notes reflecting a practitioner’s professional opinion may not be amended, but You have the right to have a statement of Your requested correction attached to the relevant record.

DISCLAIMER REGARDING SECURITY

By continuing to use the Product, You agree to the terms of this Privacy Policy. You acknowledge, agree and accept that no transmission of information or data via the internet is completely secure. You acknowledge, agree and accept that We do not guarantee or warrant the security of any information that You provide to Us, and that You transmit such information at Your own risk.

This disclaimer does not limit or affect Our obligation to take reasonable steps to protect Your Personal Information in accordance with Australian Privacy Principle 11 and the Privacy Act 1988 (Cth).

CHANGES TO THIS POLICY

We may make changes to this Privacy Policy at any time in Our sole discretion.

If We make changes to this Privacy Policy, unless We obtain Your express consent to those changes, then such changes will only apply to any information that We obtain from You after the date that the changes take effect.

If We make changes to this Privacy Policy, Your continued use of the Product after the date that the changes take effect confirms that You acknowledge, accept and agree to those changes.

COMPLAINTS

We take customer satisfaction very seriously. If You have a complaint in relation to Our handling of Your Personal Information, We will endeavour to handle it promptly and fairly. For Your information, an overview of Our complaints handling procedure is as follows:

Any complaints are forwarded to Our complaints officer for review. We aim to review all complaints within 7 days of receiving them (although this cannot be guaranteed). If necessary, the complaints officer may then refer the complaint to another section within Our organisation for consideration. If further information is required, We may contact You to request that information. If We accept fault in relation to the complaint then We will propose a resolution (which may or may not be the same as any resolution proposed by You). If We do not accept fault, then We will contact You to advise You of this. We aim to complete this entire process within 21 days, provided that We are provided complete information in the first place (although this cannot be guaranteed). However, if You do not provide complete information then this is likely to delay the handling of Your complaint.

All complaints should be provided in writing either by email or regular mail, using the contact details at the end of this privacy policy. Describe the nature of your complaint including any relevant dates, people involved, any consequences that have occurred, and what you believe should be done to rectify the issue. We will endeavour to respond within 21 days, although we cannot guarantee this.

If You are not satisfied with Our response to Your complaint, You may refer your complaint to the Office of the Australian Information Commissioner (OAIC). You can contact the OAIC by visiting www.oaic.gov.au, calling 1300 363 992, or writing to GPO Box 5218, Sydney NSW 2001.

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