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Global Health’s Commitment to Your Privacy

Global Health Limited (Global Health) respects your right to privacy.

For the purposes of this privacy policy, “Personal information” is information or an opinion we hold which is reasonably identifiable as being about you.

This privacy policy applies to Global Health, its subsidiaries and their respective websites (Sites). It states how we collect personal information from you, how we hold your personal information, the purposes for which we use it and how you can access it or seek its correction. Global Health is committed to respecting and protecting your privacy as a client and as a visitor to our Sites.

In order to maximise the benefit to users of Global Health Sites, we gather information about our users and this privacy policy discloses what personal information Global Health gathers and how we use it.

1. Australian Privacy Principles

The Australian Privacy Principles established by the Privacy Act 1988 (Cth) apply to Global Health of Level 2, 696 Bourke Street Melbourne, Victoria, 3000, Australia.

2. Why does Global Health collect information about users?

Information is requested from our users in order to provide and deliver better services and solutions to our clients, and prospective clients.

3. The personal information Global Health collects from Clients and what we use it for

3.1  Collection of personal information 

We may request, collect and/or hold the following types of personal information from you if you are our client (or use the services of our clients) in order to conduct our business:

  • names;
  • job titles and organisation details;
  • street and postal addresses;
  • email addresses;
  • telephone and facsimile numbers;
  • information about the products and/or services you have ordered/purchased and their performance records;
  • information about your business or practice needs, to assess requirements for products and services;
  • information about your enquiries, opinions or instructions;
  • information held by us as custodians of server(s) containing electronic health records. That may include:
    • health information, such as information about your physical or mental health, notes of your symptoms or diagnosis and the treatment given, specialist reports and test results, appointment and billing details, prescriptions and other pharmaceutical records;
    • other information about your date of birth, gender, race, sexuality or religion contained in an electronic health record, which you have provided to our client for the purposes of them providing you with a health service;
    • government identifiers, such as your Medicare number;
  • communications between us; and
  • credit card and bank information.
  • HealthKit Information, which is addressed in section 6 of this privacy policy.

 

3.2  Purposes for which Global Health holds personal information

We primarily hold personal information relating to clients for the following purposes:

  • invoicing;
  • to conduct direct marketing or provide you with information that we consider may interest you;
  • to assess your requirements for products and services;
  • general testing and maintenance of products, services and servers;
  • in order to correct data errors, test or carry out maintenance with the client’s consent, on databases which may include patient records;
  • to provide subscriber-based applications and services; and
  • to manage client and business relationships.

 

3.3  Access to personal and medical data

From time to time employees of Global Health (and third parties with whom we engage) may have access to personal health records by reason of a Global Health product or service which you, or your healthcare provider utilises (for example, due to the use of our patient administration software, electronic management record software, secure messaging delivery system or electronic health record systems).

Due to the national and international scope of its operations, Global Health also use a third-party offshore team to help provide a support service to you if you are our client or use the services of our clients. Whilst it is not reasonably practicable to list all of the countries where Global Health may use a third-party offshore team, the countries in which such teams are likely to be located include, but are not limited to, the Philippines and Vietnam.

Whilst the data in Global Health’s software products is stored in Australia, the offshore team may need to access this data, which may include your personal information, when they provide support to you.

Please note that if Global Health’s offshore team handles your personal information in a manner which is inconsistent, or does not comply, with the Australian Privacy Principles:

  • to the maximum extent permitted by law, Global Health will not be accountable under the Privacy Act 1988 (Cth) for any resulting loss or damage that you may suffer;
  • to the maximum extent permitted by law, you will not be able to seek redress against Global Health under the Privacy Act 1988 (Cth);
  • the offshore team may not be subject to any privacy obligations at all, or to any principles similar to the Australian Privacy Principles;
  • you may not be able to seek redress against the offshore team in their jurisdiction; and
  • in having access to your personal information, the offshore team may be subject to foreign laws which compel their disclosure of your personal information to other parties, such as overseas government authorities.

If you proceed to submit your personal information, you are consenting to the transmission, disclosure, storage and access of your personal information by those third parties in overseas jurisdictions. Australian Privacy Principle 8 which ordinarily obliges Global Health to take reasonable steps to ensure that overseas recipients of your information do not breach the Australian Privacy Principles (except Principle 1) will not apply.

If you provide your consent and subsequently elect to withdraw it, please submit a written request to Global Health’s Compliance Officer at:

  • Email: privacy@global-health.com
  • Telephone: +61 3 9675 0600

You should refer to the specific privacy policy (if any) for each of Global Health’s products and services. In the absence of a specific privacy policy for the product or service that you engage, where Global Health is allowed access to medical patient databases, and in addition to complying with the other privacy requirements set out in this privacy policy.

4. How Global Health collects personal information from visitors and users of our Sites and what we use it for:

4.1  Automatic Collection of Information:

If you do nothing during your visit but browse through our Site(s) or download information, our system will automatically gather and store certain anonymous information that cannot be linked to a specific individual. This information does not identify you personally and is used in an aggregate way to help us improve our Sites and tell us the number of visitors to our Sites each day. Our Web server automatically collects and records the following information:

  • the visitor’s domain name;
  • the visitor’s IP address;
  • aggregate information on what pages are accessed; and
  • the name and release number of web browser software used.

 

4.2  Optional Permission-based collection of Information 

We offer the following services, which collect and transfer information from other programs that we operate:

Internal transfers of personal information
A number of our products are made available to you either directly by us or by third party healthcare providers.
The personal information stored or collected in those products (e.g. MasterCare) is collected by us directly or in some circumstances transferred to, or by us, to other products within our range that you subscribe to (e.g. LifeCard®).

We offer the following services, which require voluntary submission of your email address and some personal information:

 

  • Registration for Customer Support Access
    The majority of general information does not require Global Health to gather information about people viewing our Sites. However, in order to access client-specific support, content and features of some of our Sites, we require registration, and the disclosure of personal information and in some instances, government identifiers in order to authorise client access.

 

  • Electronic newsletters
    We may offer a free electronic newsletter to users. Global Health gathers the email addresses of users who voluntarily subscribe. Users may remove themselves from our mailing lists by using the ‘Unsubscribe’ function.

 

  • Message Boards/Forums/FAQ’s
    Access to Message boards, Forums and Frequently Asked Questions (FAQ’s) is usually only available to registered Global Health clients.

 

  • Access to Web-based Products
    The nature of some of our web-based products inherently require users to provide their personal information, including sensitive personal information such as health and medical information, which is stored in Global Health’s servers.

 

  • Access to Product Updates or files
    As a service to our registered clients, we may make software updates available for direct download from our Sites, or files that have been created by other users for sharing with our broader user community. This will not be available for all software applications. In order to access and download these updates or user-created files, we require clients to be registered.

 

  • Downloads of Product information
    As a service to users of our Sites, we may make product information available for direct download. Global Health gathers minimal personal information of users who voluntarily request this Product Information.

 

  • Downloads of Trial Software
    As a service to users of our Sites, we may make product information available for direct download. Global Health gathers minimal personal information of users who voluntarily request this product information.

 

  • “E-mail this to a friend” Service
    Visitors to our Sites may choose to electronically forward a link, page, or document to someone else by clicking “e-mail this to a friend”. The users must provide their email address, as well as that of the recipient. This information is used only in the case of transmission errors and, of course, to let the recipient know who sent the email. The information is not used for any other purpose.

 

  • Polling
    We may, from time to time, offer interactive polls to users so they can easily share their opinions with other users and see what our audience thinks about important issues concerning Global Health and our brands. Opinions or other responses to polls are aggregated and are not identifiable to any particular user(s) details. Global Health may use a system to “tag” users after they have voted, to ensure that each user votes only once on a particular question. This tag is not correlated with information about individual users, and only exists for the life of the poll.

 

  • Surveys
    Global Health may occasionally conduct user surveys to better target our content to our audience. We sometimes share the aggregated demographic information in these surveys with our partners such as marketing agencies and technology solution providers. We do not share any identifying information about specific individuals with any third parties. We do not re-sell our database onto third parties.

5. Usage Tracking

Global Health tracks user traffic patterns throughout all of our Sites. However, we do not correlate this information with data about individual users. Global Health does break down overall usage statistics according to a user’s domain name, and browser type, by reading this information from the browser string (information contained in every user’s browser).

We use tracking information to determine which areas of our Sites users like, and don’t like, based on traffic to those areas. We do not track what individual users read, but rather how well each page performs overall. This helps us continue to build a better service for you. We track search terms entered in the Search function as one of many measures of what interests our users, but we do not track which terms a particular user enters.

6. With Whom Will the Information Be Shared or Disclosed?

6.1 Definition of HealthKit Information

For the purposes of this section 6, HealthKit Information means your health and fitness data:

  • which is collected by Apple Inc. using an Apple iPhone, watch or other device and stored within the Apple HealthKit, being an Apple Inc. product; and
  • which may include data related to your blood glucose levels, blood pressure, body temperature, calories burned, distance travelled, forced expiratory volume, heart rate, height, menstruation status, oxygen saturation level, peak expiratory rate, respiratory rate, resting heart rate, sleep, step count, VO2 max and weight.
6.2 Consent to individual categories of HealthKit Information

You can choose to share your HealthKit Information with, and store it within, Global Health’s LifeCard® application. This section of our privacy policy describes how we collect, disclose and use that HealthKit Information with your consent. It does not address HealthKit Information that you provide to Apple Inc, which is governed by Apple Inc’s own Privacy Policy and other terms.

Global Health may access, disclose and use one or more categories of HealthKit Information, provided that you consent to us doing so for that particular category of HealthKit Information. For example, you could choose to share your body temperature with our LifeCard® application, but not your blood pressure. We store your HealthKit Information to assist you in managing your health conditions and / or to allow our clients to provide health services to you.

You can change the categories of HealthKit Information that are shared with Global Health from time to time within the relevant Apple Inc. application (e.g. Apple Health) on your iPhone, Apple Watch or other device.

You can withdraw your consent to Global Health’s use of your HealthKit Information at any time within the relevant Apple Inc. application (e.g. Apple Health) on your Apple iPhone, watch or other device. Withdrawing your consent will not prevent you from using the LifeCard® application, however some of its functionality will be disabled or diminished.
Notwithstanding any other section of this Privacy Policy:

  • we will only use your HealthKit Information to provide information technology services which enable you to manage your health conditions and / or to provide those information technology services to our clients who provide health services to you. Global Health will not advertise, sell or share your HealthKit Information to third party advertising platforms, data brokers or information resellers. Nor will we use your HealthKit Information for data-mining activities; and
  • we will not disclose HealthKit Information to any third-party without your prior consent. Such parties may only use HealthKit Information to provide health, motion and / or fitness services (including medical research services), or to improve your health management. Third-parties with whom HealthKit Information is shared (if any) are required to provide the same or an equal degree of data protection as stated in this Privacy Policy. HealthKit Information is not transmitted to any of Global Health’s data servers overseas.

7. With Whom Will the Information Be Shared or Disclosed?

We will only disclose personal sensitive information with your consent.

Your non-sensitive personal information may be shared with third party organisations with whom we engage, such as marketing agencies, advertisers, sponsors, partners, health and other agencies, technology solution providers that comply with applicable laws or valid legal process to protect the personal safety of our users.

Except where necessary to provide subscriber-based services to our clients, we do not rent, sell, exchange or provide any of your personal information to third-party organisations for a fee.

We will allow your sensitive personal information to be shared with third party individuals and organisations only where you or your authorised delegate(s) have specifically allowed those third parties to access your sensitive information via our web-based products which have such functionality.

All Global Health employee and contractor agreements include a confidentiality undertaking on commencement of their employment or engagement.

Global Health maintains back-up records. Where you request the deletion of personal information from our records, it is not practical, and Global Health will not remove or delete all your information, from all data back-ups.

8. Children

Global Health Sites do not usually feature information and services of interest to children 13 years of age and under.

9. Cookies

We use “cookies” to provide customisable and personalised services to visitors of Global Health Sites.

A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. A cookie can’t read data off your hard disk or read cookie files created by other sites. For example, a website may use cookies to store and sometimes track information about you, your preferences, or the pages you last visited. You can change your browser settings to reject all cookies, or to ask you if you would like to accept or decline a cookie from a particular site. You do not need to have cookies turned on to use Global Health Sites. However, if you reject a cookie, certain functions of our Sites may be affected.

We use cookies on our Sites for the following purposes:
  • store and sometimes track visitor preferences;
  • record user-specific information on what pages users visit;
  • alert visitors to new areas that we think might be of interest to them when they return to our Sites; and
  • to record past activity at a Site in order to provide better service when visitors return to our Sites.

10. Security

Global Health operates a secure data network(s) protected by industry standard firewall and password protection systems. We have appropriate security measures in place in our physical facilities to protect against the loss, misuse, or alteration of information that we have collected from you at our Sites. Our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised individuals have access to the information that you provide.

11. Opt-In Policy

We will only record your email address if you send us a message, you subscribe to a mailing list or alert service or you include it in any of your Global Health accounts. Your personal information will be added to our mailing list(s) when you opt in or register to receive our electronic communications.

12. Access to and Correction of Personal Information

Requests for access to, or correction of, your personal information must be made in writing, specifying the information that you are seeking to access or correct.
We will ordinarily grant you access to personal information unless:

  • giving access would have an unreasonable impact on the privacy of other individuals;
  • the request for access is frivolous or vexatious;
  • we are unable to verify your identity;
  • we are entitled to reject your access to the personal information under any law; or
  • granting access to you would be unlawful.

We reserve the right to charge a reasonable fee for providing access to the personal information, but not for making the application or correcting personal information held by us. We may withhold access to the personal information until the fee is paid.
If you are of the view that your personal information requires correction, you should contact the Compliance Officer listed below.

13. Changes in Our Privacy Policy

We may change this privacy policy in the future. The revised versions will be uploaded onto our website, so please check back from time to time.

14. Enquiries and Complaints

Global Health is committed to following the Australian Privacy Principles as required by the Privacy Act 1988 (Cth).

For more information on the Australian Privacy Principles please refer to The Office of the Australian Information Commissioner at: http://www.oaic.gov.au.

We take complaints very seriously and ask that you provide a written explanation of your complaint. We will investigate your complaint and respond shortly after receiving it.

Enquiries and complaints may be made to:

Contact: Compliance Officer
E-mail: privacy@global-health.com
Telephone: +61 3 9675 0600

You can also make complaints to the Office of the Australian Information Commissioner at http://www.oaic.gov.au.

15. Modification Date

This privacy policy was last modified on 19 August 2021, and was last reviewed by Global Health’s Executive Management Committee on 25 October 2021.

16. Disclaimer

The Content of Our Sites

The information available at Global Health Sites as well as the products, services and resources (Content) described at our Sites, are for general educational and information purposes only. You use our Sites at your sole risk. You must evaluate, and bear all risks associated with, the use of any Content, including reliance on the accuracy, completeness or usefulness of any Content. Global Health does not guarantee the accuracy, currency or adequacy of the Content available at our Sites by virtue of providing access to or information about such Content. You should check the terms of use and warranties which apply to the Content when you subscribe to or acquire them. By including them in our Sites, Global Health does not make additional warranties or representations about the Content in addition to those already provided in relation to the products, services and resources themselves. You acknowledge that parts of our Sites are or may be provided or maintained by third party providers (Providers) and not by us. Your correspondence or dealings with any Providers are solely between you and that Provider, and you agree that we will not be liable or responsible for any loss or damage of any sort incurred as the result of such dealings.

Global Health Sites

We endeavour to provide convenient and functional Sites, but we do not guarantee that the Content will be error free or that the Sites or the server(s) that operate(s) them are free of viruses or other harmful components. If your use of our Sites results in the need for servicing or replacing property, material, equipment or data, we will not be responsible for such costs. Without limiting the above provisions, everything on our Sites is provided to you “as is” and “as available” without warranty or condition of any kind, either expressed or implied, including, but not limited to, any implied warranties of merchantability, fitness for a particular purpose, or non-infringement of intellectual property rights/laws or any other laws or third party rights.

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