Privacy Policy

We understand that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us, offline or online, including through our services, our website, and our telehealth introductory platform and pharmacy introductory platform (Services). In this Privacy Policy, we, us, or our means Chelem Health Pty Ltd.

Personal Information

The types of personal information we may collect about you include:

As a patient:

• Your name;
• Your date of birth;
• Your contact details, including email address, mailing address, street address, and telephone number;
• Your credit card or other payment details (through our third-party payment processor);
• Your sensitive information as set out below;
• Images of you for your profile;
• Your preferences and/or opinions;
• Your general practitioner’s details;
• Information you provide to us through patient surveys;
• Details of the medications you have requested/received and any other services or support we have provided to you and/or that you have enquired about, and our response to you;
• Details of the consultations you have requested/received and any other services or support we have provided to you and/or that you have enquired about, and our response to you; and
• Any other personal information requested by us and/or provided by you or a third party.

As a user of our services:

• Your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries, and/or browsing behaviour;
• Information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using, and the domain name of your Internet service provider;
• Additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms, and/or accounts from which you permit us to collect information; and
• Any other personal information about your use of the Services requested by us and/or provided by you or a third party.

We may collect these types of personal information directly from you or from third parties.

How We Treat Personal Information That Is Also Sensitive Information

Sensitive information is a subset of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information, or biometric information.

The type of sensitive information we may collect about you includes:

As a patient: Your health information such as medication prescriptions, imaging, test results, the clinical letters provided by a doctor.

As a doctor or pharmacist: Information about your criminal history and working with children check.

We will not collect sensitive information about you without your consent, unless required or authorised by law.

Where you consent, your sensitive information may only be used and disclosed for the primary purpose for which it was collected and for reasonably expected purposes directly relating to the primary purpose for which the sensitive information was collected, such as:

• For using third parties to directly assist us in providing our Services (e.g., data hosting providers);
• As a patient, to allow the doctor or pharmacist to provide their services to you, including to hold your telehealth consult or fill your medication order (as applicable);
• As a patient and if required, to inform your general practitioner or allied health practitioner of the services provided by a doctor or pharmacist;
• As a doctor or pharmacist, to assess your application to join our introductory platform; and
• As a patient, for referring you to other medical or health service providers in circumstances where it is impractical for us to obtain your consent.

Sensitive information may also be used or disclosed if otherwise permitted, required, or authorised by law.

Collection and Use of Personal Information

We may collect, hold, use, and disclose personal information for the following purposes:

• To enable you to access and use our Services, and associated applications;
• As a patient, for the doctors and pharmacists to provide their services to you as a patient, including to hold your telehealth consult or fill your medication order (as applicable);
• If you have applied to be a doctor or pharmacist on our introductory platform, to consider your application;
• To contact and communicate with you about our Services;
• For internal record keeping, administrative, invoicing, and billing purposes;
• For analytics, market research, and business development, including to operate and improve our Services and associated applications;
• To offer additional benefits to you;
• For advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you; and
• To comply with our legal obligations and resolve any disputes that we may have.

Disclosure of Personal Information to Third Parties

We may disclose personal information to:

• As a patient, doctors and pharmacists as required for them to provide their services to you as a patient, including to hold your telehealth consult or fill your medication order (as applicable);
• Third-party service providers for the purpose of enabling them to provide their services to us, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors, and payment systems operators;
• As a doctor or pharmacist, patients as required to allow patients to use our Services and benefit from your services;
• Our employees, contractors, and/or related entities;
• Our existing or potential agents or business partners;
• Sponsors or promoters of any additional benefits we offer;
• Anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• Credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services provided to you;
• Courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights;
• Third parties to collect and process data, such as data analytics businesses. This may include parties that store data outside of Australia;
• Regulatory bodies, doctors, or allied health professionals if it is unreasonable or impracticable to obtain your consent and we reasonably believe that the disclosure is necessary to lessen or prevent a serious threat to the life, health, or safety of any individual, or to public health or safety; and
• Any other third parties as permitted by law, authorised by law, or required by law.

Disclosure overseas: We may disclose personal information overseas. The countries to which we send personal information for the purposes listed above may not have the same privacy laws as Australia. If we disclose your personal information to third parties in other countries, we will perform those disclosures in accordance with the requirements of applicable law.

Your Rights and Controlling Your Personal Information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us; however, if you do not, it may affect your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Anonymity: Where practicable, we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

Restrict and unsubscribe: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. You may also unsubscribe from our email database or opt-out of marketing communications by using the opt-out facilities provided in the communication.

Access: You may request details of the personal information that we hold about you. An administrative fee may be payable for the provision of such information.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Complaints: If you wish to make a complaint about how we have handled your personal information, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and aim to respond to you within 1 month of receipt of your complaint, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact the relevant authority.

Storage and Security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the personal information and protect it from misuse, interference, loss, and unauthorised access, modification, and disclosure. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot guarantee that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

If we become aware that unauthorised access, disclosure, or loss of your personal information has occurred, we will activate our data breach plan and use all reasonable steps to minimise any risk of serious harm. Where applicable, we will carry out notification of a data breach in accordance with our legal obligations.

Cookies and Web Beacons

We may use cookies on our online Services from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online Services with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our online Services.

We may use web beacons on our online Services from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

Links to Other Websites

Our Services may contain links to other websites. We do not have any control over those websites, and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

Contact Us

For any questions or notices, please contact our privacy officer at:

Email: support@chelem.health