GGHEALTHTECH – PRIVACY POLICY
GGHealthtech Pty Ltd ABN 92 650 829 520 (we, us or our), understands that protecting your personal information is important. We provide a telehealth platform to enable healthcare providers to provide virtual consultations to patients, to allow patients to communicate virtually with their healthcare provider of choice, and facilitate administrative tasks like appointment scheduling and billing (Services). 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 when you access our Services either via our website or mobile application, or when we otherwise interact with you.
The personal information we collect
Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.
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 (including health information) as set out below;

•    your preferences and/or opinions;
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 healthcare provider (including a business contact for a healthcare provider or a healthcare professional or an administrative staff member using our Services to provide or administer healthcare services):

•    your name;

•    your contact details, including email address, mailing address and/or telephone number;

•    the organisation you work for;

•    images of you for your profile; and

•    details of services we have provided to you and/or that you have enquired about, and our response to you.

As a user of our Services:

•    information you provide to us, including through feedback, customer surveys or otherwise;

•    support requests submitted to us and our response to you;

•    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 and/or accounts from which you permit us to collect information.

•    any other personal information about your use of the Services requested by us and/or provided by you or a third party.

The sensitive information we collect
Sensitive information: is a sub-set of personal information that is given a higher level of protection. 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 types of sensitive information we may collect about patients include:

•  health information such as your Medicare number, information shared in a consultation including your
medical history, any health conditions, injuries or health concerns, your current health habits, your health
goals, and any imaging or test results; and

•  information you share or upload when booking an appointment or participating in a consultation, including information that may reveal your racial or ethnic origin, religion or sexual orientation or practices.

Unless otherwise permitted by law, we will not collect sensitive information about you without first obtaining your consent.
How we collect personal information
We collect personal information in a variety of ways, including:

•    Directly: We collect personal information which you directly provide to us, including when you register for
an account, through the ‘contact us’ form on our website or when you request our assistance via email, or
over the telephone.

•    Indirectly: We may collect personal information which you indirectly provide to us while interacting with us,
such as when you use our website, mobile application, in emails, over the telephone and in your online
enquiries.

•    From third parties: We collect personal information from third parties, such as where you are a dependent
and your parent or guardian uses our Services on your behalf, where you request that a healthcare provider
shares your personal information with another healthcare provider through our telehealth platform and
details of your use of our website from our cookie providers and marketing providers. See the “Cookies”
section below for more detail on the use of cookies.

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

•    to enable you to access and use our Services, including to setup your account and provide you with a login;

•    as a patient, to provide our Services to you, including for healthcare professionals to provide their services

•    to you, to book and manage your appointments, and to connect you to the right healthcare professionals
for your needs;

•    as a healthcare provider applying to be on our telehealth platform, to process your application;

•    as a healthcare provider, to provide healthcare services to your patients through our telehealth platform;

•    to enable you to access and use our associated applications;

•    to contact and communicate with you about our Services, including in response to any support requests you
lodge with us or other enquiries you make with us;

•    for internal record keeping, administrative, invoicing and billing purposes;

•    for analytics, market research and business development, including to operate and improve our Services,
associated applications;

•    for advertising and marketing, including to send you promotional information about our products and
services and other information that we consider may be of interest to you;

•    to comply with our legal obligations and resolve any disputes that we may have;

•    if you have applied for employment with us; to consider your employment application; and

•    if otherwise required or authorised by law.

•    Sensitive information: We only collect, hold, use and disclose sensitive information for the following purposes:
any purposes you consent to;

•    the primary purpose for which it is collected, such as:

  –     as a patient, to allow healthcare professionals on our telehealth platform to provide medical
         services to you;

  –     as a patient and if required, for your healthcare professional to disclose and discuss your condition
         and treatment plan to another healthcare professional via our telehealth platform;

  –     to refer you to other medical or health service providers in circumstances where it is impractical for
         us to obtain your consent; and

  –     to provide any other related Services;

•  secondary purposes that are directly related to the primary purpose for which it was collected, including
disclosure to the below listed third parties as reasonably necessary to provide our Services to you;

•  to contact emergency services, or to speak with your family, partner or support person where we
reasonably believe there is a serious risk to the life, health or safety of you or another person and it is
impracticable for us to obtain your consent; and

•  if otherwise required or authorised by law.

Our disclosures of personal information to third parties
We may disclose personal information to:

•  as a patient, for your nominated healthcare provider to provide their services to you;

•  third party service providers for the purpose of enabling them to provide their services, to us, including
(without limitation) data storage, web-hosting and server providers such as Amazon Web and Microsoft
Azure, professional advisors, insurance companies, organisations providing claims processing and payment
systems operators;

•  our employees, contractors and/or related entities;

•  our existing or potential agents or business partners;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have
provided to you;

•  courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in

•  connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and

•  any other third parties as required or permitted by law, such as where we receive a subpoena.

Overseas disclosure
While we store personal information in Australia, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of Australia.
Unless we seek and receive your consent to an overseas disclosure of your personal information, we will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Australian Privacy Principles and/or we will take such steps as are reasonable in the circumstances to require that overseas recipients protect your personal information in accordance with the Australian Privacy Principles.
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 our ability to provide our Services to you and 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: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the optout facilities provided in the communication.
Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.
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 promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner.
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 personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, 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.
Cookies
We may use cookies on our website 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 recognise you when you return to our online website and 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 website 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 website.
Links to other websites
Our website may contain links to other party’s 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.
Use of geo-localisation data
We collect your precise or approximate location via our mobile application for the following purposes:

•  to help you find healthcare providers and medical practices in your location area for the purposes of you
finding and booking an appointment or consultation with a local healthcare provider;

•  for security and safety;

•  to prevent and detect fraud; and

•  as permitted by law.

We collect this information when our mobile application is open (whether on-screen or not). If you do not want us to use your location for the purposes above, you should turn off the location services in your account settings in the mobile application or in your mobile phone settings. If you do not provide location information to us, we may not be able to provide our Services to you.
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.
For any questions or notices, please contact us at:
GGHealthtech Pty Ltd ABN 92 650 829 520

info@gghealthtech.com

Last update: 7th April 2022
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