Privacy and the Information Handling Practices of Elevate Technologies PTY LTD

How we handle your personal information

Personal information is information or opinion that allows others to identify you. It includes your name, age, gender, contact details, as well as your health and financial information. We are Elevate Technologies Pty Ltd  ( ‘Elevate’). We will act to protect your personal information in accordance with the National Privacy Principles published under the federal Privacy Act.

Elevate is a registered proprietary limited company that provides an online health service to its customers among other services. We value your trust, and aim to help you manage your health. The protection of your personal information is a vital part of this relationship. It is extremely important to Elevate to keep your personal information confidential.

We collect personal information to provide you with the services you request from Elevate. The law also requires us to protect your health information.

Personal information, with the exception of your health records, may be used and disclosed within Elevate to administer our products and services and billing for our customers .and, unless you tell us otherwise, to provide you with related marketing information. We also use the information we hold to help detect and prevent illegal activity. We co-operate with police and other enforcement bodies as required or allowed by law.

We disclose relevant personal information to external organisations that help us provide services. These organisations are bound by confidentiality arrangements. They may include overseas organisations.

If the information we hold about you is inaccurate, incomplete, or outdated, please inform us so that we can correct it.

Background

Common law duty of confidentiality

Elevate is required to keep any information about customers in the strictest confidence. Elevate will only disclose information held about a customer if:

Privacy Act 1988

The federal Privacy Act Commonwealth Government has enacted privacy legislation to protects information held by all credit providers (not just banks) about their customers’ personal credit dealings. Since 1991, under Part IIIA of the Privacy Act, credit providers have only been allowed to disclose information about personal credit dealings to certain classes of persons (such as another bank or a credit union) for certain very limited purposes. The objective of Part 111A of the Act is to ensure that the use of credit information is restricted to assessing applications for credit lodged with credit providers and other activities involved with providing credit.

Privacy Amendment (Private Sector) Act 2000

Elevate acts to protect your personal information in accordance with the National Privacy Principles specified within this Act.

This document

The information in this document details how we comply with the requirements of the Federal Privacy Act and the National Privacy Principles (“NPP”) adopted under it in protecting the personal information we hold about you.

Collection of personal information

What is "personal information"?

Personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

Why we collect information

Personal information is collected so that we may:

You will be deemed to have acknowledged and agreed to your Personal information may also being used for:

What we collect

Personal information collected by Elevate generally comprises name, address, date of birth, gender, marital status, occupation, credit card details, contact details (including telephone, facsimile and e-mail) and health information. Sometimes we collect a few personal details unlikely to be known to other people to help us identify you over the telephone.

If you are creating accounts for other members of your family we will also collect the number and ages of such dependants. ,In addition, as required by Part IIIA of the Privacy Act 1988, we will obtain your consent to collect, use and disclose credit information about you.

We may be obliged to take steps to verify the information we collect; for example, a birth certificate provided as identification may be verified with records held by the Registry of Births, Deaths and Marriages to protect against impersonation.

We will not collect information about your political or religious beliefs, or ethnic background.

What if you provide incomplete or inaccurate information?

We may not be able to provide you with the products or services you are seeking.

Obtaining your consent

In most cases, before or at the time you of taking out a new product or service from Elevate (or, if that is not practicable, as soon as practicable thereafter) Elevate will obtain your consent to the purposes for which it intends to use and disclose your personal information.

If you do not give us consent, we may not be able to provide you with the products or services you want. This is because it is impracticable for us to treat some customers differently. because, for example, they don’t want their billing to be done by a third party provider.

Please refer to the "Other Disclosures" section for details of the confidentiality arrangements that apply when functions are outsourced by Elevate.

Withdrawing consent

Having provided consent, you are able to withdraw it at any time. To withdraw consent, please contact Elevate. Please note that withdrawing your consent may lead to Elevate no longer being able to provide you with the product or service you enjoy given that, as mentioned above, it is impracticable for us to treat some customers differently.

Information collected from someone else

In some cases, your personal information may be provided to us by family members or health and wellness professionals with your consent, express or implied. This information is directly added to your record. We will take reasonable steps to let you know that we have your personal information, unless it is obvious from the circumstances that you should know or would expect us to have the information, such as where a doctor adds a comment on your health record.

Other Disclosures

Who we may communicate with

Depending on the product or service you have, you should be aware we may exchange personal information with:

Outsourcing

We may need to disclose some personal information (for example, your contact information) when we outsource certain functions, including bulk mailing, online billing, market research and direct marketing.  You will be taken to authorize this. We also seek expert help from time to time to help us improve our systems, products and services.

In all circumstances where personal information may become known to our contractors, agents and outsourced service providers, there areconfidentiality arrangements in place. Under these arrangements contractors, agents and outsourced service providers are not able to use or disclose personal information for any purposes other than our own.

Elevate takes its obligations to protect customer information very seriously and we make every reasonable effort to deal only with parties who share and demonstrate the same attitude. In particular, health-information is not viewed by Elevate employees or third party providers  without your approval when buying Elevate’s service. There may be an exception in the case where you are experiencing problems with your service that require a technical person to trace your information in the system. In this case, we will inform you beforehand that Elevate's technical employees may view parts of your personal information.

Sending personal information overseas

We may send billing-related information overseas if we outsource billing functions using overseas agents or contractors, or to complete a particular transaction, such as an International Money Transfer. Your billing information may also be accessed by Elevate staff in other countries, if that becomes necessary for transactional reasons or to enhance our relationship with you.

Disclosure required by law

We may be required to disclose customer information by law e.g. under Court Orders or Statutory Notices pursuant to taxation or social security laws or under laws relating to sanctions, anti-money laundering or counter terrorism financing.

Disclosure as a result of your actions

There may be circumstances in which we consider you, by your actions, to have released us from our duty of confidentiality or to have consented to the disclosure of information about you without actually saying so (for example, if you discuss your medical record publicly to the media, in such a way as to leave us with little alternative but to respond publicly).

Personal information quality

We are committed to keeping secure the health information you provide to us. We take reasonable precautions to protect the personal health information we hold about you from misuse and loss and from unauthorised access, modification or disclosure.

Online Collection of information via web site activity

For statistical purposes we collect information on web site activity (such as the number of users who visit our web sites, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering one of our web sites from another web site, the address of that web site) through the use of "cookies". This information on its own does not identify an individual but it does provide Elevate  with statistics that can be used to analyse and improve their web sites.

Cookies

A ‘cookie’ is a packet of information that allows the server (the computer that houses the web site) to identify and interact more effectively with your computer. When you use one of our web sites, we send you a temporary cookie that gives you a unique identification number. A different identification number is sent each time you use one of our web sites. Cookies do not identify individual users, although they do identify a user’s browser type and theiryour Internet Service Provider (ISP).

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Please refer to your browser instructions or help screens to learn more about these functions. If you reject all cookies, you may not be able to use our web sites. To evaluate the effectiveness of our web site advertising, we may use third parties to collect statistical data. No personal data is collected on these occasions.

Links to other websites

Our web sites may contain links to external web sites. It is up to you whether you use a link. Whilst such links are provided for your convenience, you should be aware that the information handling practices of the linked web sites might not be the same as ours.

Telephone

We may monitor and record telephone calls for training and security purposes.

Marketing

Personal information is shared between Elevate employees. They may provide you with information on their our products and services which may be of interest to you.

Changes to our privacy and information handling practices

Elevate may make changes to its privacy and information handling practices from time to time for any reason. We will publish those changes on our web sites and, if there are important changes or a lot of minor changes, by updating this document which will be available to you through our website. This document is dated January 2009.

Access to personal information

You can request us to provide you with access to the personal information we hold about you subject to you satisfying our security checks to verify your true identity.

How to gain access

Requests for access to limited amounts of personal information, such as checking to see what address or telephone number we have recorded, can generally be handled in a branch or over the telephone subject to you identifying yourself.

With regards to your request for access to more substantial amounts of personal information, we will require you to complete and sign the attached "Request for Access to Personal Information under the National Privacy Principles" form, and either mail it to the Privacy Officer, Customer Relations, Elevate Technologies PTY LTD, 203-205 Blackburn rd, Mt Waverley VIC 3149, Australia. Tel:+61398476821, Fax: +61398476800. Following receipt of your request, our Customer Relations area will provide you with an estimate of the access charge and confirm that you want to proceed.

An access charge may apply

An access charge may apply, but not to the request itself. The charge is for the time we spend on locating, collating and explaining the information you request (generally based on a rate of $70 per hour or part thereof as adjusted from time to time) plus any photocopying costs and out of pocket expenses (such as freight and travelling costs).

Responding to an access request

We will respond to your access request as soon as possible. We will endeavour to comply with your request within 14 days of its receipt but, if that deadline cannot be met owing to exceptional circumstances, your request will be dealt with within 30 days. It will help us provide access if you can tell us what you are looking for. Your identity will be confirmed verified (including by verifying your signature) before access is provided.

Requests may be denied or limited

If particular circumstances apply, we are permitted by the legislation Privacy Act to deny your request for access, or limit the access we provide. We will let you know why your request is denied or limited. For example, we might give an explanation of a commercially-sensitive decision, rather than direct access to evaluative information connected with it.

Jointly held information

Where we hold your personal information in conjunction with that of another individual or individuals (eg where you jointly administer an account), we will allow each individual access to their own personal information and to the joint information (eg medical records).