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INTRODUCTION IMAGINE IF HEALTH PTY LTD (ACN 640 306 047) (trading as IMAGINE IF HEALTH) is committed to responsible privacy practices and to complying with the Privacy Principles contained in the Privacy Act 1988 (Cth) (“Privacy Act”) and applicable health records legislation such as the Health Records Act 2001 (Vic), the Health Records (Privacy and Access) Act 1997 (ACT) and the Health Records and Information Privacy Act 2002 (NSW). This Privacy Policy sets out our policies on the management of personal information and we have tried to make this policy user friendly and easy to understand. We may change our Privacy Policy from time to time at our discretion and in line with the latest privacy regulations. The latest version of our Privacy Policy is available from our website: www.imagineifhealth.com
COLLECTION OF PERSONAL INFORMATION
In accordance with the Privacy Act, “personal information” is information or an opinion about an individual who is reasonably identifiable. For the purposes of completeness, for Imagine if Health “personal information” includes “healthcare information” which means medical and medicine related information.
Imagine if Health may collect contact details including your name, occupation, address, email address, phone number and your date of birth. We may collect research questions and things of that nature should you opt in and agree to participate. Your agreement to collect and share such data will be provided at login but you can change these preferences at any time. If you purchase products or services from us, we may also collect certain transactional information and financial details to process the transaction.
If we are providing you with Medicines Access Services then we may collect health information including information relating to marketed and non-marketed prescription medicines used to treat patients as part of a patient access program. It is also possible that our platform may be used for adverse event reporting and it is possible that patient information will be captured on the system. In all cases, we will use and disclose that information only for the purpose for which you disclosed it to us and as permitted by the Privacy Act, applicable health records legislation and other relevant laws.
Our website may collect website usage information like cookies, IP address, your browsing history and the date and time of those requests and the country you are in.
In addition to the types of personal information identified above, Imagine if Health may collect personal information as otherwise permitted or required by law.
THE PURPOSE AND DISCLOSURE OF YOUR PERSONAL INFORMATION?
Imagine if Health collects your personal information only for the purposes of optimising the user experience on our platform. The most common ways we collect your personal information are:
• directly from you when you sign on to use the platform; • via our website or when you deal with us online;
• from publicly available sources;
• from third parties such as service providers administering medicines access programs.
You have no obligation to provide any personal information requested by us however, if you choose to withhold requested personal information, we may not be able to provide you with products and services that depend on the collection of that information. The purposes for which we use and disclose your personal information will depend on the circumstances in which we collect it. We may use or disclose your personal information:
• for the purposes for which we collected it;
• to respond to you if you have requested information (including via our websites or via an email or other correspondence you send to us);
• to provide goods or services to you, to assist a health professional or service provider to provide you with certain services (e.g. health services) or to receive goods or services from you;
• to administer and manage services, including charging, billing and collecting debts;
• to enable you to participate in any research or clinical studies that we or third party providers conduct;
• to improve our user experience via our products and services and keep you up to date on such improvements;
• to allow performance reporting and benchmarking of programs;
• to contact you (directly or through our service providers) to obtain your feedback, to find out your level of satisfaction with our products and services and for other market research activities;
• to verify your identity;
• to address any issues or complaints that we or you have regarding our relationship; and
• to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone, by fax or in any other lawful manner.
• for other purposes to which you have consented; and
• as otherwise authorised or required by law.
Unless otherwise required or permitted by law, we will only collect health information about you with your consent and we will only use that information for the primary purpose for which it was collected. In some circumstances, we may collect your health information through third parties (e.g. from healthcare professionals and pharmacists). We will only do this with consent or where otherwise permitted or required by law.
THIRD PARTY DISCLOSURE OF PERSONAL INFORMATION
We may disclose your personal information to third parties in connection our core function of providing a Medicines Access Service or, for functionality to which you have agreed (e.g. research studies or experience surveys).
This may include disclosing your personal information to the following types of third parties:
• health service providers or treating health professionals (such as a doctor, pharmacist or hospital), in connection with providing medicines access program services or as otherwise required or authorised by law;
• our accountants, insurers, lawyers, auditors and other professional advisers;
• government and regulatory authorities, courts, tribunals and other bodies as required or authorised by law;
• our contractors and other third parties that provide goods and services to us (including suppliers, marketing agencies, data analytic services, billing and debt recovery providers, website and data hosting providers and other IT suppliers);
• carefully selected third parties with whom we have data sharing arrangements (e.g. Professional Services Groups, Patient Advocacy Groups, and Healthcare Regulators);
• third parties that require the information for law enforcement or to prevent a serious threat to public safety; and
• otherwise as permitted or required by law.
Where we disclose your personal information to third parties we will use reasonable effort to ensure that such third parties only use your personal information as reasonably required for the purpose we disclosed it to them and in a manner consistent with the Privacy Principles under the Privacy Act and relevant health records legislation, e.g. by (where commercially practical) including suitable privacy and confidentiality clauses in our agreement with a third party service provider to which we disclose your personal information.
PROTECTION OF PERSONAL INFORMATION
Imagine if Health has data security and encryption measures in place and places supreme importance of the security of personal information. Please notify us immediately if you become aware of any breach of security and we will do so in kind if we become aware of any data breach.
However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.
ACCURACY OF PERSONAL INFORMATION WE HOLD
We rely on the accuracy of personal information as provided to us directly (from you) and indirectly (e.g. from your doctor) and will from time to time perform audits to ensure information is as complete and correct as possible. Our system is built with inherent logic checks to attempt to improve data accuracy and we also may check and confirm through a phone call whether information provided is accurate.
You may contact us if the personal information we hold about you is incorrect or to notify us of a change in your personal information. Our contact details are set out in this Privacy Policy.
QUERIES, COMMENTS AND COMPLAINTS ABOUT OUR HANDLING OF PERSONAL INFORMATION
If you have any questions, comments or complaints about our collection, use or disclosure of personal information, or if you believe that we have not complied with this Privacy Policy, the Privacy Act or applicable health records legislation, please contact on the contact details are set out in this Privacy Policy.
Imagine if Health will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner.
HOW CAN YOU CONTACT US?
Please address all privacy complaints and requests to update or access information to:
Attention: Privacy Officer
Imagine if Health
66 Suffolk Avenue Collaroy
NSW 2097
OR
Any requests to access, update or correct your health information should be made in writing
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