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Privacy Policy

Policy Statement

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Personalised Surgery Pty Ltd (ABN 629 866 628) ("the Company") values and respects the privacy of the people we deal with.

 

The Company is committed to protecting your privacy and complying with the Privacy Act 1988 (Cth) (Privacy Act) and other applicable privacy laws and regulations.

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This Privacy Policy (Policy) sets out how the Company will manage any Personal Information that is disclosed, collected or otherwise handled in connection with:

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For employees and job applicants, Personal Information may also be collected in accordance with Personalised Surgery Employee Privacy Policy.

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This Policy may change from time to time, and it is important that you review it regularly. Any change to this Policy will become effective when we publish the revised Policy on the Website.

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What is Personal Information

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Personal Information is defined in the Privacy Act 1988 (Cth) (Privacy Act) to mean information or opinion about an individual, or an individual who is reasonably identifiable (whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not).

 

What personal Information is collected and held

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The Company may collect and hold different kinds of Personal Information about you depending on the nature of your engagement with us. Such categories of Personal Information may include the following:

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  • Contact information includes your name, phone number, email address, date of birth and your address;

  • Transaction information includes details about payments to and from you, and other details of products and services you have purchased from and sold to the Company;

  • Payment information includes credit card information and billing addresses;

  • Technical information includes username and passwords, internet protocol (IP) address, your login data, browser type, time zone setting and location, third party access tokens and other technology on the devices you use to access the Website;

  • Usage information includes information about how you use the Website;

  • Marketing information includes your preferences in receiving marketing communications from the Company; and

  • any other Personal Information that you provide to us either directly or indirectly when using the Website, or when

  • interacting with our subsidiaries or other affiliated companies.

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What is sensitive information 

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Sensitive Information is defined in the Privacy Act to include Personal Information about your race or ethnic origin, political opinions or associations, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or union, sexual orientation or practices, or criminal record information. Sensitive Information also includes information about your health or genetic background and biometric information.

 

What sensitive information is collected and held

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Under certain circumstances, the Company may need to collect and hold sensitive information about you. This might include the following types of Sensitive Information and use such Sensitive Information for reasons directly relevant to the Company’s relationship with you:

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  • criminal record information;

  • health information; and

  • information in relation to your race or religion.

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If the Company collects your Sensitive Information, the Company will do so only with your consent, if it is necessary to prevent a serious and imminent threat to life or health, or as otherwise required or authorised by law, and the Company takes appropriate measures to protect the security of this information.

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You do not have to provide the Company with your Personal Information. Where possible, the Company will give you the option to interact with us anonymously or by using a pseudonym. However, if you choose to deal with us in this way or choose not to provide us with your personal information, we may not be able to provide you with our services or otherwise interact with you.

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How your personal information is collected 

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The Company will collect Personal Information directly from you wherever it is reasonable and practical to do so. The Company may also obtain Personal Information indirectly, for example, from:

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  • health care workers;

  • the Company’s subsidiaries and other affiliated companies;

  • referrals;

  • attending a Company event;

  • publicly available sources.

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The Company may collect Personal Information from you as a result of:

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  • your use and access of the Website;

  • your response to any surveys or marketing materials the Company sends out;

  • information uploaded to the Website by yourself or by other users;

  • apply for a position with the Company as an employee, contractor or volunteer; and

  • interactions between yourself, other users of the Website or any internal applications (if applicable), and the Company’s employees.

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The Company may also collect your Personal Information from third parties in addition to those referred to above, including:

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  • third parties who provide services to the Company;

  • other third parties who provide services through the Website;

  • via public sources.

 

How your personal information is held

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The Company generally holds Personal Information in electronic format, which is stored either within the Company’s own internal systems and applications or using third party data processors and data storage providers. 

 

The Company may otherwise hold your Personal Information in hard copy form which is stored in the Company’s offices.

 

Use of your personal information

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The Company uses Personal Information for many purposes in connection with our functions and activities, including the following purposes:

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  • to provide you with information or services that you request from us;

  • deliver to you a more personalised experience and service offering;

  • improve the quality of the services we offer;

  • internal administrative purposes;

  • marketing and research purposes;

  • to process and respond to a complaint or request you may make;

  • information we believe you might be interested in (however in doing so the Company will comply with all applicable laws regarding the provision of unsolicited messages); or

  • where it is necessary to meet our obligations at law, for example:

  • for conducting identity checks required by the anti-money laundering, anit-corruption and counter-terrorism financing laws; and

  • for the inclusion of information about your shareholding in our share register as required under the Corporations Act 2001 (Cth).

 

Disclosure of personal information 

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The Company may disclose your Personal Information to third parties in accordance with this Policy in circumstances where you would reasonably expect us to disclose your information. For example, we may disclose your Personal Information to third parties. These third parties may include:

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  • technology partners and service providers in connection with services that these parties perform for the Company;

  • the Company’s lawyers and accountants;

  • the Company’s sales agents, contractors or our subsidiaries and other affiliated companies (and their agents and others they rely on to provide their services);

  • medical service providers;

  • to law enforcement authorities where the Company is required to do so by law or pursuant to a legal process; or

to any entity in the event that we sell or transfer (or propose to sell or transfer) all, or a portion of our shares, business or assets. Should such a sale or transfer occur, the Company will use reasonable efforts to require that the transferee uses the Personal Information you have provided to us in a manner that is consistent with this Policy. 

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Some of the third-party service providers the Company may disclose Personal Information to may be based in or have servers located outside of Australia. Where we disclose your Personal Information to third parties overseas, the Company will take reasonable steps to ensure that data security and appropriate privacy practices are maintained. The Company will only disclose to overseas third parties if:

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  • you have given us your consent to disclose personal information to that third party; or

  • the Company reasonably believe that:

    • the overseas recipient is subject to a law or binding scheme; and

    • the law or binding scheme can be enforced; or

    • the disclosure is required or authorised by an Australian law or court / tribunal order.

The Company ensures there are appropriate privacy, data handling and security arrangements in place to protect your information.

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Direct marketing

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The Company may provide you with electronic marketing messages from time to time. You may opt out of receiving electronic messages from the Company at any time by contacting our Marketing Coordinator via the contact details at the bottom of this Policy or by using the opt out mechanism included in our electronic marketing messages.

 

Data security

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The Company will take reasonable steps to ensure that the Personal Information that we hold about you is kept confidential and secure, including by:

  • having a robust physical security of our premises and databases / records;

  • taking measures to restrict access to only personnel who need that personal information to effectively provide services to you;

  • having technological measures in place.

 

Access and correction of personal information 

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The Company takes reasonable steps to ensure that the Personal Information the Company handles is accurate, complete and up-to-date. If you become aware of any errors in your Personal Information or, if you change your Personal Information, please let the Company know.

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You can request access to any Personal Information we hold about you at any time. To request access to any Personal Information that we may hold about you, please contact the Company using the contact details at the bottom of this Policy.

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You may request us to amend any Personal Information the Company holds about you which you believe to be inaccurate, incomplete, or out of date. To request an amendment to any Personal Information that we hold about you, please contact the Company using the contact details at the bottom of this Policy.

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For more information regarding privacy, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

 

Information retention

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The Company will not keep your Personal Information for longer than it is required. In most cases, this means that the Company will only retain your Personal Information for the duration of your relationship with us unless we are required to retain your Personal Information to comply with applicable laws, for example record-keeping obligations.

For more information in relation to these requirements, please contact the OAIC via the website referenced above.

 

Cookies

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Our website may use ‘cookies’. Cookies can be used to collect Personal Information. A cookie is a small file that is stored on your device by a website. Cookies contain information which is readable by the website that issued the cookie to you and is commonly used to remember your details and preferences when you return to that website. If you set up your web browser to reject cookies, please be aware that your browsing experience and the Company’s website’s functionality may be affected.

 

Website analytics

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Our website uses an analytics service to help the Company better understand visitor traffic, so the Company can improve its services. Although this data is mostly anonymous (excluding sales orders or direct enquiries), it is possible that under certain circumstances, the Company may connect it to you.

 

Complaints

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The Company takes your privacy concerns seriously. If you have a complaint regarding our handling of your Personal Information or concerning our privacy practices, you may file a complaint using the contact details set out at the bottom of this Policy. The Company will confirm receipt of your complaint. If Management believes an investigation is necessary, the Company will open an investigation into your complaint. An employee from the Company may need to contact you to request further details of your complaint. If an investigation has been opened following a complaint made by you, the Company will contact you with the result of that complaint as soon as possible.

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In the unlikely circumstances that the Company is unable to resolve your complaint to your satisfaction, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

 

Contact us

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If you have any questions about this Policy, our privacy practices or if you would like to request access to, or correction of, any Personal Information we hold about you, please contact:

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Email: service@personalisedsurgery.com
Phone: +61 02 9437 9426
Address: Level 2, 500 Pacific Highway, St Leonards, NSW 2065

 

Policy version

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This Privacy Policy was last updated on 25 October 2023.

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