Privacy Policy

Tegmen Project 1 Pty Ltd ACN 618 481 799 (Tegmen, we, our or us), the owner of the MCRI AllergyPal application (the App), recognises the importance of protecting the privacy and rights of individuals in relation to their personal information. This document is TEGMEN’s Privacy Policy and applies in respect of the information collected and used by both TEGMEN and our related bodies corporate. We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act). TEGMEN also complies with the Health Privacy Principles as set out in the Health Records Act 2001 (Vic) where applicable and as amended from time to time.

This Privacy Policy explains how TEGMEN collects, uses, stores and discloses personal information relating to individuals with whom TEGMEN interacts, including patients, research participants, donors, customers, medical professionals, consultants and contractors (referred to in this policy as you).

By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.

 

  1. Personal information and sensitive information

The expression "personal information" has the meaning given by the Privacy Act and includes information or an opinion about an individual that is reasonably identifiable. This may include your name, age, address, telephone number and email address. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered to be personal information.

Some personal information may also be “sensitive information.” Sensitive information has the meaning given by the Privacy Act and includes information or an opinion about your racial or ethnic origin, your political opinions, your membership of a political association, your religious beliefs/affiliations, your philosophical beliefs, whether you are a member of a trade or professional association or trade union, your sexual orientation/practices, your criminal record, health information, genetic information or biometric information. 

 

  1. What personal information does the App collect and hold?

We only collect personal information if it is reasonably necessary for one or more of our functions or activities. We may collect the following types of personal information:

  • name;
  • date of birth;
  • email address;
  • telephone number;
  • health and medical history or information (i.e. ASCIA Action Plan);
  • information about your dependents (as reasonably necessary);
  • any other information relevant to a TEGMEN research project you have agreed to participate in;
  • bank account or credit card details if you are making a donation or payment;
  • photographs of you or your dependents as part of your/your dependents identification in the App;
  • any additional information relating to you that you provide to us directly through the App or indirectly through your use of the App; or
  • any other personal information that may be required in order to facilitate your dealings with us.

Where the personal information is also sensitive information, we will only collect it with your prior consent.

We may receive personal information which we did not ask for (i.e. unsolicited information).  If this occurs, within a reasonable period of time we will determine whether we could have collected the information by seeking it from you.  If we determine that we could not have collected that information from you, we will destroy the information or de-identify it where it is otherwise lawful to do so.

We may also collect information from time to time that is not personal information because it does not identify you or any other individual. For example, we may collect anonymous answers to surveys or aggregated information about how people use the App and our services.

 

  1. How and when does TEGMEN collect personal information?

We collect your personal information directly from you unless it is unreasonable or impracticable to do so. If we collect your personal information from someone other than you, we will take reasonable steps to ensure that you are or have been made aware of what information has been collected, and the purpose of that collection. When collecting personal information from you, we may collect it in ways including:

  • when you or a medical professional enter personal details into the App, including when you register to use our App;
  • a copy of the relevant ASCIA Action Plan or similar document;
  • during conversations between you and our staff (which includes paid employees and volunteers);
  • when you complete documentation;
  • when you participate in research activities or other activities in relation to MCRI Allergy Pal.

Our website Privacy Policy is set out at www.mcri.edu.au/privacy-policy. That policy applies to your use of our website and details how your personal information may be used by us when provided through our website.

 

  1. For what purposes does TEGMEN collect, hold and use personal information?

We will only collect and/or use your personal information (including health information) to the extent that this is necessary for one or more of the following activities:

  • to enable you to access and use our App;
  • to provide services to you;
  • to operate, protect, improve and optimise our App, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
  • to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
  • to verify your identity, respond to your requests or as otherwise directed by you;
  • to provide you with news, information and material in relation to services of TEGMEN and our related bodies corporates if requested by you;
  • to undertake medical research as consented to by you in collaboration with MCRI;
  • to undertake general research or other reasonably related research activities for TEGMEN or our related body corporates, including surveys and polls and other reasonably related research activities;
  • for the administrative, employment, planning, service development, quality control and research purposes of TEGMEN; 
  • to update our records and keep your contact details up to date;
  • to process and respond to any complaint made by you;
  • to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority in Australia;
  • to send you marketing and promotional messages and other information to promote programs and activities of TEGMEN or our related bodies corporate, including fundraising, corporate philanthropy and education; and
  • otherwise as permitted by law.

 

  1. Do we use your personal information for direct marketing?

In relation to the use of your personal information to provide you with information about our programs, activities and fundraising and those of the MCRI, you may at any time request us not to provide you with any direct marketing and fundraising communications or publications. We will provide you with a simple means to opt-out of receiving such correspondence from us. You may elect to opt-out from receiving direct marketing and fundraising information at any time, by contacting us at the contact details below or, in the case of electronic correspondence, by selecting any unsubscribe option. Please note that you cannot opt-out of receiving contractual notifications such as changes to our terms and conditions for the supply of goods or services or other important information. In relation to sensitive information, we will not use or disclose this for the purpose of direct marketing unless you have expressly consented.

 

  1. What happens if you do not provide us with the personal information we request?

You have the right to not identify yourself, including the right to not provide us with your personal information.

If you do not provide us with the personal information described above, we may not be able to provide the requested services to you, either to the same standard or at all, and we may not be able to provide you with information about services that you may want, including information about related services.

 

  1. How does TEGMEN securely hold your personal information?

We will take reasonable steps to protect all personal information which we hold from misuse or loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified by us when it is no longer needed for the primary purposes (or any related secondary purposes) set out in this privacy policy.

All personal information will be held securely on Amazon Web Services (AWS) cloud infrastructure in accordance with global privacy and data protection best practises and the Privacy Act.

You should be aware when using the App that no data transmission over the Internet can be guaranteed as totally secure. Although we strive to protect such information, we do not warrant the security of any information that you transmit to us over the Internet (including through our website), and you do so at your own risk.

 

  1. Who does TEGMEN disclose your personal information to?

We may provide your personal information (including your health information), to:

  • our staff, which include our paid employees, volunteers and contractors;
  • our professional advisors;
  • our related bodies corporate, partners, affiliates, research collaborators, contractors and consultants who assist us in providing services to us and are required by us to protect your personal information;
  • any organisation or any authorised person with your express consent;
  • a person or organisation to whom we are compelled by law, or otherwise permitted by law, to provide your information; or
  • your organisation, if you are acting on behalf of an organisation.

If we refer you to a third party service provider, that service provider may also collect and store your personal information. We make no representation or warranties in relation to the privacy practices of any third party service provider and we are not responsible for their collection, use or disclosure of your personal information. Third party service providers are responsible for informing you about their own privacy practices.

 

  1. Does TEGMEN disclose personal information to anyone outside Australia?

We may be required, from time to time, to disclose your personal information to our international partners and research affiliates or collaborators located in New Zealand,    USA, Canada, EU (including, but not limited to, United Kingdom, France, Italy, Finland, Sweden, Netherlands, Cyprus), Japan, Singapore, Hong Kong, Indonesia, Vietnam, Fiji, Thailand, Qatar, Mongolia, Lao PDR, Papua New Guinea, Nigeria, The Gambia, Brazil, and Chile for the performance of the activities detailed in section 4 of this Privacy Policy.

When you provide us with your personal information, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian privacy law. Notwithstanding this, we will take reasonable steps to ensure that the overseas recipient observes confidentiality in a manner consistent with this Privacy Policy and requirements of the Privacy Act. To the extent that it is reasonable and practical for us to do so, we will use reasonable endeavours to de-identify any such personal information prior to overseas disclosure.

 

  1. How can you access and correct your personal information?

You may request access to any personal information we hold about you at any time by contacting the TEGMEN General Compliance Officer (see details in section 13 below). Where we hold information that you are entitled to access, we will take reasonable steps to provide you with suitable means of accessing it.

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

We will take reasonable steps to ensure that any personal information that we have collected is accurate, up-to-date and complete.  We also take reasonable steps to ensure that any personal information we use or disclose is accurate, up-to-date, complete, and relevant having regard to the purpose of the use or disclosure.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it by contacting the TEGMEN General Compliance Officer (see details in section 12 below). We will take reasonable steps to correct the information held. 

 

  1. What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, please contact the TEGMEN General Compliance Officer (see details in section 13 below) and provide details of the incident so that we can investigate it.

We may require any complaint to be made in writing first. We will then endeavour to respond to your complaint within 30 days. If we are unable to resolve your complaint to your satisfaction, a complaint can also be made to the Office of the Australian Information Commissioner.

 

  1. Changes to this Privacy Policy

We reserve the right to change, modify or update this Privacy Policy (or our website Privacy Policy), from time to time and without liability to you, on how we handle personal information or the types of personal information which we hold, by publication of the revised version. Any revision to our website Privacy Policy will be published on our website. The revised version shall take effect immediately upon publication.

  1. Contacting us about an enquiry or complaint

If you have an enquiry about this privacy policy, or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please contact the TEGMEN General Compliance Officer at:

 

Att: TEGMEN General Compliance Officer
Dept. Business Development and Legal
c/o Murdoch Children’s Research Institute
Royal Children's Hospital
50 Flemington Road
Parkville VIC  3052

 

Email: issues@mcriallergypal.com.au

 

We will treat your enquiry or complaint confidentially. One of our staff will contact you within a reasonable time after you have made contact with us to discuss your enquiry or complaint and outline options regarding how it may be dealt with. We will aim to ensure that any complaint is resolved in a timely and appropriate manner.