Integrative Medicine Hub Pty Ltd (ACN 643 807 685) (IMH, we or us) is an Australian proprietary company registered at 427 South Road, Bentleigh, VIC 3204, Australia.
We are responsible for your personal data when You use the website owned or controlled by usat https://imh.education (Websites) or our smartphone application (IMH App) (the Websites).
We comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles that regulate the way personal information is collected, used, disclosed and managed by us. We are committed to protecting your privacy and by complying with these laws. Our aim is to always respect and uphold your rights to privacy protection.
You can obtain more information about the Australian Privacy Principles from the Office of the Australian Information Commissioner at https://www.oaic.gov.au
Our philosophy is one of trust, confidentiality and professionalism. We recognise the information we collect from you is of a sensitive nature. As part of our ongoing commitment to you we review and update our Websites in compliance with the privacy law and its regulations to ensure your personal information is fully protected.
1. What is personal information or data?
Personal information or data is generally information or opinion relating to an identified, or reasonably identifiable, individual. The type of information we collect from you or third parties can include:
- Identity Data such your first name, maiden name, last name, username, marital status, title, date of birth, gender and visual images.
- Contact Data can include your billing address, delivery address, email address and telephone numbers.
- Financial Data can include your bank account and payment card details.
- Transaction Data this can include details about payments between us and other details of purchases made by you, as well as details of services we have provided to you or that you have enquired about and our response.
- Technical Data can include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data can include your username and password, purchases or orders, your interests, preferences, feedback and survey responses, professional information as well as designation, registration status, endorsements and current employer and any additional personal information that you provide to us directly or indirectly through your use of our Websites, associated social media platforms or accounts from which you permit us to collect information.
- Usage Data can include information about how you use our website, products and services.
- Marketing and Communications Data can include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
2. What non-identifiable information do we collect?
The type of personally non-identifiable information and information obtained from third parties we collect can include:
- IP addresses
- cookie information
- log files
- domain names, and
- your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and browsing behaviour.
We collect this information to enable us to better serve your needs.
3. Collection of sensitive information or data
Some information we collect from you may be 'sensitive information' or 'sensitive data'. This could include information about your opinion, location, your membership of a professional or trade association or similar personally sensitive information about you.
We collect this information to enable us to better serve your needs to streamline our products we provide to you on our Websites.
We may use and disclose your sensitive information or data for the primary purpose for which it was collected, or for reasonably expected secondary purposes which are directly related to the primary purpose, or for purposes to which you have consented and in other circumstances authorised by the Privacy Act 1988 (Cth).
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to provide the product or service to you and may need to cancel a product or service you ordered. If this situation arises we will notify you at the time.
4. Use of personal information or data
As explained above, personal information is collected for a range of reasons on our Websites and generally arises where you register for an educational event, subscribe to and use our services or provide comments on content.
We only use your personal information or data when legally permitted. The most common uses of your personal information or data is:
- to contract between us and you for a service
- to comply with a legal or regulatory obligation
4.1 Processing your personal data
Generally, we do not rely on your consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message.
You always have the right to withdraw your consent to marketing material by emailing us at firstname.lastname@example.org or opt-out links on any marketing message.
4.2 Marketing communications
You will receive marketing communications from us if you have:
- requested information from us or purchased goods or services from us; or
- if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
If you opt out of receiving our marketing communications, this will not apply to personal data you provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
4.3 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify and explain to you the legal ground for changing the purpose.
You have the right to permit us or not to use your personal data in this new situation.
We may process your personal data without your consent where this is required or permitted by law.
5. Disclosure of your personal information
It is important that you know we do not sell or license your personal information to third parties.
However, we may disclose personal information to third parties without first obtaining your specific consent where disclosure is to:
- persons authorised by you in writing to receive information held by us or identified by us at the time the information is requested from you
- external service providers that provide services to us
- as part of any investigation into you or your activities where we reasonably believe that disclosure is necessary to the police, any relevant authority or enforcement body, or your internet service provider or network administrator
- to credit reporting agencies and courts, tribunals and regulatory authorities where you fail to pay for goods or services provided to you
- third parties to collect and process data such as Google Analytics or other relevant businesses. This may include parties that store data outside of Australia; and/or
Or is otherwise required or permitted by any law (including the Privacy Act 1988 (Cth).
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the Privacy Act 1988 (Cth) or relevant legislation of their country of residence.
If none of the above safeguards is available we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
6. IMH App
All information documented along with any attached files that relate to your personal use of the IMH App is private. This private information is not viewed for any purpose except to fix technological issues that may arise from time to time. In order to improve the functionality of the IMH App, big data (which refers to many people’s inputs into the IMH App) may be statistically analysed for patterns of use and behaviours.
Big data is always analysed in a de-identified format which ensures there is no breach of personal privacy.
We do not sell any part of your personal information for use by other service providers.
7. Third party service providers and links to other websites
We do not provide external advertising on our Websites.
Occasionally there are third party links contained on our Websites. We do not have any control over those third party websites. We are not responsible for or liable for the protection and privacy of any information which you provide to such third party suppliers or whilst visiting such websites.
Please be aware we engage third party providers such as Google and others to assist with our Website analytics (for instance, tracking and reporting traffic to the Websites, how users engage with the Websites etc) and storage of data via cloud storage.
8. How do we protect your personal information?
We take reasonable measures (physical, organisational, managerial and technological) to safeguard against unauthorised access of your personal information, to safely store your personal information and to protect your personal information from modification or disclosure.
Due to the nature of our service we may be required to store the details of your credit card. We endeavour to protect the security of your credit card information when processing your payments. We do this by using SSL encryption software.
We encourage all users and subscribers of our services to protect themselves against unauthorised access to their account and to keep their login details confidential.
For your part we recommend that you log out when you have finished using our Websites.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Log Files
When you visit the Websites we automatically log information about your computer, such as the IP address, browser type and access times.
We utilise this information to conduct site performance evaluations, to see where visitors are coming from and to keep track of how people use our Websites. This data helps us to determine what content our subscribers find most appealing so that we can maximise your enjoyment of our Websites.
Users who do not register or log in as subscribers may browse the Websites without providing any personally identifiable information. However, ‘users' non-personally identifiable information may nevertheless be tracked for the purposes of clause 2.
10. Cookies and Web Beacons
Cookies are small text files that are often created when you visit a website and which are stored in the cookie directory of your Internet-accessing device.
A cookie may be created when you visit us. We may use either or both permanent cookies and session cookies.
The permanent cookie stores a random number on your computer to help us count the number of times you return to our Websites. Permanent cookies do not expire when you leave our Websites and may be used on subsequent visits to the Websites.
The session cookie lets us know which pages within our Websites you visit. Session cookies expire when you leave our Websites or switch off your computer.
You can set your browser not to accept our cookies.
You should read the information that came with your browser software to see how you can turn off the automatic download feature, should you so wish.
Please be aware that depending on which cookies you block, our Websites may stop working or you may not be able to fully access all features or those features may not work correctly.
We may use web beacons on our Websites from time to time. Web beacons or clear.gifs are small pieces of code placed on a web page to monitor visitors' behaviour and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit the page or to deliver a cookie to the browser of a visitor viewing that page.
We may use Google Analytics and other third parties to collect and process data to assist us in better managing our business.
11. How can you control the collection, disclosure and use of your personal information and data?
Under certain circumstances you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the rights set out above please email us at email@example.com You will not have to pay a fee to access your personal data or to exercise any of the other rights.
If your request is without substance, repetitive or excessive then we are permitted to charge you a reasonable fee for the work we complete at your request. We will invoice you at the end of the process.
If access to your data is requested we will likely need to request specific information from you to help us confirm your identity to ensure your personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month, if your request is particularly complex, or, you have made a number of requests; we will notify you and keep you updated.
We may however refuse to comply with your request as permitted by the Privacy Act 1988 (Cth).
12. How can you make a complaint about IMH's collection, disclosure and use of your personal information?
We will promptly investigate your question or complaint and respond to you in writing setting out the outcome of our investigation, what steps we propose to take to remedy the breach (if any) and any other action we will take to deal with your question or complaint.
If you remain dissatisfied with our response you can contact the Office of the Australian Information Commissioner at https://www.oaic.gov.au/
13. How can you update and access your personal information?
Subject to some exceptions in the Privacy Act 1988 (Cth) you can access the personal information we hold about you.
Use of our products, services and Websites may require you to create an account.
If you make a mistake after creating your "IMH" account you may correct or update your personal information by clicking on the 'Log In (sign in)' link found on the Websites. The changes you make will be reflected in our databases instantly.
If you wish to deactivate your account or if you think we hold other information about you not accessible via logging in please contact us by emailing firstname.lastname@example.org
If you believe any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading please contact us by emailing email@example.com
We rely upon you as our Member to advise us when their personal information changes so please contact us by emailing firstname.lastname@example.org so we can update your details.
14. Choice and Consent
Providing us with your personal information is a decision only you can make.
If you choose not to provide us with your personal information you may not be able to utilise all aspects of our Websites or services.
15. Your provision of third party information
If you provide us with third party personal information then you warrant to us that you have the third party's consent to provide this information.
16. How does IMH communicate with you?
From time to time we may send you messages alerting you to products and services that are available from us, promotional materials, to remind you to provide feedback, to provide feedback to you.
You will also receive communication from us:
- if you contact us for a particular reason, or
- to receive your orders, or
- should we need to contact you for administrative purposes, such as winning a contest or participating in research which you have agreed to.
If you wish to opt-out of receiving our promotional emails please use the unsubscribe function located at the end of our emails or contact us by emailing email@example.com
17. When do we delete your personal information?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for which includes for the purposes of satisfying any legal, accounting, or reporting requirements and those requirement detailed in the Privacy Act 1988 (Cth).
To determine the appropriate retention period for personal data we consider the amount, the nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of that personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six (6) years after they cease being customers for tax purposes.
As outlined above some circumstances entitle you to request us to delete your data or if that isn’t possible we may be able anonymise your personal data or use the anonymised data for research or statistical purposes.
If you do not request us to delete your personal information, but we decide that we no longer require it and we are not legally required to retain it we will take all reasonable steps to destroy or permanently de-identify your personal information.
18. Your feedback is always welcome