Privacy Policy

1. About our Privacy Policy

We care about your privacy and digital safety and through ongoing review and updating our policy we aim to provide you with the highest standard of protection

We care about your privacy and digital safety and through ongoing review and updating our policy we aim to provide you with the highest standard of protection.

This Privacy Policy describes how Primary Health Care Technology Pty Ltd ACN 670 514 637 (“we”, “us”, “our”, “PHC Tech”) collects, uses, and shares personal data pertaining to the Our Care. Connected platform (“Platform”).

The Platform is a health communication platform and therefore requires the sharing of personal information in order to deliver its services. If you do not provide personal information, we are unable to provide this service.

We are committed to protecting your privacy, your personal information, and your digital safety when you interact with our products and services.

This Privacy Policy covers both patient or care recipient users (“Care Recipients”) and clinician, health administrator or care provider users (“Care Providers”), collectively termed “users”.

2. Accepting our Privacy Policy

By interacting with Our Care. Connected platform you are agreeing to the terms of this Privacy Policy

By interacting with the Our Care. Connected platform you are agreeing to the terms of this Privacy Policy.

By accessing, using and interacting with our Platform, you are declaring to us that you agree to the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you must not use the Services.

Your continued use of our Platform after we make changes to this Privacy Policy declares to us that mean that you agree to those changes.

3. The information we collect about you

We collect personal information you choose to share with us when you interact with our Platform. You can choose what information is shared. if you limit the sharing of your information, the quality of the service to you may be limited.

We collect personal information you choose to share with us when you interact with our Platform. You can choose what information is shared. If you limit the sharing of your information, the quality of the service to you may be limited.

We collect your personal information through the Platform’s Web App and Mobile App. The information that we collect can be divided into two categories.

1. Information collected to make an account on the platform, such as

• In the case of a Care Recipient user:
  • your name, date of birth, sex, gender identification, and contact details such as phone number, email, or address
• In the case of a Care Provider user:
  • your name, date of birth, sex, gender identification, and contact details such as phone number, email, or address
  • place of work, who you work with, and your specialisation
  • any information or opinions that you upload to the Platform that is about your Care Recipients

2. Information uploaded by a Care Recipient, or a Care Provider, to a Care Recipient account on the Platform. This might include

• name, date of birth, sex, gender identification, marital and family status,
• contact details such as phone number, email, or address
• place of work
• government-related identifiers such as your Medicare number
• your health information such as the health or community service you received, when it was received, who performed or verified the service was provided, the type of service, any associated tests and results, your past medical and community history

When you upload information to the Platform, you consent to our collecting and storing of that information.

4. How do we hold your personal information?

We employ multiple levels of security strategies to protect you and your personal information ensuring your data is encrypted, secured, and not visible to administrators or developers of the Platform.

It is important to us to secure your information, and, to protect you from shared deidentified information becoming reidentified when compared with external databases.

To protect your privacy and personal information we partner with security services, use secure servers, and engage only with trusted third-party providers.

In addition, if you are a Care Recipient, your personal information in the Platform (such as your name, date of birth, phone number, names of your significant others, and their contact details) is encrypted from viewing by Platform administrators, employees, and contractors. Your email address is visible as this is your username to access the platform; however, the data linked to the email address remains encrypted. This ensures that your personal information cannot be seen by those developing or administrating our Platform. Consequently, we are unable to identify you if you contact us about a specific profile.

While we take reasonable steps to secure and protect your personal information (including encrypting information that you upload to the Platform), we cannot guarantee absolute security of your personal information.

You acknowledge that by using our Platform, providing us with information, or allowing other users to provide us with information about you, this information is being collected at your own risk.

5. How we use your information

We collect information to enable you to use our services, enable us to improve our services to you, and enable us to support other health organisations to improve your health and wellbeing.

We collect, hold, and use your personal information in the following ways:

• To enable you to use the Platform and its features
• To continue to optimise and improve our Platform and its services to you
• To present you with products and services that may improve your health and wellbeing, or the health and wellbeing of Users with whom you are associated
• To measure the Platform’s performance
• To measure the Platform’s impact on health and wellbeing
• To communicate with you
• To comply with legal obligations and resolve disputes

As part of the services, we provide to you, if you are a Care Recipient, we deidentify your personal information (such as your name, date of birth, email address, phone number), and use that deidentified information to advise and support health organisations understand the demographics of the populations they service.

6. Do we use and share identifying personal information?

We do not share identifying personal information unless we are sharing to operate and develop our Platform, or we are required by law. You can choose how your information is shared with other Users on the Platform.

We do not share identifying personal information that we may have access to except in the following circumstances:

• you ask us to share the personal information with another Care Recipient User or Care Provider User
• it is reasonably necessary to share information about your account (but not the contents of your account) with contractors, or third-party service providers to the extent necessary to operate, develop, or secure our Platform
• we are required to under a court order, warrant, or to comply with applicable laws and regulations – this might include the information provided to open an account and the contents of a record.
• In exceptional circumstances and where permitted by law

We do not have the technical means to access identifying information that is uploaded to the Platform by Care Recipient Users or Care Provider Users about Care Recipient Users.

We allow and support you to share your personal information with other Users in accordance with the health communication function of our Platform. You can choose what information you share, how long you share it for, and when you no longer wish to share personal information.

We do collate deidentified personal information about Care Recipient Users to share with health organisations. However, this information is presented using data anonymising strategies to ensure your identity cannot be attained from the information. Therefore, this information when it is shared, is not considered to be personally identifiable information.

Information stored in the Platform is stored on Australian-based services. We aim to ensure all information remains stored and used within Australia. We are unlikely to disclose data overseas. If we disclose your information outside of Australia, we will comply with applicable privacy laws.

7. How does our privacy policy apply to children?

Children under the age of 16 are not permitted to use the Platform. Parents or guardians can create a profile for a child in their legal care.

Our Platform is not designed for use by people under the age of 16. Children may create an account on the platform if they are 16 or older.

A parent or guardian can create a profile for a child in their legal care if they desire to do so.

8. How can you change or delete your personal information?

You are in control of your personal information and can change or delete it as you desire.

You are in control of your personal information on the Platform, subject to the scope of the Platform’s functionality. When you delete or change your personal information, or allow another User to delete or change your personal information, it is changed or deleted everywhere on the Platform.

De-identified information may be retained on our servers for our future service development.

If you have trouble changing or deleting personal information from your account, please contact us at privacy@phc.technology and we will take all reasonable steps to support your requests.

9. How do we review and update our Privacy Policy?

This Privacy Policy will be reviewed and updated over time. If there is a material difference in terms from when you first accepted our privacy terms, we will ask you to agree to the new terms to continue using the Platform.

This Privacy Policy may be reviewed and updated over time as we continue to aim for the highest level of privacy and security we can reasonably provide. We maintain the right to change this Privacy Policy at any time and will endeavour to provide notification when our Privacy Policy changes.

If we decide to use personal information in a manner materially different from that stated at the time it was collected, we will notify you by email or via a prominent notice on our website, and where necessary we will seek your consent for the new privacy terms.

10. How can you ask questions or complain about our Privacy Policy?

If you have a question or a complaint about how we manage your personal information or would like to know more, you can contact us via email at privacy@phc.technology.

If you’ve made a complaint, we aim to acknowledge receipt of your complaint and action it as soon as possible.

You may have the right, depending on the jurisdiction, to make a further complaint to the relevant regulator, such as:

• The Australian Information Commissioner: https://www.oaic.gov.au/
• The Health Complaints Commissioner, in Victoria: https://hcc.vic.gov.au/
• The Information and Privacy Commissioner, in New South Wales: https://www.ipc.nsw.gov.au/
• The Human Rights Commission, in the Australian Capital Territory: https://www.hrc.act.gov.au/

In some cases, these regulators may expect you to have made a complaint to us first. Further information, including about any applicable time limits for making complaints, can be found on the relevant websites.