Privacy Policy
1. Introduction
(a)
The personal healthcare management mobile application (CDMpal App) and our website (www.cdmpal.com.au) is created, operated, and controlled by CDMPRO Pty Ltd (ACN 666 351 444) (we, our, or us).
(b)
The CDMpal App is a mobile software application that allows users to:
- Securely receive, view, store, track, and manage their health, medical, and pharmaceutical-related information and data;
- Share health, medical, and pharmaceutical-related information and data with their treating medical practitioner or healthcare professional by integrating with third-party software;
- Manage their treatment and medication using calendar reminders tools;
- Request allied health and medical specialist appointments;
- Record, store, and track fitness, activity, and wellbeing by integrating with fitness tracking devices and other wearable and non-wearable healthcare devices (collectively, the Services).
(c)
We are committed to ensuring your Personal Information is protected. We manage your Personal Information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).
(d)
By downloading, visiting, accessing, or using the CDMpal App and Services, you agree to this Privacy Policy.
(e)
This Privacy Policy outlines how we collect, store, process, use, and disclose your Personal Information, and how you may access your Personal Information kept by us or how you may make a privacy complaint.
(f)
For the purpose of this Privacy Policy, Account, CDMpal ID, Paired User, and Medical Provider have the meaning in the CDMpal App Terms and Conditions and User, you, or your means the individual who accesses or uses the CDMpal App and the Services, and whose details are listed in the Account.
2. The Information We Collect
2.1. Personal Information
(a)
Personal information has the same meaning that it has under the Privacy Act, namely, information means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and recorded in a material form or not.
(b)
Sensitive Information has the same meaning that it has under the Privacy Act, namely information or opinions about your health, political affiliations, sexual preferences, religious beliefs, racial or ethnic origin, criminal history, or other such private information. A reference to Personal Information in this Privacy Policy includes Sensitive Information except where otherwise indicated.
(c)
We collect and use Personal Information and Non-Personal Information from you and your Paired Users who upload, publish, and store information on, or via, the CDMpal App, and any other individual who interacts with us.
(d)
We will only collect and hold Personal Information about you that is reasonably necessary to undertake our business activities and functions, to make the CDMpal App and the Services and our other products and services available to you, or as otherwise permitted by law.
(e)
The type of Personal Information and Non-Personal Information that we collect and use depends on the type of dealings that you have with us.
2.2. User
We collect, store, and hold Personal Information about Users of the CDMpal App as well as information or data that does not contain Personal Information. For example, the type of Personal Information and Non-Personal Information that we collect includes:
- Contact details and account registration information (for example, your name, email address, phone number, date of birth, gender at birth, and location, username, and password);
- Health, medical, wellbeing, and pharmaceutical-related information and data (including, but not limited to, your medical history (such as your height, weight, blood pressure, fluid intake and output, temperature, blood oxygen saturation, allergies, dietary and nutritional information), notes of your symptoms or diagnosis, specialist reports and test results, specialist and healthcare professional referrals, medical certificates, information about healthcare services you have received or are scheduled to receive, healthcare plans, action plans, photographs, videos, prescriptions and other pharmaceutical purchases and usage, hospital admission and discharge letters, demographic information, power of attorneys and advanced care directives and any other health and medical records, or any other data or information that is or may be deemed to be Personal Information or Sensitive Information (collectively, User Data);
- Data and information relating to your dealings, or enquiries you have made, with us, including information about: (i) the Services you have ordered or used; (ii) the third-party products and services you have used or enquired about; and (iii) Paired Users that you have paired and connected with through the CDMpal App and otherwise interacted with on, or via, the CDMpal App (including User Data you have shared with Paired Users on, or via, the CDMpal App);
- Payment and billing information; and
- Other information that you provide to us or that we may collect in the course of our relationship with you.
2.3. Paired Users
We collect and hold Personal Information as well as information or data that does not contain Personal Information about Paired Users that access and use on, or via, the CDMpal App. For example, the type of Personal Information and Non-Personal Information that we collect includes:
- Information from other Users who you have paired with (such as the full name of the Paired User, the Paired User’s relationship to the User (for example, spouse, parent, sibling), age/date of birth and CDMpal ID);
- Information of Medical Providers (for example, the Medical Providers’ MGTcare ID number, name of the medical practitioners, address, type of medical or allied health services and phone number);
- Data and information relating to your dealings, or enquiries you have made, with us, including information about the Users that you have paired and connected with through the CDMpal App and otherwise interacted with on, or via, the CDMpal App (including User Data you have uploaded, published, downloaded, or shared with a User on, or via, the CDMpal App); and
- Other information that you provide to us or that we may collect in the course of our relationship with you.
2.4. Other Information
(a)
We may also collect some information that is not Personal Information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how you use the CDMpal App and Services and how you interact with Paired Users.
(b)
If you are a candidate seeking employment with us, we will use your Personal Information to process your application and assess your suitability for any role. We may retain your information for future reference.
3. How We Collect Personal Information
3.1. Direct Collection from You
(a)
We will collect Personal Information and Non-Personal Information about you in a number of different ways. We may collect Personal Information and Non-Personal Information directly from you or in the course of our dealings with you. For example, when you:
- Access and use the CDMpal App and Services (including when you open an Account or create or update your Account on, or via, the CDMpal App);
- Update, upload, download, publish, share, or submit User Data on, or via, the CDMpal App;
- Connect or pair with Paired Users through the CDMpal App, interact with or request User Data from your Paired Users;
- Visit the CDMpal App, our website, or submit information, questions, or queries through the CDMpal App or our website or complete any online forms or documents or when you enter or participate in surveys and questionnaires; and
- Otherwise contact, interact, or communicate with us (such as by telephone, email, or in person) with a query or request or lodge a complaint with us on, or via, the CDMpal App; and
- When otherwise legally authorized or required to do so.
(b)
By providing your Personal Information to us, you acknowledge that you are authorized to provide such information to us.
3.2. Collection from Third Parties
(a)
We may also collect Personal Information and Non-Personal Information about you from third parties, including:
- When Paired Users update, upload, publish, or submit User Data on, or via, the CDMpal App;
- When you provide your Personal Information to our Authorized Affiliates or other third parties;
- If you use third-party products or services that interact with the CDMpal App, Services, or our other products and/or services (for example, third-party payment processors, MGTcare software platform, medical recording devices such as smartwatches, smartphones, and medical instruments).
(b)
If you provide us with Personal Information about another individual (as their authorized representative), we rely on you to:
- Inform them that you are providing their Personal Information to us; and
- Advise them that they can contact us for further information.
(c)
You must take reasonable steps to ensure the individual is aware of, and consents to, the matters outlined in this Privacy Policy, including that their Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual's right to access that information, and who we are and how to contact us.
(d)
Upon our request, you must also assist us with any requests by the individual to access or update the Personal Information you have collected from them and provided to us.
3.3. Third Party Payment Processor
We use a third-party payment processor to process payments made to us. In connection with the processing of such payments, we do not collect, process, use, or store any Personal Information or payment information, including credit card numbers. All such information is provided directly to our third-party processor, [Processor Name], whose use of your Personal Information is governed by their privacy policy, available at [Processor Privacy Policy Link].
4. How We Use Personal Information
4.1. General Purposes
We collect, hold, use, and disclose your Personal Information for the following purposes:
- To enable you to access and use the CDMpal App and Services;
- To provide, operate, protect, improve, and optimize the CDMpal App and Services, 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 send you marketing and promotional messages and other information that may be of interest to you, including information about our products and services, and information about third parties’ products and services;
- To administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our partners;
- To comply with our legal obligations, resolve disputes, and enforce our agreements with third parties;
- To consider your employment application; and
- To otherwise enable you to access and use the CDMpal App and Services.
4.2. Direct Marketing
(a)
We and/or our Authorized Affiliates may send you direct marketing communications and information about our products and services and/or the products and services of third parties that we consider may be of interest to you. These communications may be sent in various forms, including by telephone, post, SMS, or email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth).
(b)
You consent to us and/or our Authorized Affiliates sending you those direct marketing communications by any of those methods. You may opt-out of receiving marketing communications from us by contacting us (using the contact details provided below) or by using the opt-out mechanisms provided in those communications.
(c)
We do not provide your Personal Information to other organizations for the purposes of their direct marketing unless expressly authorized by you.
5. Sharing and Disclosure of Personal Information
5.1. General
We may share your Personal Information and Non-Personal Information with third parties in the following circumstances:
- With your consent;
- To our Authorized Affiliates, employees, contractors, and/or third-party service providers (such as medical professionals, payment processors, IT service providers, and our delivery partners) that assist us in the provision of the CDMpal App and Services;
- To any law enforcement body, government agency, court, or regulatory body where we believe disclosure is necessary to comply with applicable laws, regulations, or codes;
- To our successors and/or assigns, including any organization that purchases our business or assets, or with whom we merge or transfer business to, in which case, the transferee will assume our obligations under this Privacy Policy;
- Where we consider it is necessary to protect our rights, property, or personal safety and that of our customers or the public;
- To any other organization or individual for any authorized purpose with your express consent; and
- As otherwise required or authorized by law.
5.2. International Transfer of Information
Your Personal Information may be transferred to, stored, or processed outside of Australia by our third-party service providers. These service providers may be located in the United States of America, Canada, the European Union, and other countries. We take reasonable steps to ensure that any third-party service providers to whom we disclose your Personal Information are bound by confidentiality and privacy obligations in relation to the protection of your Personal Information.
6. Security of Personal Information
6.1. General Security Measures
(a)
We take reasonable steps to ensure your Personal Information is protected from misuse, interference, loss, unauthorized access, modification, or disclosure. We use a variety of physical, electronic, and procedural safeguards to protect your Personal Information.
(b)
While we take reasonable precautions to protect your Personal Information, we cannot guarantee the absolute security of your Personal Information. You acknowledge that you provide your Personal Information at your own risk.
6.2. Third-Party Service Providers
(a)
We may engage third-party service providers to assist us in providing our services, including IT service providers and data storage providers. We require our service providers to comply with our privacy policies and any applicable laws relating to the protection of Personal Information.
(b)
While we take reasonable steps to ensure our service providers comply with these requirements, we cannot guarantee their absolute compliance. You acknowledge that your Personal Information may be subject to the privacy and data protection policies of these third-party service providers.
7. Access to Personal Information
7.1. General
You have the right to access your Personal Information held by us, subject to some exceptions allowed by law. You can request access to your Personal Information by contacting us using the contact details provided below.
7.2. Correction of Personal Information
(a)
If you believe that any Personal Information we hold about you is inaccurate, incomplete, or out of date, you may request that we correct the information. We will take reasonable steps to ensure that the Personal Information we hold about you is accurate, complete, and up to date.
(b)
If we refuse to correct your Personal Information, we will provide you with a written notice setting out the reasons for refusal and how you can complain about the refusal.
8. Complaints
8.1. Making a Complaint
If you have a complaint about how we collect, store, use, or disclose your Personal Information, please contact us using the contact details provided below. We will take reasonable steps to investigate your complaint and respond to you as soon as practicable.
8.2. Resolution of Complaints
If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner.
9. Changes to this Privacy Policy
(a)
We may update this Privacy Policy from time to time. Any changes to this Privacy Policy will be posted on our website and/or the CDMpal App. Your continued use of the CDMpal App and Services following any changes indicates your acceptance of the changes.
(b)
We encourage you to review this Privacy Policy periodically to stay informed about our collection, use, and disclosure of your Personal Information.
10. Contact Us
If you have any questions about this Privacy Policy, or if you wish to request access to or correction of your Personal Information, please contact us at admin@cdmpal.com.au
11. Changes to this Privacy Policy
(a) From time to time, it may be necessary for us to review and revise our Privacy Policy. We may notify you about changes to this Privacy Policy by posting an updated version on the CDMpal App.
(b) We encourage you to check the CDMpal App from time to time to ensure you are familiar with our latest Privacy Policy.
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