Last Revised: 1st October 2018
This website and its content is owned by Kim Campbell, trading as Red Clover Health (ABN: 36265351807).
The trust, confidence and protection of our Client, Users and Visitors’ privacy is paramount. Which is why we have put together this Privacy Statement is to set out how we collect, use, process, protect and distribute your information. If, at any time, an individual provides Personal Information or other information about someone other than himself or herself, or on behalf of an organisation to which he, or she have been authorised to represent, the individual warrants that they have that person’s consent to provide such information for the purpose specified. If a minor is accessing our Website, it is presumed that they have gained a parental or guardian’s consent.
We may make changes to this Privacy Statement. Therefore please refer back to this page to review any amendments. We will also do things to addition to what is statement under this statement to comply with the Australian Privacy Principles.
INFORMATION WE COLLECT
When visiting our website, or engaging us, or purchase from us, we collect Personal Data. Without limitation, the type of information we may collect is:
(a) Personal Information. We may collect personal details such as an individual’s name, age,
gender, location, job title, residential address, and other information defined as “Personal Information” in
the Privacy Act;
(b) Sensitive information. Through our client intake form and in person consultations, we may collective
sensitive information about an individual’s mental health, disability, previous health and/or medical
conditions, lifestyle routines, religion or political affiliations, hobbies, racial or ethnic Origins.
(c) Contact Information. We may collect further information such as an individual’s telephone number,
email address, and delivery and billing address.
(d) Statistical Information. We may collect information about an individual’s online and offline
preferences, habits, IP address, device ID, geolocation, device type, movements, trends, decisions,
purchases and other information for statistical purposes.
HOW INFORMATION IS COLLECTED
From information you provide to us
Information will be collected when a user subscribes to our Newsletter, when a client or potential client completes our consultation form or when an individual contacts or engages us about our services and/or products.
During consultation, you will be asked to complete a medical intake form for the purposes of communication and ensuring the safety of any herbal prescriptions and/or nutritional advice we give. Updates on the progress will be recorded on each visit.
From information we collect automatically
We can collect non-personal information about an individual such as their computer, network, browser and/or their IP address.
From information available in the public
We may also receive Personal Information from sources such as advertising, public records, and mailing lists from trusted third parties. Where we obtain Personal Information without an individual’s knowledge (such as by accidental acquisition from a client) we will either delete/destroy the information, or inform the individual that we hold such information, in accordance with the Australian Privacy Principles.
WHEN PERSONAL INFORMATION IS USED AND/OR DISCLOSED
Owing to the nature of our services to you, where we are required to conduct assessment and treatment, we are required to collect and use personal data from you. Although it is not mandatory for you to provide this to us, you understand that the omission of relevant personal data may affect the outcomes of your treatment. Therefore, to ensure we to achieve an effective outcome, it is important that the personal information you provide to us is comprehensive, true, and accurate.
Your Personal Data will also be used in the below circumstances:
- To verify your identity
- To communicate with you about a product, or service
- To obtain feedback about a particular product or service
- For our own marketing and promotions to clients
- To investigate complaints made by an individual, or where we have reasonable suspicions that an individual is in breach of our terms
- As required to, or permitted by law
- In personalising our experiences on our website, communicate and/or services to clients
- To analyse, aggregate and report analytical reports which may be shared publicly or with third parties; and
- To send our users/clients important notices, such as changes to our terms, conditions, policies or service offerings.
There are some circumstances in which we must disclose an individual’s information:
- Where we have reasonable belief that an individual is engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of
- As required to, or permitted by law
- For bookkeeping or accounting purposes.
- To our employees, contractors, officers, or subcontractors insofar as reasonably necessary for the purposes as set out in the policy.
Your personal information may also be disclosed in circumstances on a “strict to know” basis, whereby professional discussions with other health practitioners are required in order to articulate the best course of action of your health concern (with no identifying information to be shared without your consent).
HOW YOUR DATA CAN BE SHARED
Your Personal Data may be shared to third parties such as service providers who assists us with the functionary of our website or Google Analytics. We will not sell, trade, or provide any personally identifiable information to outside parties.
You acknowledge that in some circumstances (from interests of public health laws or in the case of a person who have notifiable communicable diseases or a conditions that must be recorded), such information may be shared with a third party such as the client’s GP or specialist healthcare practitioner. In these cases, the client will be expressly informed.
It may be shared with an actual buyer or potential buyer (or its advisors) in connection to a proposed purchase or acquisition of any part of our business.
THE SAFETY AND SECURITY OF PERSONAL INFORMATION
As health professionals, we agree to take all reasonable precautions to protect an individual’s Personal Information from unauthorised access. Representatives and staff of Red Clover Health will be made aware of confidentiality requirements and we will use third party technology that provide a secure environment and access control for confidential information.
For in person consultations, we ensure your personal data is stored in a locked filing cabinet, or a password protected computer. Our staff who may be exposed to your personal data will be required to sign a confidentiality agreement. For online consultations, these will be stored via our online system: Acuity Scheduling. You acknowledge that the security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. Each individual that provides information to us via the internet or by post does so at their own risk.
We cannot accept responsibility for misuse or loss of, or unauthorised access to, Personal Information where the security of information is not within our control.
You will entitled to view, opt-out, unsubscribe or delete any personal information that Red Clover Health holds about you. A copy of the personal information we have collected from you can be provided and we are able to also request for your information to be restricted or deleted or destroyed. To exercise these rights at anytime, please email us at firstname.lastname@example.org and we will respond to you within 30 days.
Your Personal Data will be stored and processed by us in Australia. However, you acknowledge that while we make all reasonable efforts to protect your Personal Data, data shared with a third-party data processor will be processed and stored in accordance to their local policies, compliance, and regulatory laws.
If you are accessing our website from the European Union (“EU”), or other regions of the world with laws governing data collection and use that may differ from the law of the Australia, you will be transferring your personal information outside of those regions to Australia for storage and processing. By providing any information, including personal information about you, you consent to such transfer, storage, and processing.
COMPLAINTS AND DISPUTES
If you would like to make a complaint about our handling of your Personal Information, or believe we have breached the APP or a relevant registered APP code (if any), please get in touch with us via email to Red Clover Health at email@example.com
Where we become aware of any unauthorised access to an individual’s Personal Information we will inform you at the earliest practical opportunity once we have established what was accessed and how it was accessed.
Information related to minors are collected from parents and guardians with children in their care. Such sensitive information may also be collected from children themselves who are under the age of 18 in the presence of their parents/guardian’s, or with their parent/guardian’s full consent. We agree to exercise all “reasonable efforts” to further verify that the person providing the consent is indeed a parental figure.
RETENTION OF YOUR PERSONAL DATA
For as long as we have a relationship with you, we will be retaining your Personal Data, up to a period of time afterwards. Following this period, we will delete and destroy your personal data.