This Policy governs how ADA will deal with your personal information collected in connection with the Services.
This Policy also applies to personal information collected by ADA in connection with its website/s, social media accounts, software, the Teeth Platform and other technological means (Online Platforms), as well as in connection with any direct communication between you and ADA.
ADA uses third parties located both locally and overseas in addition to its own resources to provide these Services.
1. SCOPE OF THIS PRIVACY POLICY
1.1. We understand that when accessing our Services, the privacy and confidentiality
of personal information (as defined under the Privacy Act) (Personal Information)
is important to you. That’s why we fully respect your rights to privacy and are committed
to protecting the personal and financial details you provide us in line with this Privacy
Policy. This Privacy Policy applies to our Services and all individuals who use our
Services or whose Personal Information is processed by ADA.
1.2 We are committed to protecting the privacy of everyone who uses our Online Platforms
and/or our Services, for them to understand what Personal Information we collect and
store, and why we do so, how we receive and/or obtain that information, the rights an
individual has with respect to their Personal Information in our possession, and with
complying with the Australian Privacy Principles set out in the Privacy Act 1988
(Cth) (Privacy Act) and the General Data Protection Regulation (EU) 2016.679
(GDPR).
2. THE INFORMATION WE COLLECT
We may collect Personal Information that allows us to identify who an individual is and in order for us to provide the Services.
The information we may collect includes personal details such as an individual’s name and email address for the purposes of (including, but not limited to) distributing our ‘smile newsletter’ (Newsletter) and, if elected by you, your telephone number for the purpose of responding to any queries you raise through the Teeth Platform.
We may also collect statistical information such as behavioural and statistical information about an individual and businesses in connection with the Services and/or the Online Platforms.
Where the Online Platforms permit the purchase of goods or services, we may also collect:
2.1. Contact Information - such as residential, business and postal address and other information that allows us to contact the individual or otherwise allows us to deliver the Services;
2.2. Financial Information - such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our Services;
3. WHY WE COLLECT PERSONAL INFORMATION
3.1. We collect your Personal Information so that we can carry out the following actions:
3.1.1. to provide our Newsletter;
3.1.2. to respond to any queries you lodge via the Teeth Platform;
3.1.3. to provide our Services;
3.1.4. to enable you to use our Online Platforms;
3.1.5. to communicate with you, including about our Services and offers which
might interest you;
3.1.6. to provide you with information or advice;
3.1.7. to process payments by or to you in connection with our Services;
3.1.8. to create and update accounts, tax invoices or receipts;
3.1.9. to provide your personal information to third parties in order for them to
supply the Services to you;
3.1.10. to consider and respond to complaints made by you.
3.2. We may disclose additional purposes for collection of your Personal Information in collection statements at the point of collection.
4. HOW INFORMATION IS COLLECTED
4.1 Information is collected in association with your use of the Services but also
via (without limitation):
4.1.1. an enquiry lodged via the Teeth Platform;
4.1.2. you providing us with your contact details when signing up to our
Newsletter;
4.1.3. telephone calls;
4.1.4. social media messages, posts or feeds;
4.1.5. via the Online Platforms;
4.1.6. email correspondence; or
4.1.7. generally dealing with us directly or via our Online Platforms.
5. WHEN PERSONAL INFORMATION IS USED & DISCLOSED
5.1 We will not use any Personal Information other than for the purpose
for which it was collected other than with the individual’s permission.
5.2 We will retain Personal Information for the period necessary to fulfill
the purposes outlined in this Privacy Policy unless a longer retention
period is required or permitted by law.
5.3 Subject to clause 7, we will not sell an individual’s Personal Information
to unrelated third parties.
5.4. There are some circumstances in which we must disclose an individual’s
information:
5.4.1. where we reasonably believe that an individual may be engaged
in fraudulent, deceptive or unlawful activity that a governmental
authority should be made aware of;
5.4.2. as required by any law (including the Privacy Act and GDPR); and/or
5.4.3. in order to sell our organisation (in that we may need to transfer
Personal Information to a new owner).
6. OPTING “IN” OR “OUT”
6.1. By clicking “I Agree” or any other button indicating your acceptance of this
privacy policy, you expressly consent to the collection and use of your
Personal Information in accordance with this privacy policy.
6.2. An individual may opt to not have us collect their Personal Information
(for example by unsubscribing to any marketing emails received). This
may prevent us from offering them some or all of our services and
may terminate their access to some or all of the services they access
with or through us.
6.3. If an individual believes that they have received information from us that
they opted out of receiving, they should contact us on the contact details
set out in clause 14.
7. DE-IDENTIFIED INFORMATION
7.1. We may use your Personal Information in de-identified form (de-identification
being a process by which a collection of data or information is altered to
remove or obscure personal identifiers and personal information) to assist
us in providing you with the Services, Online Platform or otherwise for the
general operation of our organisation. We may also provide, including by way
of sale, de-identified information in aggregated form, to third parties. This
information may include (but is not limited to):
7.1.1. Such other data and/or information that is collected via the Platform
and/or Services and is not capable of identifying You.
7.1.2. Statistics or trends in connection with the Services.
7.2. When your Personal Information is included in de-identified, aggregated data,
it is not possible to identify you or anything about you from that data.
8. COOKIES
We may use temporary (session) cookies or permanent cookies when you access our Online Platforms and/or Services. This allows us to recognise your browser and track the web pages you have visited.
The use of cookies on our Online Platforms and/or Services are otherwise governed by our Cookie Policy.
9. THE SAFETY & SECURITY OF PERSONAL INFORMATION
9.1. We may hold your personal information in either electronic or hard copy form.
9.2. If you provide information to us electronically, we retain this information in our
computer systems and databases. If you provide information to us in hard copy
(paper) this information is normally retained in our files and a copy is made to
our electronic files.
9.3. We use industry standard security measures to safeguard and protect your
information.
9.4. We may disclose your personal information to third parties and service providers
located overseas in connection with any purpose, including to overseas cloud
computing hosts. We take reasonable steps to ensure that the overseas
recipients of your personal information do not breach the privacy obligations
relating to your personal information.
9.5. We are not responsible for the privacy or security practices of any third party
(including third parties that we are permitted to disclose an individual’s
Personal Information to in accordance with this policy or any applicable laws).
The collection and use of an individual’s information by such third parties may
be subject to separate privacy and security policies.
9.6. If an individual suspects any misuse or loss of, or unauthorised access to,
their Personal Information, they should let us know immediately.
9.7. Where we become aware of any breach to our security systems that breaches
or is likely to result in a breach of your rights or freedoms with respect to your
Personal Information, we will notify you and any supervisory authority as required.
9.8. We are not liable for any loss, damage or claim arising out of another person’s
use of the Personal Information where we were authorised to provide that person
with the Personal Information.
10. HOW TO ACCESS AND/OR UPDATE INFORMATION
10.1. If you would like us to update or amend your personal information, please contact
us on the contact details set out in clause 14 and we will make the requested
amendments.
10.2. We may ask you to verify your identity to ensure that personal information we
hold is not improperly accessed.
11. RIGHT TO BE FORGOTTEN
In the event that you decide that you no longer want us to hold your Personal Information, you may notify us in writing on the contact details set out in clause 14 of your desire for us to delete your Personal Information on record. We will use our best endeavours and comply with all legal requirements within a reasonable timeframe to delete your Personal Information, unless we are required by law to retain such information.
12. LINKS
Links from our Online Platforms or via our Services to third party services that we do not operate or control are provided for your convenience. We are not responsible for the privacy or security practices of services that are not covered by this Privacy Policy. Third party services should have their own privacy and security policies which we encourage you to read before supplying any personal information to them.
13. DIRECT MARKETING
13.1. We may contact you with direct marketing communications and information
about the Services or other products and services offered by us via telephone,
email or SMS.
13.2. If you have indicated a preference for a method of communication, we will
endeavour to use that method wherever practical to do so.
13.3. You may opt out of receiving marketing communications at any time by
responding via the channel in which you received the marketing communication,
or by contacting us on the contact details set out in clause 14. You can
unsubscribe from emails by clicking the unsubscribe link on the footer of
the email communication you have received.
14. COMPLAINTS AND DISPUTES
14.1. If an individual needs to contact us or has a complaint about our handling
of their Personal Information, they should address their communication in
writing to the details below:
14.2. Privacy Officer
Address: 14-16 Chandos Street, St Leonards NSW 2065
Email: contact@ada.org.au
14.3. If we have a dispute regarding an individual’s Personal Information, we
both must first attempt to resolve the issue directly between us.
14.4. If we become aware of any unauthorised access to an individual’s Personal
Information we will inform them and any supervisory authority as required,
at the earliest practical opportunity once we have established what was
accessed and how it was accessed.
15. GDPR
15.1. If you are:
15.1.1. A resident of the European Union accessing our Online Platforms or
receiving our Services in Australia; or
15.1.2. accessing our Online Platforms or receiving our Services from within
the European Union, then in addition to our obligations under the
Privacy Act, ADA is required to comply with the GDPR with respect
to your Personal Information.
15.2. Any reference to Personal Information in this Privacy Policy is also a
reference to Personal Data (as defined under the GDPR).
15.3. ADA takes the security and privacy of your Personal Information seriously
and has prepared this privacy policy and taken measures to collect, process
and hold all Personal Information in compliance with both the Privacy Act
and GDPR regardless of the user. Therefore, no additional terms for GDPR
users are required.
16. ADDITIONS TO THIS POLICY
If we decide to change this Privacy Policy, we will post the changes on our website. Please refer back to this Privacy Policy to review any amendments.
Version: 1.0
Date Reviewed
24 January 2022
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