Version 1, September 2019
Gertrude complies with the Australian state and commonwealth privacy laws including the Privacy Act 1988 (Cth) and the Australian Privacy Principles (collectively, "Privacy Laws").
Gertrude is committed to the privacy of its Visitors and potential Visitors (collectively, "Visitors") and to to operate at all times in a confidential and safe manner.
INFORMATION GERTRUDE COLLECTS AND HOLDS
Personal information is defined by the Privacy Laws as “information or an opinion about an identified individual, or an individual who is reasonably identifiable: (a) whether the information or opinion is true or not; and (b) whether the information or opinion is recorded in a material form or not.”
From time to time, Gertrude may collect certain of a Visitor's personal information. Gertrude only collects that personal information that is reasonably necessary for or related to Gertrude's business or to facilitate the use of the Website by Visitors.
Generally, the only personal information Gertrude collects about a Visitor is that information which a Visitor choose to disclose to Gertrude or which a Visitor authorises Gertrude to obtain.
Access to certain areas of website may require you to provide us with certain personally identifiable information. The type of information Gertrude collect may include a Visitor’s:
Sensitive information is a special category of the most sensitive personal information including racial or ethnic origin, political opinion, police record, health and disability information etc.
Gertrude does not collect sensitive information.
How Gertrude collects and holds personal information
Where possible, Gertrude will collect a Visitor's personal information directly from a Visitor, but information may also be collected via:
wi-fi routers; and
Personal and sensitive information may be collected from a Visitor when a Visitor provides it to Gertrude directly.
Gertrude has established appropriate physical, electronic and managerial procedures to safeguard any information Gertrude collects. This helps prevent unauthorised access, maintains data accuracy and ensures that the information is used correctly.
All data transferred to and from Gertrude's servers is encrypted and a firewall is in place to prevent intrusion. All data stored within Gertrude's systems is designed to only be able to be accessed by Gertrude's officers, employees, contractors and the relevant hosting facility.
The purposes for which Gertrude collects, holds, uses and discloses personal information.
Gertrude collects personal information that Gertrude considers relevant for the purpose of providing the Website. Gertrude will not use or disclose personal information collected about an individual for the purposes of direct marketing unless the individual has given Gertrude consent to do so. Gertrude will not disclose any personal information to any third-party overseas recipients unless the individual has given Gertrude consent to do so.
How Gertrude may use personal information
Some of the ways Gertrude uses personal information includes to:
communicate with a Visitor and others as part of Gertrude's business
enable Gertrude to provide a service
personalise a Visitor's website experience
send a Visitor information regarding changes to Gertrude's policies, other terms and conditions, on-line services and other administrative issues
manage accounts and perform other administrative and operational tasks (including risk management, systems development and testing, credit scoring and staff training, collecting debts and market or Visitor satisfaction research)
prevent, detect and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks
verify information given to Gertrude
carry out market research and analysis, including satisfaction surveys
provide marketing information to a Visitor (including information about other products and services offered by selected third party partners) in preferences a Visitor have expressed
manage Gertrude's infrastructure and business operations and comply with internal policies and procedures, including those relating to auditing accounting billing and collections IT systems data and website hosting business continuity and records, document and print management
resolve complaints and handle requests for data access or correction
comply with applicable laws and regulatory obligations (including laws outside a Visitor's country of residence), such as those relating to anti-money laundering, sanctions and anti-terrorism
comply with legal process and respond to requests from public and governmental authorities (in outside a Visitor's country of residence)
establish and defend legal rights protect Gertrude's operations or those of any of Gertrude's group companies or insurance business partners, Gertrude's rights or property and/or that of Gertrude's group companies, a Visitor or others and pursue available remedies or limit Gertrude's damages
To whom does Gertrude disclose a Visitor's personal information?
Gertrude may disclose a Visitor's personal information to:
government authorities (where required by law including workers compensation laws)
third parties involved in court action (where required by law)
other parties that provide support services to Gertrude including support services, merchant services, online marketing programs for the purposes of marketing Gertrude products only
potential business partners or purchasers
What happens if a Visitor doesn't provide personal or sensitive information?
If a Visitor does not provide some or all of the information requested, Gertrude may not be able to provide the services to such Visitor.
Using a pseudonym or engaging with Gertrude anonymously
Where practicable, a Visitor will be given the opportunity to engage with Gertrude on an anonymous basis or using a pseudonym.
Credit card details
Gertrude does not collect or store credit card numbers.
Website cookies and usage information
When a Visitor access Gertrude's website, Gertrude may use software embedded in Gertrude's website and Gertrude may place small data files (or cookies) on a Visitor's computer or other device to collect information about which pages a Visitor's view, how a Visitor reach those pages, what a Visitor does when a Visitor visits a page, the length of time a Visitor remains on the page and how Gertrude performs in providing content to a Visitor. A cookie does not identify individuals personally, but it does identify computers.
A Visitor can set a Visitor's browser to notify a Visitor when a Visitor receive a cookie and this will provide a Visitor with an opportunity to either accept or reject it in each instance. Gertrude may gather a Visitor's IP address as part of Gertrude's business activities and to assist with any operational difficulties or support issues. This information does not identify a Visitor personally.
The Gertrude website may contain links to other websites. When a Visitor accesses these links, Gertrude recommends that a Visitor read the website owner's privacy statement before disclosing a Visitor's personal information. Gertrude does not accept responsibility for inappropriate use, collection, storage or disclosure of a Visitor's personal information collected outside Gertrude's website.
Opting out of direct marketing communications
Where Gertrude uses a Visitor's personal information to send a Visitor marketing and promotional information by post, email or telephone, Gertrude will provide a Visitor with an opportunity to opt-out of receiving such information. By electing not to opt-out, Gertrude will assume Gertrude has a Visitor's implied consent to receive similar information and communications in the future. Gertrude will ensure that Gertrude's opt-out notices are clear, conspicuous and easy to activate. If a Visitor wish to opt out of communications from Gertrude, please use the contact details below.
Cross-border disclosures of a Visitor's personal information
Gertrude does currently use off-shore service providers with regard to storage of personal information data including email services, support service and telephonic services. Gertrude reserves the right to use data hosting facilities and third-party service providers both in Australia and overseas to assist Gertrude's operations.
Right to opt out of personal information use
Gertrude will comply with any request from a Visitor to process or cease using their personal information data as soon as practicable.
Unless a Visitor specifically opts-out of use of personal information for marketing purposes, Gertrude will assume Gertrude has a Visitor's implied consent to receive similar information and communications in the future.
Right to rectification
Gertrude has obligations to take reasonable steps to correct personal information held by Gertrude if Gertrude is satisfied that it is inaccurate, out-of-date, incomplete, irrelevant or misleading for the purpose for which it is held.
Gertrude will comply with any request from a Visitor to update and/or correct their personal information data within 28 days.
Gertrude may take reasonable steps to verify a Visitor's identity before making any such changes.
In cases where the information was provided by a third party, Gertrude may not be able to correct information and a Visitor may have to contact the third-party that gave information to Gertrude.
How to contact Gertrude regarding privacy
The Privacy Officer
GERTRUDE BIOMEDICIAL PTY LTD
c/- Acorn Consulting
Level 6, 12/20 Flinders Ln
Melbourne VIC 3000
Gertrude will take all complaints regarding privacy of information seriously. Gertrude will respond to any requests, questions, or complaints as soon as possible in a reasonable time frame.