In this Privacy Policy, a reference to “Insitu”, “we”, “our” or “us” is a reference to Insitu Clinical Support Pty Ltd ACN 620 595 753.

We recognise the importance of your privacy and understand your concerns regarding the security of the personal information which you provide to us.

In the course of providing our services to you or interacting with you, the collection of personal information in some instances is necessary or unavoidable. We are committed to protecting the privacy of all personal information that we collect and ensuring that your personal information is stored and handled correctly.

All personal information collected by us will be treated in accordance with the Australian Privacy Principles (“APPs”) as contained in the Privacy Act1988 (Cth) (“Privacy Act”). The APPs detail how personal information may be collected, used, disclosed, stored and destroyed, and how an individual may gain access to or make complaints about the personal information held about them.

This Privacy Policy details the type of personal information we may collect from you when you use our website, smartphone app, and any other affiliated platform that we may introduce from time to time (“our Platform”). This Privacy Policy also details how we store and process personal information about you, and with whom we may share it. We also describe the measures we take to safeguard your personal information and tell you how to contact us regarding our privacy practices, including how you may access the personal information about you that is held by us and seek the correction of such information, and how you may complain about a breach of the APPs and how we will deal with such a complaint.

While our Platform may contain links to websites owned by third parties, those websites are not subject to our privacy standards, policies and procedures. We recommend that you make your own enquires as to the privacy policies of these third parties and we are in no way responsible for the privacy practices of these third parties.

By submitting your personal information to us or by using our Platform, you understand, consent to, and authorise us collecting, using and disclosing your personal information in accordance with this Privacy Policy.

1. Types of personal information we collect and hold

“Personal information” is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or not. Information where we have removed any reference to a person, so that the person cannot be reasonably identifiable from the information, is not personal information.

“Sensitive information”, a sub-set of personal information, is information or an opinion about an individual’s racial or ethnic origin, political opinions, political association membership, religious beliefs or affiliations, philosophical beliefs, professional or trade association membership, trade union membership, sexual orientation or practices, or criminal record, and includes health information and genetic information.

Information collected directly from you

We collect personal information from users of the website (Task Hosts or Task Completers). The kinds of personal information that we may collect from you and hold include:

• contact information, such as your name, postal address, email address and telephone number;
• account information such as your username and password;
• if you are a Task Host, healthcare tasks or services needed, and bank account or credit card information to facilitate payment processing;
• if you are a Task Completer, work experience, professional registration numbers, education, professional references, professional skills and qualifications, schedule availability, and bank account details to facilitate payment processing; and
• any other personal information submitted by you to us.

We will only collect sensitive information from you if you consent to the collection of such information and such information is reasonably necessary for one or more of our functions or activities.

Information we collect automatically

We may automatically collect information from you and your devices when you use our Platform. This may include your IP address, the type of browser and device or operating system you use to access our Platform, the date and time of your visit, language preferences, pages visited, information downloaded and other identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to our Platform.

We may also use third party web analytics services on our Platform, such as Google Analytics. These service providers help us analyse how users use our Platform.

Information we collect from other sources

We may collect personal information about you from third parties that assist us in providing you access to and the use of our Platform, such as service providers who assist with identifying you or companies that offer their products and/or services on our Platform.

Other users may provide us personal information about you through our Platform. Examples include when a user posts feedback regarding another user.

2. How we collect personal information

We collect certain personal information directly from you. For example, you provide us with personal information about yourself when you:

• create an account with us as a Task Host or a Task Completer;
• make an enquiry or request a service;
• submit documents, information or other material to us or on our Platform; and
• provide other information to us through other communications between us and you.

We also collect other information about your online activities and your use of our Platform automatically, usually from the use of cookies and web beacons.

We may also collect information about you from other sources, such as third parties who provide services to us, and other users who provide feedback about you.

If we receive personal information that we have not requested (unsolicited information) then we will destroy or de-identify the information if it is lawful and reasonable to do so.

3. Purposes for which we collect, hold, use and disclose personal information

We collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us to carry out our business functions and activities and as necessary to provide to you access to and the use of our Platform. We also collect, hold, use and disclose your personal information for related purposes that you would reasonably expect, such as our administrative and accounting functions.

For example, we may use the information obtained from you to:

• process the creation of your account as a Task Host or a Task Completer;
• manage your account on our Platform;
• connect Task Hosts with Task Completers through our Platform;
• run a background check or qualification check on you;
• respond to and communicate with you about your requests, questions and comments;
• send newsletters, surveys, offers and other materials to you which are relevant to our services;
• facilitate the collection and distribution of payments between Task Hosts and Task Completers;
• protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
• comply with and enforce applicable legal requirements, relevant industry standards and our policies.

If we do not collect, hold, use or disclose your personal information, or if you do not consent to us doing so, then we may not be able to answer your enquiry, complete the transaction you have entered into, or provide to you access to and the use of our Platform.

In addition, we may use information collected online through the use of cookies and web beacons and other automated means. This information is used to:

• recognise your device when you use our Platform;
• manage our Platform;
• offer and provide products, services and information to you;
• help us to make decisions about maintaining and improving our Platform;
• analyse your use of our Platform;
• personalise our Platform, including targeted advertisements that may be of particular interest to you;
• help diagnose technical and service problems;
• identify users of our Platform; and
• gather demographic information about our users.

4. Cookies and web beacons

We may use technologies like cookies and web beacons to recognise you when you to visit or use our Platform and to provide, improve, protect and promote our products and services.

A "cookie" is a small text file which is placed on your computer or device by our webpage servers when you access our Platform. The purpose of a cookie is to help analyse web traffic and to allow our Platform to respond to you when you return to our Platform. Cookies are also used to enhance the secure use of our Platform.

Cookies are frequently used and in themselves do not identify the user, just the computer used.

When you browse our Platform, we may record geographical tagging, cookies and statistical data. We use cookies because they help us recognise your device when you use our Platform, manage and improve our Platform, analyse your use of our Platform, help diagnose technical and service problems and gather demographic information about our users.

You can choose if and how a cookie will be accepted by configuring your preferences and options in your browser. However, if you decide not to display cookies, you may not experience optimum performance of our Platform.

We also may use “web beacons” on our Platform. A web beacon, also known as a pixel tag or clear GIF, may be used to transmit information collected through cookies to our service providers’ servers, such as the server of Google AdWords. These web beacons enable our service providers to compile anonymous information about your browsing activity.

5. Ad networks[delete if not applicable]

You may see certain advertisements on other websites based on your visits to our Platform because we participate in advertising networks administered by third party vendors, such as Google Ads. Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests and browsing context. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs and web beacons. The networks use this information to show you advertisements that are tailored to your individual interests, to track your browser across multiple websites, and to build a profile of your web browsing. The information our ad network vendors collect includes information about your visits to websites that participate in the vendors’ advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Platform and on third party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.

We may use features of Google Analytics for display advertisers. That includes obtaining specific visitor cookie data, such as the source, medium and keywords used to visit our Platform.

To learn more about how to opt out of ad network interest-based advertising, please contact us using our contact details referred to in this Privacy Policy.

6. Marketing

We may use your information to offer you products and services that we think may be of interest to you, unless you have opted out of marketing communications.

Where required by applicable law, we will obtain your consent before sending you any marketing communications. You may withdraw your consent to the use of your data for marketing purposes at any time by contacting us by using our contact details referred to in this Privacy Policy.

We will not provide your information to third parties for marketing purposes without your consent.

7. Basis for processing information

If European data protection laws apply, our lawful basis for collecting and using the information described in this Privacy Policy will depend on the information concerned and the specific context in which we collect or use it.

We normally collect or use information from you where we have your consent to do so, where we need the information to perform a contract with you, to provide our products or services to you upon your request, or where the processing is in our legitimate interests and not overridden by your data protection interests or rights and freedoms.

For example, when we:

• use information to effect a transaction you have requested, we need it in order to provide you with the product or services you are acquiring;
• use names and email addresses for email marketing purposes, we do so with your consent (which you can revoke at any time); and
• gather usage data and analyse it to improve our Platform and services, we do so based on our legitimate interest in safeguarding and improving our Platform and services.
  1. Disclosure of personal information

Information shared with third parties

We will only disclose personal information to third parties if it is necessary for the primary purpose of collecting the information, such as to other users of the Platform to facilitate the connection between Task Hosts and Task Completers, or for a related secondary purpose that could be reasonably expected, such as to insurance providers or other third parties for the purpose of arranging insurance on your behalf.

We may also share your personal information with:

• companies that are related to us through common ownership; and
• contractors or third parties that assist us in providing our services.

Where we wish to use or disclose your personal information for other purposes, we will obtain your prior consent. Otherwise, we will only disclose your personal information to third parties without your consent if the disclosure is:

• necessary to protect or enforce our legal rights or interests or to defend any claims;
• necessary to prevent or lessen a serious threat to a person’s health or safety;
• required or authorised by law; or
• permitted by another exception in the applicable privacy laws.

We will not sell your personal information without your consent.

Third party analytics

We may use third party web analytics services on our Platform, such as Google Analytics. These service providers help us analyse how users use our Platform. The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. These service providers may retain and use anonymised, aggregated data collected from users of our Platform in connection with their own businesses, including in order to improve their products and services.

To learn more about opting out of data collection through analytics services such as Google Analytics, please contact us using our contact details referred to in this Privacy Policy.

Company reorganisation

In the event that we undergo reorganisation or are sold to a third party, any personal information we hold about you may be transferred to that re-organised entity or third party in compliance with applicable law.

8. Security of personal information

We respect the privacy of your personal information and will take such steps as are reasonable in the circumstances to protect such information from misuse, interference and loss, and from unauthorised access, modification or disclosure.

Your personal information may be held and stored on paper, by electronic means or both. We have physical, electronic and procedural safeguards in place for personal information and will take reasonable steps to ensure that your personal information is protected from misuse, interference, loss and unauthorised access, modification and disclosure.

The steps we take to protect your personal information may, if applicable, include the following: 

• data held and stored on paper is stored in lockable offices and in secure premises;
• data held and stored electronically is protected by internal and external firewalls, limited access via file passwords, and files designated read-only or no access;
• when transferring information to others, we ensure that appropriate and suitable safeguards and data protection measures are in place to protect your personal information;
• where we disclose personal information to third parties, our contractual arrangements with them include specific privacy requirements;
• only authorised personnel will have access to personal information; and
• our staff receive training on privacy procedures.

Overseas recipients

Personal information that we hold may be transferred to our affiliates or service providers in select other Countries. By using our Platform you consent to such disclosure. We will only disclose your information to such locations if permitted by law.

If your personal information is disclosed to another country we will ensure that any disclosure is in accordance with the relevant laws, and that appropriate safeguards are put in place.

9. Retention of personal information

We will only retain your personal information for as long as is reasonably necessary in relation to the purposes for which it was collected. We will also retain personal information to ensure compliance with any applicable statutory or regulatory obligations imposed on us in relation to the retention of records.

Where you have requested we stop processing your personal information for marketing purposes, we may retain a record of your request to ensure we abide by your request in the future.

10. Destruction and de-identification of personal information

When your information is no longer needed, or if you request that we delete any personal information which we hold about you, we will use secure methods to destroy or to permanently de-identify your personal information when it is no longer needed. For example, paper records are shredded or destroyed securely and any electronic records are deleted from all locations, to the best of our ability, or permanently de-identified.

11. Children

Our Platform is not directed at children under the age of 16. We do not knowingly collect personal information from children under 16.

If it comes to our knowledge that we have collected personal information of a child under 16 years old, we will take steps to delete such information as soon as possible.

12. Requests for access to personal information

You have the right of request access to personal information we hold about you. If you believe that we hold personal information relating to you and you wish to obtain access to this information, please contact us using our contact details referred to in this Privacy Policy.

If you make a request to us to access personal information about you that is held by us, we will review our records to determine the personal information relating to you which we hold. We will endeavour to respond to your request within a reasonable period after the request is made, and give access to the information in the manner requested by you, if it is reasonable and practicable to do so.

We may withhold access to some of the personal information which we hold in circumstances where we consider that:

• providing access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety;
• providing access would have an unreasonable impact upon the privacy of other individuals;
• the request for access is frivolous or vexatious;
• the information relates to existing or anticipated legal proceedings between us and you, and the information would not be accessible by the process of discovery in those proceedings;
• providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations;
• providing access would be unlawful or the denying of access is required or authorised by or under law or a court/tribunal order;
• we have reason to suspect that unlawful activity, or misconduct of a serious nature, that relates our functions or activities has been, is being or may be engaged in, and providing access would be likely to prejudice the taking of appropriate action in relation to the matter;
• providing access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
• providing access would reveal evaluative information generated within us in connection with a commercially sensitive decision-making process.

We will not charge you for the making of the request. However, we may charge you for the reasonable costs incurred by us in providing you with access to the personal information held by us.

If we refuse to give access to the personal information because of one of the above reasons, or to give access in the manner requested by you, we will give you a written notice setting out the reasons for the refusal (except to the extent that it would be unreasonable to do) and the mechanisms available to complain about the refusal.

13. Correction of personal information

To assist us to keep our records up-to-date, please notify us of any changes to your personal information as soon as possible following the change.

If we hold personal information about you, and either we are satisfied that the information held is inaccurate, out-of-date, incomplete, irrelevant or misleading, or you request us to correct the information, we will take such steps as are reasonable in the circumstances to correct that information to ensure that the information is accurate, up-to-date, complete, relevant and not misleading (having regard to the purpose for which it is held).

If we correct personal information about you that we previously disclosed to another entity that is required to comply with Australian privacy laws, and you request us to notify that other entity of the correction, then we will must take such steps as are reasonable in the circumstances to give that notification unless it is impracticable or unlawful to do so.

If we refuse to correct the personal information as requested by you, we will give you a written notice setting out the reasons for the refusal (except to the extent that it would be unreasonable to do) and the mechanisms available to complain about the refusal.

14. Complaints

If you have any complaints about our dealings with your personal information including any breaches by us of any APPs, you may submit that complaint by contacting us using our contact details referred to in this Privacy Policy.

Any complaints received by us will be referred for prompt investigation by our compliance team and a written response will be provided to you within a reasonable time (usually no longer than 30 days). We may seek further information from you in order to provide you with a full and complete response.

15. Data breaches

In the event that:

• we become aware that there are reasonable grounds to believe that there has been an unauthorised access to, unauthorised disclosure of, or loss of, personal information about you held by us, and the access, disclosure or loss is likely to result in serious harm to you; and
• we have not been able to prevent the likely risk of serious harm with remedial action,

we will notify both you and the Australian Information Commissioner of the data breach as soon as practicable.

16. Amendments to this Privacy Policy

This Privacy Policy is subject to occasional revision from time to time. Please check our Platform regularly for any updates and amendments

If we make any material changes in the way we use your personal information, we will notify you by posting a notice of the changes on our Platform.

Any changes to this Privacy Policy will be effective upon the earlier of 30 days after posting a notice of the changes on our Platform. The changes will be effective immediately for new users.

Your use or continued use of our Platform following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by such changes.

17. Contact

If you have any questions about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us using the following details:

Email: lesley@insituclinical.com

Telephone: +61 (0) 407 55 22 44

Post: Director, InSitu Clinical Support Pty Ltd

If you make request to us to provide a copy of this Privacy Policy in a particular form, we will take such steps as are reasonable in the circumstances to give you a copy in that form.

This Privacy Policy was last updated on 01 February 2019.

Please be sure to read our Terms and Conditions