(Last Updated 14 June 2019)
CONTROLLED DOCUMENT DTP-106 Rev 3 Owner Privacy Officer
Device Technologies is committed to safeguarding your privacy and the confidentiality of your personal information.
In this policy, Device Technologies means Device Technologies Australia Pty Ltd, its associated entities, related bodies corporate.
Personal information is information that identifies you or could reasonably identify an individual, such as name, contact details and records of dealings with Device Technologies.
Sensitive information is a type of personal information which may include, amongst other things, information regarding a person’s criminal record, mental and health information and racial or ethnic origin.
2. COLLECTION OF PERSONAL INFORMATION
Device Technologies collects personal information that is reasonably necessary for or directly related to our functions and activities as a provider of medical devices. In some cases we are required by law to collect personal information in order to comply with our legal and regulatory obligations such as responding to safety concerns about our products.
The personal information we collect may include your name, address, date of birth, email address and phone number. At times where reasonably necessary for a legitimate business purpose, information collected may include sensitive information such as health and medical procedure information.
Device Technologies collects your personal information through our interaction with you in the course of providing a product or service or when you have other dealings with us. For example, your personal information will be collected when you communicate with us by telephone, email, online or when receiving technical and customer support.
Device Technologies may collect information about you from third parties such as credit reporting bodies or other similar entities. In the event that we receive your personal information from a third party, it is under the condition that the third party providing this data has obtained your consent to disclose your personal information to Device Technologies (either held directly by Device Technologies or by an offshore entity).
3. USE AND DISCLOSURE OF PERSONAL INFORMATION
Device Technologies will use your personal information for the purpose for which it is collected as outlined in this policy or otherwise disclosed to you at the time of collection, which generally includes the following purposes:
- For our everyday business operations and to interact and carry out transactions with you or your organisation;
- in the course of the sale, distribution or provision of medical devices;
- in the course of support service to those medical devices;
- to respond to your inquiries and requests providing you information regarding our products and services via email alerts, SMS or post;
- for the purposes of upcoming conferences and other scientific and educational programs;
- any required financial disclosure reporting;
- assessment of credit account applications;
- for business records keeping purposes as required by any applicable laws or internal business policies;
- for any employment related purposes;
- for internal business purposes such as improving our products and services offerings including and providing you with offerings about products and services that may be of interest to you including mobile computing applications;
- to provide you with access to online social media resources which we may offer from time to time;
- for compliance with regulatory requirements, such as maintaining a record of medical queries, complaints, adverse events and recalls relating to our products;
- any purpose to which you provided an express consent; and
- any purpose required and permitted by law.
Device Technologies may disclose your personal information to third parties (including overseas parties) to enable its provision of products and services, including:
- manufacturers of products supplied to you;
- professional advisers, including lawyers, insurers, financial institutions, accountants and auditors
- third party service providers such as website hosting and moderating, IT services, mobile application hosting, data analysis, e-mail and direct mail delivery services, payment and credit card processing, and other such services; and
- Government, regulatory and law enforcement authorities.
4. CROSS BORDER TRANSFER
Device Technologies may transfer personal information across borders on the basis of a genuine business need, for example:
- to our overseas suppliers and product manufacturers for product placement, complaint resolution and technical servicing requirements including where in the event a software requires repair or servicing and it is impossible to separate personal information from the software;
- to selected third parties to provide Device Technologies with support services such as database IT support, where from time to time such third parties may access your personal information to enable them to provide those services to Device Technologies; and
- Information to countries outside country of origin in the course of electronic data storage, transmission and management.
Device Technologies will ensure that the use and disclosure of personal information overseas is done in compliance with applicable local data protection and privacy laws.
Device Technologies will not sell your personal information to any third party for any purpose.
Device Technologies also uses pixel tags (which are similar to cookies) to monitor the open rate of our communications, they are used to determine whether certain promotional or commercial emails we send to you are opened. This helps us understand the effectiveness of communications we send.
6. STORAGE AND SECURITY OF PERSONAL INFORMATION
Device Technologies stores personal information in a combination of secure computer storage facilities, paper based facilities and other records including cloud storage. If you have registered on our website or have requested information via our websites, we store your personal information in databases and email servers.
We will endeavour to take all reasonable precautions to maintain the security of the information in our systems. Device Technologies uses a variety of security technologies and procedures to help protect your personal information from unauthorised access, use or disclosure. Device Technologies secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.
Unfortunately, no method of safeguarding information is 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting our Privacy Officer using the details below.
If you do not wish to continue receiving marketing communications from Device Technologies, please use the unsubscribe facility on the bottom of the company’s emails, or contact our Privacy Officer using the details below.
8. ACCESSING AND UPDATING YOUR PERSONAL INFORMATION
Subject to some exceptions contained in the Privacy Act, you may review, correct, update, or delete the personal information we hold about you by contacting our Privacy Officer using the details below. We will comply with your request as soon as reasonably practicable.
9. PRIVACY COMPLAINTS
If you wish to complain about our handling of your personal information, please contact our Privacy Officer using the details below.
We will investigate all complaints and respond to you as soon as practicable. If you believe your complaint has not been satisfactorily resolved, you may lodge a complaint with the Federal Privacy Commissioner in Australia, or the relevant local authority body. For more information on privacy, you can contact the Office of the Australian Information Commissioner’s (OAIC's) hotline service on 1300 363 992 or visit the OAIC's website at www.oaic.gov.au or your relevant local authority body.
10. CONTACT OUR PRIVACY OFFICER
If you have a privacy complaint or wish to review, correct, update, or delete the personal information that we hold about you, please contact our Privacy Officer using the following details:
Address: The Privacy Officer
Device Technologies Australia Pty Ltd
1 Garigal Rd,
Belrose NSW 2085