Modified: July 2023
SCOPE:
- Device Technologies is committed to safeguarding your privacy and the confidentiality of your personal information.
- This Privacy Policy explains how we handle and protect personal information. It also explains the ways in which an individual can contact us to request access, to correct its personal information and complain about a breach of privacy.
- In this policy, Device Technologies means collectively Device Technologies Australia Pty Ltd, its associated entities, related bodies corporate and/or affiliates (including but not limited to its subsidiaries).
- Personal information is information that identifies you or could reasonably identify an individual, whether directly or indirectly, 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, health information, information regarding a person’s criminal record, mental health information and racial or ethnic origin.
- By providing personal or sensitive information to us or by using this website, you agree to the terms and conditions of this Privacy Policy.
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1. 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.
- Device Technologies will only collect personal information to the extent required to carry on its business, and only for the purposes set out in this Privacy Policy, unless notified to you at the time of collection. Device Technologies may collect personal information about you through our interactions with you and we will inform you about the purpose and use of the collected information.
- 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 (including photography/videography). Examples may be to investigate a product complaint, to support the use of medical devices or for training and education purposes.
- Device Technologies collects your personal information in a variety of ways. For example:
You may also choose to allow us to personalise your visits to our websites, in which case we will ask you for certain personal information to make your visits to our websites more helpful to you. When this information is combined with the non-personal information that we collect through cookies, we will be able to tell that you have visited our websites before.
- We may collect personal information from you when you contact us for information on the products and services that we provide, or when you lodge a product complaint.
- We may collect personal information about you in the course of engaging in commercial transactions with our customers, vendors, and other business contacts.
- Where discrete consent is provided, we may collect personal information from you as part of the development of training and education resources, including photography or videography.
- Personal information may be collected in the course of:
- Providing technical assistance to a patient or healthcare professional about the products and services that we provide.
- Responding to product or service queries.
- Sales calls or follow-up meetings with our sales representatives; or
- Using our websites, apps, product information or other services, including through use of cookies. Information about your computer hardware and software may be automatically collected by Device Technologies, including your IP address, browser type, domain names, and access times and referring website addresses. This information is used by Device Technologies for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Device Technologies website. See also the section titled 'USE OF COOKIES’.
- Device Technologies may also collect your personal information from third parties in relation to our dealings with you, such as credit reporting bodies or other similar entities. In the event that we receive your personal information unsolicited 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 or to an offshore entity.
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2. 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.
- 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:
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3. 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 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 this Privacy Policy and applicable local data protection and privacy laws.
- Device Technologies will not sell your personal information to any third party for any purpose.
- Device Technologies may transfer personal information across borders on the basis of a genuine business need, for example:
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4. USE OF COOKIES
- A cookie is a small text file that is placed on your computer’s hard disk by a Web page server. Cookies record information about your visit, including the type of browser and operating system you use, previous sites visited and your server’s IP address. Device Technologies’ websites use cookies to recall such information on subsequent visits. Device Technologies does not use cookies to record any of your personal information. If you do not wish to use a cookie, you can adjust your browser settings to reject cookies or notify you when they are being used.
- 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.
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5. STORAGE AND SECURITY OF PERSONAL INFORMATION
- Device Technologies commits to use reasonable physical, administrative, and technical safeguards to protect your personal information from loss, misuse, and unauthorised access, disclosure, alteration, or destruction. Access to the personal information is restricted to those employees and third-party service providers who need to use the data, who have been trained to handle such data properly and observe strict standards of confidentiality. Your personal information is also stored 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.
- 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.
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6. OPTING-OUT
- 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, if you have previously provided consent for Device Technologies to use your personal information (including images or video content), and you wish to revoke that consent, please contact our Privacy Officer using the details below in section 9.
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7. ACCESSING AND UPDATING YOUR PERSONAL INFORMATION
- Subject to some exceptions contained in the Privacy Act (or other relevant privacy legislation), 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.
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8. 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.
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9. 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:
Email: privacy@device.com.au
Address: The Privacy Officer
Device Technologies Australia Pty Ltd
1 Garigal Rd,
Belrose NSW 2085
- 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:
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10. UPDATES TO THIS PRIVACY POLICY
- Device Technologies may from time to time update this Privacy Policy. Device Technologies encourages you to periodically review this policy to be informed of how Device Technologies is protecting your information.