In this Privacy Policy, ‘us‘ ‘we‘ or ‘our‘ means Waratah Independent Living Pty Ltd (ABN 12 621 879 409). 

We are committed to respecting your personal information. Our Privacy Policy sets outs out how we collect, use, store and disclose your personal information in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act).

By providing personal information to us, you acknowledge that you have read and understood this Privacy Policy and you consent to our collection, use, storage and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.

What is personal information?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

What personal information do we collect?

We may collect the following types of personal information:

• your name, date of birth, mailing or street address, email address, personal and work telephone number, and other contact details;
• your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
• your financial information and payment details;
• any information that you provide to us when making an enquiry through our website;
• any information that you provide to us when requesting an appointment in person, by telephone or via our website;
• details of the services we have provided to you or that you have enquired about, including any additional information necessary to deliver those services and respond to your enquiries;
• any information that you provide to us when requesting an appointment in person, by telephone, by email, or via our website;
• any additional information relating to you that you provide to us directly or indirectly in person, by telephone, by email, or via our website; and/or
• personal information which is sensitive information including: your racial or ethnic origin; religious beliefs or affiliations; philosophical beliefs; sexual orientation or practices; and health information including genetic information (including the health information contained in your plans prepared from time to time pursuant to the National Disability Insurance Scheme (NDIS)); and/or
• any other personal information that may be required in order to facilitate your dealings with us.

How do we collect your personal information?

We may collect these types of personal information directly from you when you:

• use our website;
• enquire about or receive services from us;
• communicate with us in person, by telephone, by correspondence (e.g. letters, email, facsimile via social media networking sites, online chat bots);
• share information with us from other social applications, services or websites; and/or
• interact with our website.

We may also receive your personal information indirectly from the following sources:

• your family members, guardians or other legally authorised representatives;
• our contracted service providers;
• your carer, attorney or guardian or other persons responsible for your healthcare decisions;
• the NDIS, and any other government agencies which administer subsidies and benefits relevant to our services;
• your NDIS support coordinator;
• your GP and other medical and healthcare professionals; and/or
• any person who makes an enquiry or referral through our website on your behalf.

If you provide us with a third party’s personal information, you must inform the third party about our Privacy Policy and that you are providing their personal information to us.

Why do we collect, hold, use and disclose personal information?

We may collect, hold, use and disclose your personal information for the following purposes:

• to provide supports and services to you;
• to send administrative messages, reminders, technical notices, updated, security alerts, and information about our supports and services;
• to provide appropriate information and opinions about your care needs and our supports and services to you;
• to operate, protect, improve and optimise our website, services, operations and user-experience – such as to perform research and analytics to identify alternative or additional accommodation, technologies, and other services and supports that we may wish to offer you and others;
• for advertising and marketing purposes;
• to send you marketing and promotional messages, and other information that may be of interest to you;
• to provide information to our professional advisors, contractors, service providers and other personnel for the purpose of us providing our services to you;
• to provide information to a hospital or aged care facility if you are referred for respite or higher levels of care;
• to provide information to a third party support provider in circumstances where you decide to engage a different organisation or NDIS provider unrelated to us;
• to provide information credit reporting agencies and courts, tribunals and regulatory authorities if you fail to pay for the services and supports we have provided;
• to provide information to courts, tribunals, regulatory authorities, and law enforcement officers as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
• to comply with our legal obligations (including under the National Disability Insurance Scheme Act 2013 (Cth) and its associated Rules);
• to resolve any disputes with or in relation to you; and/or
• to enforce our agreements with third parties.

We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.

When no longer required by us, unless required by law to retain it, we will take reasonable steps to destroy or de-identify your personal information securely.

Do we use your personal information for direct marketing?

We may send you direct marketing communications and information about us and our services. This may take the form of emails, SMS, mail or other forms of communication.  You may opt-out of receiving marketing communications and information from us by contacting us at [email protected] or by using the opt-out facilities provided (eg an unsubscribe link).

To whom do we disclose your personal information?

We may disclose personal information for the purposes described in this Privacy Policy to:

• your family members;
• your carer, guardian, legally authorised representative or other persons responsible for your healthcare decisions;
• your GP and other medical and healthcare professionals involved in your care;
• the NDIS and any other government agencies responsible for administering entitlements and benefits relevant to our services;
• your NDIS support coordinator;
• if you receive services and/or supports from third parties – those third parties to the extent reasonably required to coordinate service delivery or as otherwise required at law;
• if you transition to another service provider – that third party service provider to facilitate their provision of your services and supports;
• third party suppliers, including cloud-based storage solution service providers and other service providers, that we rely on to operate our website and otherwise provide services to our users;
• third party payment service providers that we rely on to process your payments to us;
• our employees, contractors, and other personnel;
• our professional advisers;
• our existing or potential agents, business partners or partners;
• our sponsors or promoters of any competition that we conduct via our services;
• anyone to whom our assets or business (or any part of them) are transferred;
• specific third parties authorised by you to receive information held by us – e.g. your GP and other medical and healthcare professionals; and/or
• other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

Using our website and cookies

We may collect personal information about you when you use and access our website.  While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website and/or mobile app usage and remember your preferences. Cookies are small files that store information on your computer, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies, but our website may not work as intended for you if you do so.

We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act.  We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.

We may also use Google Analytics, a service that enables the tracking of user analytics including but not limited to browser information, operating system information, pages viewed while browsing the website, website session times and referring website addresses, and enables us to help understand traffic and usage of our website and services. Information about you regarding your usage behaviour is held by Google and is subject to its privacy policy which can be viewed here. Information about privacy issues relating to Google Analytics can be found here. https://support.google.com/analytics/topic/2919631?hl=en&ref_topic=1008008

We may also use the Google Ads service to enable remarketing services, and Google UserID, demographic and interest reports. Information about you regarding your web usage behaviour is held by Google. Information from Google’s UserID service may be connected to other data that we hold about you.

We may also use Facebook pixels for conversion tracking and custom audiences, in accordance with Facebook’s terms which can be viewed here https://www.facebook.com/customaudiences/app/tos/?ref=u2u.

We may also use other third-party providers. You can opt out of a third-party vendor’s use of cookies, or the collection and use of information for ad targeting, by visiting the Network Advertising Initiative opt out page or AdChoices.

Security

We may hold your personal information in either electronic or hard copy form.  We take reasonable steps to protect your personal information from misuse, interference and accidental loss, as well as unauthorised access, use, destruction, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information.  In particular:

• data is stored on a secure cloud storage system, which is encrypted upon storage;
• emails are encrypted in transit using TLS;
• computer devices are protected by anti-malware software;
• access to our information systems is controlled through identity and access management, including password protection for clients and personnel;
• our information systems are configured to alert management when a user accesses sensitive information, as well as record the date and time of that access;
• personnel are required to comply with password protection policies designed to reduce the risk of a security breach;
• physical files are kept in locked filing cabinets; and
• we require website users to not take any action that would constitute a breach of the privacy rights of an individual in our Website Terms of Use available [here] link to terms of use.

However, we cannot guarantee the security of your personal information.

We may retain your personal information to fulfil the purposes outlined in this Privacy Policy for as long as needed, as allowed, or as required by law.

Links

Our website, and documents produced in the course of providing the services such as reports, may contain links to websites operated by third parties.  Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites.  The privacy policies and other terms that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

Accessing or correcting your personal information

You can access the personal information we hold about you by contacting us using the below contact information.  Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We reserve the right to charge a reasonable fee for searching for, and providing access to, your information on a per-request basis. We may also need to verify your identity when you request your personal information.

If you think that any of the personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the below contact information and we will take reasonable steps to ensure that it is corrected.

Changes to this Privacy Policy

We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

Making a complaint

If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us about your complaint using the below contact information.  Please include your name, email address and/or telephone number and clearly describe your complaint.  We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.  If you think that we have failed to resolve the complaint satisfactorily, please let us know and we will provide you with information about the further steps you can take.

Contact Us

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the following contact details:

By mail:
Gary Mosphilis
Privacy Officer
Waratah Independent Living Pty Ltd
PO Box 3847

Parramatta NSW 2124By

Email: [email protected].au

Current as at: 03/05/2021