Privacy Policy – KnowDiabetes

1. About

Know Diabetes Pty Ltd ACN 12 635 816 205 (‘hereinafter referred to we, us, our and KnowDiabetes) values transparency and privacy. We are committed to protecting the personal information that we collect, store and use when you access our Website and/or Services (‘Personal Information’). Personal Information is information about an individual whose identity is apparent or can reasonably be ascertained from that information.
www.knowdiabetes.com.au, www.pharmacydiabetes.com.au & www.clinicdiabetes.com.au (the ‘Website’) are digital platforms/ marketplace (‘Services’) through which Health Care Providers (‘HCP’) such as dieticians, credentialled diabetes educators, pharmacists and psychologists offer and provide personalised services including product selection/training, coaching and health education face to face or via phone and web-based tools (‘HCP services’) to people impacted by chronic ailments or their carers (‘Customer/s’).
This Privacy Policy describes how your personal information is managed, collected, used and shared when you visit or use our Website and Services.
We may update this Privacy policy from time to time to reflect changes in how we handle Personal Information and to reflect any changes to the privacy laws. Updates to this Privacy Policy will be effective upon posting to the Website.
By using our Website, you consent to the collection, processing, and management of Personal Information as set out in this Privacy Policy.

2. Acceptance

We manage your Personal information in accordance with the requirements of the australian privacy principles ( ‘APPs’ ) in the Privacy Act 1988 (Cth) which govern how organisations collect, hold, use and disclose personal information. We also adhere to the privacy Amendment (Notifiable Information Breaches) Act 2017 (‘NDB’ ) and other applicable australian and state and territory privacy information.
To obtain access to our services, you must register for a member account through our website ( ‘Member Account’) and subscribe to our services.
By registering for a member account, you will be required to accept our Terms and privacy policy by clicking the “register” button in the user interface as a condition of joining as a member ( ‘Member’ ). By clicking the “ register ” button you agree to all the terms and conditions of our Terms and Privacy Policy listed on this Website which gives notice to you through our user interface as follows:
By registering, you agree that you’ve read, understood and accepted our website Terms and conditions and you expressly consent to our privacy policy
By accessing the platform and entering your details via ‘contact us’, or by subscribing to our mailing list or registering a healthcare professional or customer account or profile, you consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.

3. Types of personal information we collect

We receive and store Personal information you provide to us through the supply of our services, through your use of our website, when we answer your queries or when you submit Personal Information to us online when you use our platform.
Personal information about visitors to our Website is collected only when it is knowingly and voluntarily submitted with your consent. For example, we may need to collect this information to provide you with our services or to answer any requests or enquiries.
We only collect personal information that is reasonably necessary for the purpose of our functions.
For any of our services that require a login and password (‘Login Details’) , it is your responsibility to keep your Login Details confidential and secure.
We ask you to provide personal information and obtain other information from you when you use our Website and services.
This Personal Information may include,
- - name, age, mobile number, address, email address;
  - payment details;
  - sensitive health information such as Customer’s medical data (e.g. type of diabetes, length of time for diabetes disorder, medication, blood glucose readings, device used, insulin pump data record, etc); and
  - any other information reasonably collected or required for the supply of our Services;
from HCPs:
- name, age, mobile number, address, email address;
- payment details;
- professional qualifications;
- experience in years;
- credentialled status (you consent to KNOWDIABETES verifying your qualifications and work status with a credentialled professional body per the consent form made available to you in our user interface);
- interest area; and
- any other information reasonably collected or required for the provision of our Services.
We may collect additional information from you at other times, including but not limited to, when you provide feedback, change your content or email preference, respond to surveys, or when you email us or communicate with our support team.
We also collect and use Personal Information to improve our Services through marketing communications.
You are solely responsible for:
- the accuracy, quality, integrity, legality, reliability, and appropriateness of the Personal Information that you provide to us, and
- accessing and updating that Personal Information if it is inaccurate or complete

4. Sensitive health information

We may, only with your express consent, collect health information from you that is considered sensitive. You must be adequately informed before giving this consent, you must give this consent voluntarily, the consent must be current and specific, and you must have the capacity to understand and communicate your consent.
We collect sensitive health information from you to provide you with our Services, subject to that information being reasonably necessary for the performance of our activities.
In this Privacy Policy, we also explain to you how we store, protect and keep your sensitive health information confidential and how and when we disclose it to third parties.
You own your sensitive health information. You can decide who accesses it and you have a right to access it by asking us for a copy. You can add or delete information or change who has a right to access your records by changing the information in your Member Account.
You can also contact us at any time to request information about the records that we hold about you, to correct any information that we hold about you, to delete any information that we hold about you or to opt out of emails, marketing or any other notifications that you receive from us. Health information can’t be used for direct marketing unless you’ve specifically agreed to it. If you agree initially, you can contact us and ask not to receive any further marketing materials.
We may share or disclose your sensitive health information when your or someone else’s health or safety are seriously threatened or when the information will reduce or prevent a serious threat to public health or safety. There are also certain exemptions which may apply in law enforcement situations and in a court of law.
We may ask you to verify your identity before acting on any of your requests.

5. What we do with your personal information

use your Personal Information and you consent to us using your Personal Information to:
- supply you with and market the Services on our Website;
- provide you with information and updates about our Website and our Services;
- communicate with you by a variety of measures including, but not limited to, by telephone, email, SMS or mail;
- manage, research and develop our Services, including through data analytics;
- administer our business activities and internal record keeping;
- meet legal, regulatory and compliance obligations; and
- investigate any complaints.
We may disclose your Personal Information to third parties where:
- the disclosure is directly related to the purpose for which the Personal Information was collected, and we have no reason to believe that you would object;
- you are likely to be aware, or have been made aware, that Personal Information of that kind is usually disclosed;
- where we believe on reasonable grounds that the disclosure is necessary to prevent or lessen a serious and imminent threat to the life or health of you or another person; or
- where that disclosure is authorised, otherwise permitted or required by law.
We also use your Personal Information to assist us in providing our Services to you, to verify your identity, contact your or respond to your queries, display, update and maintain the platform and its content, tailor your experience of the platform and our communications to you.
If you choose to withhold your Personal Information, it may not be possible for us to provide you with our Services or for you to access certain parts of our Website or for us to respond to your query.

6. Disclosure of your personal information

KNOWDIABETES does not disclose your contact information publicly or to other third parties unless it is authorised or required by law, or as otherwise outlined in this Privacy Policy.
From time to time, KNOWDIABETES may share or disclose your Personal Information, on a confidential basis, to any of our officers, employees, vendors, service providers, insurers, professional advisers, agents, suppliers, third party service providers or subcontractors and others that we transact with in the ordinary operation of our business, shipping and fulfilment companies, marketing and promotion, user experience research and surveys, Website hosting, and support and maintenance. We will disclose your Personal Information only for the extent required by our third-party service providers or subcontractors insofar as reasonably necessary to provide our Services to you.
We may also disclose aggregated data, in a form that does not identify you individually, to our advisors for the purposes of conducting market and user experience analysis.
If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user information databases, together with any Personal Information and non-Personal Information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality.
Personal Information that we collect from you will be stored in servers located in Australia.

7. Manner of collection

KNOWDIABETES will use reasonable endeavours to only collect your Personal Information directly from you, including through the use of online forms. If you are disclosing details of another person (for example, where you are subscribing on their behalf), it is your sole responsibility to ensure that that person understands and consents to the collection, use and disclosure of their personal information in the manner set out in this Privacy Policy.

8. Data ownership

You, as a Customer or HCP, own all rights, title and interest in the content and Personal Information that you provide to us (‘Member Data’) .
You are solely responsible for the accuracy, quality, integrity, legality, reliability, and appropriateness of your Member Data.
You grant to KNOWDIABETES, or to any third parties used by us to provide the Website or Services and any associated software, a non-exclusive, worldwide and royalty free licence to use, copy, display, perform, distribute, disseminate, transmit, translate, edit, cache and create derivative works of Member Data.
KNOWDIABETES or any related entities owns all right, title and interest in any data or information that we create, generate, compile, derive or produce in connection with any supply of our Website or Services, including data and information that is:
- aggregate or raw or statistical relating to usage, analyses and results of the Website;
- for the purpose of optimising delivery, commercialisation and performance of our Website; and
- samples and prototypes, conclusions, techniques, know how, methods, and undocumented findings generated in the usual course of our business.

9. Platform user experience tracking

KNOWDIABETES may use Google Analytics Advertising products such as Remarketing with Google Analytics, and Google Analytics Demographics and Interest Reporting. Google Analytics collects data about our Website traffic via Google Advertising cookies and anonymous identifiers. Data collected via these Google products is not linked with any personally identifiable information you submit while on our platform. If you wish to opt out of the Google Analytics data collection, you may do so on Google’s Website at https://tools.google.com/dlpage/gaoptout/.
As is true of most platforms and mobile applications, we and, in some instances, our third-party tracking-utility partners automatically gather certain information and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
KNOWDIABETES uses this information, which does not identify individual users, to analyse trends, to administer the platform, to track users’ movements around the platform and to gather demographic information about our user base as a whole.
KNOWDIABETES and its marketing and development partners, affiliates, and analytics or third-party service providers or subcontractors, such as online customer support provider and email marketing system, use technologies such as cookies, beacons, tags and scripts. These technologies are used in analysing trends, administering the Website, tracking users’ movements around the Website and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as on an aggregated basis.
KNOWDIABETES uses cookies for authentication purposes and for tailoring the Website according to user preferences. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Website, but your ability to use some features or areas of our Website may be limited.

10. Marketing material

KNOWDIABETES may use your Personal Information to provide you with materials, promotions and communications from time to time about Services available to you or from other service providers in partnership with us, or to invite you to continue to use our Services. This information will only come from us. KNOWDIABETES will not sell your Personal Information to other providers without your express consent.
You may opt out of receiving promotional materials from us at any time by contacting us at support@knowdiabetes.com.au or by clicking the ‘unsubscribe’ link on the relevant promotional emails.

11. Protecting and maintaining personal information

KNOWDIABETES will take all reasonable steps to protect your Personal Information unauthorised access, use and disclosure. However, we cannot guarantee that our systems and stored data will be completely free from third party interception or data corruption.
Certain parts of the platform (such as those parts that require you to provide us with your credit card number) provide the ability for you to transmit information to our platform in an encrypted form by using secure socket layer technology (SSL). We cannot ensure or warrant, and do not warrant, the absolute security or privacy of your Personal Information, including payment and account details. If you have any questions regarding security, you can contact us at support@knowdiabetes.com.au.
If you use our platform to link to another website, we encourage you to view their terms and conditions of use, privacy policies and security statements before disclosing any of your Personal Information on those Websites.
You agree that the transmission and exchange of information is carried out at your own risk. No method over the transmission or storage system is 100% private and secure. You understand that we do not guarantee or warrant the absolute privacy or security of any information we collect from or about you. If you have any questions about privacy or security, please contact us.

12. Notifiable data breach

The security of your data is important to us but remember no method of transmission over the internet is 100% private and secure. We do not guarantee or warrant the absolute privacy or security of any data we collect from or about you.
The internet is an insecure medium and users should be aware that there are inherent risks transmitting information across the internet. Information submitted unencrypted via electronic mail or web forms may be at risk of being intercepted, read or modified.
A reportable “Data Breach” is a security incident where the integrity of Personal Information is compromised through being destroyed, lost, altered, corrupted, disclosed or accessed by an unauthorised person where it is likely to result in serious harm to any individual affected.
We have procedures and systems in place including a data breach incident response plan, specific data breach policies and procedures and personnel to deal with an actual or suspected “Data Breach” and will notify you and the applicable regulator in accordance with our obligations under the Privacy Laws and NDB
Please report to KNOWDIABETES any actual or suspected data breaches for investigation by using the contact details provided below.

13. Accessing personal information

It is your responsibility to advise us of any changes to your personal details to ensure we can keep our records accurate and up to date. If you wish to access some or all of the Personal Information that you have provided us, please submit a request to support@knowdiabetes.com.au.
We request that you keep your information as current as possible so that we may continue to improve our supply of Services to you.
If you believe that your Personal Information with us is incorrect, you may request for the amendment of such information. You may also request that we delete your Personal Information with us.
If you request KNOWDIABETES not to use your Personal Information in a particular manner or at all, we will adopt reasonable measures to observe your request but we may, to the extent permitted by law, still use or disclose your Personal Information if you subsequently consent to the disclosure or if we believe that the use or disclosure is reasonably necessary to assist a law enforcement agency or is otherwise required or authorised by law. If you know the information we hold about you is not accurate or complete, please notify us. We will respond to requests for access within thirty (30) days.
We will retain your Personal Information for as long as your subscription is active or as needed to provide you Services. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

14. Opting-out

If we use your Personal Information to market and promote our Services, you may notify us at any time that you do not wish to receive marketing or promotional material by contacting us directly or through the “unsubscribe” mechanism in our marketing or promotional emails.

15. If you have concerns

If you have any concerns about how we handle your Personal Information or if you need further information, please contact our Privacy Officer at support@knowdiabetes.com.au. Also use this contact if you no longer consent to receiving marketing materials from us.
We may change this policy from time to time to reflect changes to our information practices. We encourage you to regularly review this statement to inform yourself of any amendments.

16. Contact us

This Website is owned and operated by KNOWDIABETES Pty Ltd (ACN 12 635 816 205).
You can contact us by email at support@knowdiabetes.com.au