Privacy policy.
This Privacy Policy applies to the collection, storage, use, and disclosure by CINGULUM HEALTH PTY LIMITED (ABN 90 636 435 875) (Cingulum, we, us, our) of your personal information. It also provides information on how you can obtain access to or seek correction of your personal information. Cingulum is committed to the protection of personal information and has developed this Privacy Policy in line with the ‘Australian Privacy Principles’ in the Privacy Act 1988 (Cth) (Privacy Act).
You agree that providing us with your personal information when you contact us, use the https://cingulumhealth.com/ website (Website), complete an assessment form in person or through the Website, or book an appointment in person, through the Website, or via other means, your consent to the collection and use of your personal information in accordance with this Privacy Policy. We may change this Privacy Policy from time to time.
Types of Personal Information We Collect
The types of personal information we collect can include (but is not limited to), your name, postal address, billing address, email address, contact phone numbers, driver's licence number (or other government-issued identification information), date of birth, credit, or debit card details (for payment purposes only), and Medicare number or private health insurance member details.
We will also collect and hold sensitive health information about you, such as your medical history, biometrics (including height and weight), brain imaging, and current medications.
Collection of Your Personal Information
If you complete an assessment form, booking form, google form, email us, or provide your personal information once you become a patient, Cingulum may collect:
Information that personally identifies you (including details such as your email address) but only when you voluntarily give it to us; and/or
Sensitive information including health information (such as any health conditions you suffer from, health care records, medical history, and health insurance fund memberships) but only when you voluntarily give it to us.
In operating the Website, Cingulum may collect:
Information that does not personally identify you but tracks your use of the Website to learn about your preferences so that we can make our Website better; and/or
Information that personally identifies you (including details such as name, email address, and telephone number) but only when you voluntarily give it to us.
The collection of this personal information is required to enable Cingulum to provide the services to you and to ensure the highest quality of service provision. Individuals do not have to supply Cingulum with their personal or health information, however, if the individual chooses not to do so Cingulum may be unable to provide the services required or sought.
Purpose of Collecting Your Personal Information
The purpose of collecting your personal information is so we can offer services to you relating to the treatment of various neurological disorders, including movement disorders (stroke, Parkinson’s disease, etc.), psychiatric disorders (depression, anxiety, PTSD, OCD, eating disorders, etc.), chronic pain, tinnitus, memory loss, and dementia. Our services utilise the latest technology and advances in non-invasive brain stimulation procedures.
We also collect, hold, use and disclose your personal information to:
offer and provide you with our services;
manage and administer those goods and services, including account keeping procedures;
share with neuroimaging companies, such as Omniscient Neurotechnology, in order to calibrate and tailor services to you;
communicate with you, including (but not limited to) emailing you tax invoices;
send you marketing or promotional information in relation to Cingulum or our business partners that might be of interest to you;
comply with our legal and regulatory obligations; and
otherwise to manage our business.
Use and Disclosure of Your Personal Information
Cingulum will use and disclose your personal and health information in order to provide you with the services requested. We do not otherwise share, sell or otherwise disclose your personal information for purposes other than as outlined in this Privacy Policy.
We may disclose personal information to third parties such as our suppliers, organisations that provide us with technical and support services, or our professional advisors, where permitted by the Privacy Act. If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do.
Specifically, we will disclose personal and health information for the purposes outlined in this Privacy Policy to third-party service providers in order to support our business, such as neuroimaging companies like Omniscient Neurotechnology.
We may also use your personal information to do the following:
Contact you by telephone, post, email, and/or SMS to tell you about our products, services, and promotions;
Contact you by telephone, fax, post, email, and/or SMS to ask you to provide feedback about the services and the Website;
Contact you via our messaging service;
Contact you for advertising, promotional and direct marketing purposes in order to inform you about our activities and to improve the Website;
Perform administrative functions and activities in relation to our services and the Website;
Send to neuroimaging centres or other healthcare professionals for the purpose of delivering our services to you, including tailoring your treatment to your specific health needs;
Disclose your personal and/or health information to health professionals involved in your case;
Improve our services or Website to develop new products or services which may involve performing analytics on information that we collect automatically including, but not limited to, through your IP address, browser type, and operating system information;
Disclose to third parties we engage to perform functions or provide products and services on our behalf such as processing credit card information, mail outs, debt collection, event management, marketing, research, and advertising;
Respond to enquiries you make regarding the services or the Website; and/or
Comply with any applicable laws.
If you decide that you do not wish to receive information from us, please contact us with your request to be removed from our mailing list. We will remove your name within a reasonable period of receipt of notice.
Where practicable we will endeavour to collect, hold, use and disclose personal information for the purposes described above on a de-identified basis.
Storage and Security of Your Personal Information
From time to time we may hold personal information in any combination of data storage facilities, cloud computing facilities (which may be located overseas), or secure paper-based files which may be operated or held by us or by third-party service providers under a contractual arrangement.
We will use all reasonable endeavours to maintain the security of your personal information from unauthorised access, modification, or disclosure.
We cannot ensure or warrant that your personal information will always be secure during transmission or protected from unauthorised access during storage therefore you provide your personal information to us at your own risk.
Please contact us immediately if you become aware or have reason to believe there has been any unauthorised use of your personal information in connection with the Website.
We will take all reasonable steps to destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.
Access, Amendment, and Deletion of Your Personal Information
We will use all reasonable endeavours to keep your personal information accurate, complete, up-to-date, relevant, and not misleading. Please contact us to examine your personal information if required and we will provide a complete list of your personal information within a reasonable period of receipt of your request.
You may contact us to amend any of your personal information that is inaccurate, incomplete, or out-of-date or request that your personal information be deleted. It is your sole responsibility to ensure that your personal information is accurate and kept up to date. We will amend or delete your records as requested within a reasonable period of receipt of notice. If applicable, any legal requirement on us to maintain certain records of your personal information shall prevail over any of your requests. Cingulum may require identification to be provided before releasing copies of personal information.
Anonymity
You may seek to remain anonymous or use a pseudonym when you deal with us. However, this may mean that we will be unable to provide our services to you.
Disclaimer - Further Disclosure
We will only collect, use or disclose information that personally identifies you in accordance with this Privacy Policy, unless we are required to disclose it by law, or in our opinion we are required to disclose it to protect the rights or property of us or any third party or to avoid injury to any person.
Links
If you use a Link to access a third-party website from our Website, you do so entirely at your own risk. You should always read the applicable privacy policies on the other websites.
Cross Border Disclosures
We currently only operate in Australia.
From time to time, we may engage an overseas recipient to provide services to us, such as cloud-based storage solutions. Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider. However, by providing us with your personal information, you consent to the storage of such information on overseas servers and acknowledge that APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the Australian Privacy Principles, that entity will not be bound by, and you will not be able to seek redress under, the Privacy.
Mandatory Data Breach Notifications
Pursuant to the Privacy Act, we will be required to notify you and the Australian Information Commissioner if an eligible data breach (relating to your personal and/or health information) has occurred.
Applicable Law
The Website is controlled from our offices in Australia. This Privacy Policy will be governed by and construed in accordance with the laws of Australia. You irrevocably and unconditionally submit to the exclusive jurisdiction of the courts of New South Wales, Australia.
If any provision of this Privacy Policy is found to be invalid or unenforceable by a court of law, such invalidity or unenforceability will not affect the remainder of this Privacy Policy which will continue in full force and effect.
Contact Us
You may contact us in relation to your personal information by email at info@cingulumhealth.com.
Making a Complaint
If you have any concerns about how we manage your personal information, you may write to our Privacy Officer at info@cingulumhealth.com. We will reasonably endeavour to provide a response within 30 days of receipt of your complaint.
If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) by writing to the OAIC at GPO Box 5218, Sydney NSW 2001. For further information about the OAIC, please visit www.oaic.gov.au.