Who we are
Daniel Christopher Hug and Nick Muir (ABN 61 120 854 679) trading as ‘Hug Health’ (“HH” or “we”) owns and operates the HH software application that allows users to log patient falls and associated fall data (the “App”).
The services offered by HH include the App, the website located at www.hughealth.com.au (the HH Website), any HH mobile services and any other features, content or applications offered from time to time by HH using the App or in connection with the App (collectively, the “Services”).
At HH we respect the privacy of your personal information in our care and are committed to protecting the privacy of the personal information we collect and receive.
(b) the kind of information we collect about you, how we collect it, and how we use it;
(c) how we may disclose that information;
(d) how you can access the information we hold about you;
(e) when we may use your information to contact you;
(f) the protection of your personal information; and
This policy also informs you of your rights to privacy and describes how we comply with our privacy requirements as set out in the Privacy Act 1988 (Cth) (the Privacy Act) and the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth). The Australian Privacy Principles contained in the Privacy Act govern the way in which we collect, use, disclose, store, secure and dispose of your personal information.
By using the Services you consent to the privacy practices set out in this policy. If you do not agree with the policy and consent please discontinue use of the Services.
3. Personal information
Personal information is information or an opinion that can be used to identify you or which allows your identity to be worked out from the information. This might include personal details like your name, address, date of birth, other contact information like your email address and phone number and financial information like your credit card number or bank details. It may also include your opinions about our services and our staff, as well as any information sent to us through correspondence.
4. SENSITIVE INFORMATION
5. The kind of personal information HH collects and holds
The personal information we collect and hold will depend on our dealings with you. The different kinds of personal information we collect and hold about individuals includes:
- contact details, including address, phone number and email address;
- dates of birth;
- opinions about our services and staff; and
- any information sent to us through correspondence.
6. How HH collects your personal information
HH collects personal information about you in a number of ways, including:
- from you directly by personal contact when you create an account as well as through mail, telephone, email and online communications and interactions; and
- your account activity when you use the Services.
7. Why HH Collects Your Personal Information
HH collects personal information for a number of reasons including:
- to communicate with you;
- to determine whether we are able to provide the Services to you and to determine the applicable fee payable by you for the Services;
- to supply the Services to you;
- to manage and administer your relationship with us, including processing payments, accounting, auditing, billing and collection and support services to provide the Services to you;
- for marketing purposes;
- to measure our performance and to improve the Services, including for the quality assurance of the Services;
- for analysis of the Services;
- to develop the Services;
- to better understand your requirements and preferences and improve the Services;
- to recruit employees;
- to perform other administrative functions, such as maintaining your client file;
- to obtain and maintain insurance;
- to comply with legal requirements; and
- for purposes directly related to any of the above.
8. Use and disclosure of your personal information
We disclose your personal information to third parties for the following purposes:
- to provide you with the Services;
- to store our data;
- to improve our services;
- for research purposes;
- for quality assurance purposes;
- if permitted or required by law or a governmental authority;
- to obtain and maintain insurance, or if required by our insurer in connection with a claim; or
- for any other purpose, with your consent.
We may also provide your personal information to our related bodies corporate and our service providers who assist us with customer contact, archival, auditing, accounting, legal, business consulting, banking, delivery, data processing, website or technology services. We will take reasonable and practicable steps to ensure third parties we deal with take steps to protect your privacy. All of our employees are required to maintain the confidentiality of any personal information held by us.
We may also need to disclose your personal information to our advisors, including our accountants and lawyers.
HH uses hosting companies that may have servers that are physically located overseas. HH may also use service providers and contractors located overseas, and your personal information may be disclosed to them. HH will take reasonable steps to ensure that any overseas recipient complies with the Privacy Act. You should also be aware that where data is hosted overseas, access to and use of that personal information will be governed by laws that apply in those overseas locations.
HH may share aggregated, non-personally identifiable information publicly, for example, to show trends about the general use of Services or for research purposes.
We will never sell your personal information to anyone.
Generally we will not disclose your personal information to anyone overseas, except if we are required to do this by law or if it is necessary to provide you with the services you have requested from us
9. Direct Marketing
From time to time we may use the personal information collected from you for direct marketing purposes. If we do contact you in this way, it will only be in relation to matters that customers would reasonably expect us to contact them directly about.
We will ask for your consent before we use your personal information for marketing purposes if we have not collected that personal information directly from you.
If you receive marketing offers from us and do not wish to receive them in the future, please use the ‘unsubscribe’ link provided in those electronic communications.
10. SECURITY OF YOUR PERSONAL INFORMATION
We may hold your personal information in physical and electronic form both at our premises and with the assistance of our service providers. We implement a range of measures to protect the security of that information. We are also required to take reasonable steps to destroy or de-identify information when no longer needed for any permitted purpose.
If you are considering sending us any personal information electronically, please be aware that the information may be insecure in transit, particularly where no encryption is used (e.g. email, standard http). You agree that, even though HH uses reasonable endeavours to secure your personal information, HH cannot guarantee that any information sent or accessed electronically is secure.
You may also assist HH in keeping your personal information secure by maintaining the confidentiality of your account information and notifying HH immediately if there is any unauthorised use of your account, or any other breach of security relating to your account.
In the unlikely event of a suspected data breach, HH will within 30 days assess and evaluate whether a breach has occurred and will, if required, notify the relevant data protection authority unless the breach is not likely to present any risk to your rights.
12. Destroying personal information
HH will destroy, or take reasonably commercial steps to de-identify, personal information when this is no longer required by us.
The Services may contain links to Third Party Websites. HH is not responsible for the information on these sites, or their privacy policies. HH may keep track of your interactions with Third Party Websites provided on the Services in order to improve the Services and to aggregate statistics.
14. Accuracy of your information
HH takes all reasonable precautions to ensure that the personal information it collects, uses and discloses is accurate, complete and up-to-date. However, the accuracy of that information depends to a large extent on the information you provide. We therefore recommend that you:
- let us know if there are any errors in your personal information we hold; and
- keep us up-to-date with changes to personal information you have previously provided.
15. Your rights in relation to personal information
Under the Privacy Act you have the right to request access to your personal information that is held by us about you. You also have the right to request correction of any of your personal information that we hold.
Please contact us if you would like to request access to the personal information we hold about you. You will need to put your request in writing for, security reasons, and send it to the using the contact details as set out in paragraph 16 below. Please provide us with as much detail as you can about the particular information you seek, in order to help us retrieve it. We will use commercially reasonable endeavours to provide the information within 10 business days of receiving your request. Please note that HH may charge a fee to cover the cost of meeting your request.
You are able to change or update your account information at any time through the Services.
If you believe that the privacy of your personal information is not effectively protected, or if you are concerned that your privacy has been compromised through the dissemination of your personal information, please contact us using the contact details as set out below:
By email: firstname.lastname@example.org
Attention: Daniel Hug
We take all enquiries seriously and will attend to your question or complaint promptly. If you are not happy with the way we deal with your privacy complaint you can make a complaint to the Privacy Commissioner at the Office of the Australian Information Commission (OAIC). More information about making a complaint to OAIC is available at http://www.oaic.gov.au/privacy/privacy-complaints
Policy last updated March 2020