Privacy Policy
Medlo Pty Ltd (ACN 667 986 361) (we, us or our), understands that
protecting your personal information is important. This Privacy Policy
sets out our commitment to protecting the privacy of personal information
provided to us, or otherwise collected by us when providing our platform
Medlo to you (Services) or when otherwise interacting with you, including
via our website.
The information we collect
If you are a Doctor:
Unless otherwise permitted by law, we will not collect sensitive information about you without first obtaining your consent.
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Identity Data including first name, middle name, last name, maiden
name, title, date of birth, gender, job title, photographic
identification, and images of you.
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Contact Data including billing address, email address and telephone
numbers.
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Financial Data including bank account and payment card details
(through our third party payment processor).
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Background Verification Data including evidence of your medical
qualification(s), AHPRA registration, medical provider numbers,
working with children check, criminal record check, passport number,
driver licence number, photographic identification, visa or other
details requested as part of our verification process to comply with
our due diligence obligations and related ongoing monitoring
commitments. We may also collect information about you that we find
online, including on your social media platforms, online search
engines (such as Google) and medical registration websites.
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Transaction Data including details about payments to you from us and
from you to us and other details of products and services you have
purchased from us or we have purchased from you.
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Technical and Usage Data including internet protocol (IP) address,
your login data, your browser session and geo-location data, device
and network information, statistics on page views and sessions,
acquisition sources, search queries and/or browsing behaviour,
information about your access and use of our website, including
through the use of Internet cookies, your communications with our
website, the type of browser you are using, the type of operating
system you are using and the domain name of your Internet service
provider.
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Profile Data including your username and password for Medlo, profile
picture, support requests you have made, content you post, send
receive and share through our platform, your interests, preferences,
feedback and survey responses.
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Interaction Data including information you provide to us when you
participate in any interactive features of our Services, including
surveys or events, and in the course of any of our scheduled meetings
that you attend (including online meetings).
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Marketing and Communications Data including your preferences in
receiving marketing from us and our third parties and your
communication preferences.
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Professional data including where you are a worker of ours or applying
for a role with us, your professional history such as your previous
positions and professional experience.
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Sensitive information is a sub-set of personal information that is
given a higher level of protection. Sensitive information means
information relating to your racial or ethnic origin, political
opinions, religion, trade union or other professional associations or
memberships, philosophical beliefs, sexual orientation or practices,
criminal records, health information or biometric information.
In the course of providing our Services, we may collect, or come
across such sensitive information in different situations, including
during the course of conducting a background verification check on you
or when reviewing your CV.
Unless otherwise permitted by law, we will not collect sensitive information about you without first obtaining your consent.
If you are a hospital contact liaising with us on behalf of a Hospital:
Interaction Data including information you provide to us when you participate in any interactive features of our Services, including surveys or events and in the course of any of our scheduled meetings that you attend (including online meetings).
Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
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Identity Data including your first name, middle name, last name and
job title.
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Contact Data including billing address, email address and telephone
numbers.
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Financial Data including bank account and payment card details
(through our third party payment processor).
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Transaction Data including details about payments to you from us and
from you to us and other details of products and services you have
purchased from us or we have purchased from you.
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Technical and Usage Data including internet protocol (IP) address,
your login data, your browser session and geo-location data, device
and network information, statistics on page views and sessions,
acquisition sources, search queries and/or browsing behaviour,
information about your access and use of our website, including
through the use of Internet cookies, your communications with our
website, the type of browser you are using, the type of operating
system you are using and the domain name of your Internet service
provider.
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Profile Data including your username and password for Medlo, profile
picture, support requests you have made, content you post, send
receive and share through our platform, your interests, preferences,
feedback and survey responses.
Interaction Data including information you provide to us when you participate in any interactive features of our Services, including surveys or events and in the course of any of our scheduled meetings that you attend (including online meetings).
Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
If you are a Referee:
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Identity Data such as first name, middle name, last name, title, job
title, and your relationship with the Doctor.
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Contact Data including email address and telephone numbers.
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Interaction Data including information you provide to us when you
provide a reference check to us in relation to a Doctor.
How we collect personal information
We collect personal information in a variety of ways, including:
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Directly: We collect personal information which you directly provide
to us, including when you register for an account, through the
‘contact us’ form on our website or when you request our assistance
via email, or over the telephone.
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Indirectly: We may collect personal information which you indirectly
provide to us while interacting with us, such as when you use our
website, in emails, over the telephone and in your online
enquiries.
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From third parties: We collect personal information from third
parties, such as from your employer where they allocate you as an
authorised user, or details of your use of our website from our
analytics and cookie providers and marketing providers. See the
“Cookies” section below for more detail on the use of cookies.
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From publicly available sources: We collect personal data from
publicly available resources such as the Australian Securities and
Investment Commission (ASIC) and professional networking sites such as
LinkedIn, the Australian Health Practitioner Regulation Agency website
and Google .
Why we collect, hold, use and disclose personal information
We have set out below, in a table format, a description of the purposes
for which we plan to collect, hold, use and disclose your personal
information.
Category
Type of Personal Information We May Collect
Primary Purpose of Collection
Identity Data
Your first name, last name, title, date of birth, gender, job title.
If you are a Doctor or a Hospital, to enable you to access and use
Medlo, including to provide you with a login. If you are a Referee,
to verify your identity to enable you to provide a reference check
for a Doctor.
Contact Data
Your billing address, email address and telephone numbers.
If you are a Doctor or a Hospital, to contact and communicate with
you about our services, including in response to any service
requires you lodge with us or other enquiries you make with us. If
you are a Referee, to contact and communicate with you in relation
to a reference check for a Doctor.
Financial Data and Transaction Data
Your bank account and payment card details (through our third party
payment processor), details about payments to you from us.
For internal record keeping, administrative, invoicing and billing
purposes.
Background Verification Data
Evidence of your medical qualifications, AHPRA registrations,
working with children check, criminal record check, identification
documents or other details requested as part of our verification
process.
To comply with our due diligence obligations and related ongoing
monitoring commitments, including to ensure that you have the
necessary qualifications to work at partner Hospitals.
Technical and Usage Data
Your IP address, device and network information, browsing behaviour,
information about your access and use of our website and related
information.
For analytics, market research and business development, including
to operate and improve our services, associated applications and
associated social media platforms.
Profile Data
Your username and password for Medlo, and any other interactions you
have with us via Medlo, including your preferences, feedback and
survey responses
To enable you to access and use Medlo and for analytics, market
research and business development, including to operate and improve
our services, associated applications and associated social media
platforms.
Interaction Data
Information you provide to us when you participate in any
interactive features of our services, or where you attend a meeting
we schedule.
For analytics, market research and business development, including
to operate and improve our services, associated applications and
associated social media platforms.
Marketing and Communications Data
Your preferences in receiving marketing from us and our third
parties and your communication preferences.
For advertising and marketing, including to send you promotional
information about our events and experiences and information that we
consider may be of interest to you.
Any Relevant Personal Information
Any personal information you may otherwise provide to us.
To comply with our legal obligations or if otherwise required or
authorised by law.
Our disclosures of personal information to third parties
We may disclose personal information to:
Google Analytics: We may have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting etc. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.
You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.
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other users on Medlo (for example, to a hospital for the purposes of
facilitating your placement at an interested hospital);
- our employees, contractors and/or related entities;
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IT service providers, data storage, web-hosting and server
providers;
- marketing or advertising providers;
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professional advisors, bankers, auditors, our insurers and insurance
brokers;
- payment systems operators such as Xero;
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our existing or potential agents or business partners including
hospitals and health boards;
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anyone to whom our business or assets (or any part of them) are, or
may (in good faith) be, transferred;
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courts, tribunals and regulatory authorities, in the event you fail to
pay for goods or services we have provided to you;
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courts, tribunals, regulatory authorities and law enforcement
officers, as required or authorised by law, in connection with any
actual or prospective legal proceedings, or in order to establish,
exercise or defend our legal rights;
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third parties to collect and process data, such as Google Analytics
(See
here
how Google uses data when you use third party websites or
applications), Meta Pixel or other relevant analytics businesses;
and
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any other third parties as required or permitted by law, such as where
we receive a subpoena.
Google Analytics: We may have enabled Google Analytics Advertising Features including Remarketing Features, Advertising Reporting Features, Demographics and Interest Reports, Store Visits, Google Display Network Impression reporting etc. We and third-party vendors may use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together.
You can opt-out of Google Analytics Advertising Features including using a Google Analytics Opt-out Browser add-on found here. To opt-out of personalised ad delivery on the Google content network, please visit Google’s Ads Preferences Manager here or if you wish to opt-out permanently even when all cookies are deleted from your browser you can install their plugin here. To opt out of interest-based ads on mobile devices, please follow these instructions for your mobile device: On android open the Google Settings app on your device and select “ads” to control the settings. On iOS devices with iOS 6 and above use Apple’s advertising identifier. To learn more about limiting ad tracking using this identifier, visit the settings menu on your device.
Overseas disclosure
While we store personal information in Australia, where we disclose your
personal information to the third parties listed above, these third
parties may store, transfer or access personal information outside of
Australia, including New Zealand. We will only disclose your personal
information overseas in accordance with the Australian Privacy Principles.
We take rigorous steps to protect your personal information from misuse or
unauthorised disclosure. For example, we ensure that we only collect your
personal information for legitimate business purposes (including to allow
you to access and use Medlo and for us to deliver our services to you) and
we will only share your personal information with third parties for lawful
purposes as permitted under the Australian Privacy Principles.
Your rights and controlling your personal information
Your choice: Please read this Privacy Policy carefully. If you provide
personal information to us, you understand we will collect, hold, use and
disclose your personal information in accordance with this Privacy Policy.
You do not have to provide personal information to us, however, if you do
not, it may affect our ability to provide our Services to you and your use
of our Services.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you also have the right to contact the Office of the Australian Information Commissioner.
Storage and security
We are committed to ensuring that the personal information we collect is
secure. In order to prevent unauthorised access or disclosure, we have put
in place suitable physical, electronic and managerial procedures, to
safeguard and secure personal information and protect it from misuse,
interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.
The security measures we have implemented to safeguard your personal information includes:
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.
The security measures we have implemented to safeguard your personal information includes:
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we do not sell, trade, rent or otherwise share for marketing purposes
your personal information without your prior consent;
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we are a paperless business and where we receive your personal
information on paper, we will upload the personal information and/or
document into our online systems and will destroy the paper copy in a
confidential and secure manner;
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where personal information is no longer required for the purposes for
which it was collected, we will, after we have retained the documents
in accordance with the periods mandated by legislation, either destroy
the personal information or de-identify it; and
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personal information you provide us is securely stored at all times.
Multi-factor Authentication
We prioritise the security of your personal information and have
implemented multi-factor authentication to safeguard access to your Medlo
account using Google and Microsoft Azure. By employing multi-factor
authentication, we aim to reduce the risk of unauthorised access to your
account and ensure the integrity of your personal information. If you sign
up for Medlo using your existing Google or Outlook account, we will employ
the Google API and the Outlook API (APIs) to pull your name and email
address, and for the sole purposes of verifying your details to create an
account for you on Medlo. We will not otherwise use the APIs to collect
any other personal information about you.
Recordings
We may record meetings that we schedule. Where we record those meetings,
we will seek your prior written consent before the recording commences.
All recordings will be stored in accordance with this Privacy Policy.
Cookies
We may use cookies on our website from time to time. Cookies are text
files placed in your computer's browser to store your preferences.
Cookies, by themselves, do not tell us your email address or other
personally identifiable information. However, they do recognise you when
you return to our online website and allow third parties, such as Google
and Facebook, to cause our advertisements to appear on your social media
and online media feeds as part of our retargeting campaigns. If and when
you choose to provide our online website with personal information, this
information may be linked to the data stored in the cookie.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Links to other websites
Our website may contain links to other party’s websites. We do not have
any control over those websites and we are not responsible for the
protection and privacy of any personal information which you provide
whilst visiting those websites. Those websites are not governed by this
Privacy Policy.
Amendments
We may, at any time and at our discretion, vary this Privacy Policy by
publishing the amended Privacy Policy on our website. We recommend you
check our website regularly to ensure you are aware of our current Privacy
Policy.
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Last update: 5 July 2023