Security and Privacy

About This Security and Privacy Policy

We are bound by the National Privacy Principles ("Principles") of the Privacy Act, 1988 (Cth) and are committed to protecting personal information we may hold at any time in respect of any individual, in accordance with the requirements of those Principles. "Personal information" for the purposes of this Privacy Policy is information about and which identifies individuals. It includes information obtained from an individual or a third party and, for individual credit applicants and guarantors, includes anything about credit worthiness, standing, history and capacity which, under and in accordance with the Privacy Act may lawfully be exchanged. In general, we will not use or disclose personal information collected about you otherwise than for a purpose set out in this Privacy Policy, for a purpose you would reasonably expect, a purpose required or permitted by law, or a purpose otherwise disclosed to, or authorized by, you.

We want you to be confident that you can use our websites safely and be certain that the information you share with us is protected and treated confidentially. This Security and Privacy Policy explains how we protect the privacy of your personal information and sets out the matters which we are required to disclose under the Principles when you use our websites. This Security and Privacy Policy should be read with our Website Terms of Use. You should also read our Confidentiality Policy and Disclosure Statement if you intend to obtain our products and services.

In this Security and Privacy Policy and in our Website Terms of Use, the expressions We, Us and Our, are a reference to Global Mind Screen Pty Ltd and any related entity of Global Mind Screen Pty Ltd. A reference to our website is a reference to our main public US website at www.globalmindscreen.com (including secure areas accessible only to accredited Mind Screen practitioners and administrators) and our US patients' website at session.globalmindscreen.com, both operated by Global Mind Screen Pty Ltd (ABN 87 105 265 736).

In connection with particular services we offer or provide to you, we may make other privacy disclosures to you or seek your authority to use your personal information in ways which are different from or more specific than those stated in this Privacy Policy. There may be some specific security and privacy obligations that apply to us or to you for parts of our websites. We will notify you of these on those parts of our websites to which they apply. You must read such notices and you acknowledge and agree that those obligations apply in the same manner as this Security and Privacy Policy. If there is any inconsistency between what is said in this Security and Privacy Policy and those notices, the obligations in the notice apply.

The Security and Privacy Policy may also apply to services offered by us on other people's websites. Whenever that's the case, we'll put a note on those websites to let you know. If we put such a note on another person's website, you agree to comply with this Security and Privacy Policy when accessing, viewing or using that website as if it was our website.

Information Collected

We will not ordinarily collect any information about you except where you provide it to us or it is provided to us with your authority. We explain to you in this Security and Privacy Policy how we might collect information from our websites and what the information may be used for by us. The types of personal information we collect generally includes your name, address, telephone number, email address and shipping details. We only collect personal information about you that is necessary for our functions and activities and, ordinarily, you will be told the purposes for which we collect that information when it is collected. As a general rule the collection of your personal information will be necessary for us to provide a product or service to you or to maintain our relationship with you. Additionally, the purposes for which we will generally collect and use your personal information will include:

• complying with legislative and regulatory requirements;
• considering any application you make to us;
• performing our administrative operations, including accounting, risk management, record keeping, archiving, systems development and testing, credit scoring and staff training;
• managing our rights and obligations in relation to external payment systems;
• conducting market or customer satisfaction research;
• developing, establishing and administering alliances and other arrangements (including rewards programs) with other organizations in relation to the promotion;
• administration and use of our respective products and services;
• developing and identifying products and services that may interest you; and
• (unless you ask us not to) telling you about products and services.

In certain circumstances, we may also collect personal information about you which is sensitive. Sensitive information includes information about your health, religious or philosophical beliefs, membership of professional or trade associations or a criminal record. Unless the collection of sensitive information is required or permitted by or under law, we will obtain your consent to its collection. If the sensitive information relates directly to your ability to meet a financial obligation to us, you consent to our collection of it. We will collect personal information directly from you when you open an account with us, complete an application form for one of our products or services, deal with us over the telephone or in person, send us a letter or visit our website. We may, for purposes of security, training, or information or transaction verification, listen to and/or record telephone calls to which you are a party with us.

The information we collect about you depends on how you use our websites. If you visit an unsecured area, for example - that's to say one which doesn't require you to log on to read, browse or download information - our system will record the date and time of your visit, the pages you look at, and any information you download. We won't record any information which could identify you. This information does not record your personal details.

Although our websites offer you a number of interactive facilities, we will not use these facilities to capture any personal information which could identify you which you might enter while using any of them without your prior consent.

If you decide to complete an online application form, the personal information that you enter into the form will only be collected by us. If at any stage you cancel your application or log out prior to submitting it, the information you have entered up to that point will be automatically deleted.

The types of personal information we collect generally from our online application forms are set out in our Privacy Policy. In certain circumstances, we may also collect personal information about you which is sensitive. Sensitive information includes information about your health, religious or philosophical beliefs, membership of professional or trade associations or a criminal record. Unless the collection of sensitive information is required or permitted by or under law, we will obtain your consent to its collection.

Our websites also contain links to the websites of other, third party providers of goods and services. If you visit such sites via any of our sites - and if those third parties collect information about you, we may get a copy of that information - or have access to it - as part of our arrangements with those third parties. If your consent to this collection is required by law, we will first obtain your consent prior to collecting the information.

We may also share cookie information, information about your preferences or other information you have given the third party. You can't usually be identified from the shared information, but if you can, we'll ask you first before sharing it. You should also review the Privacy Policy and any disclosure statement which appears on a third party website.

Personal Information About Third Parties

If at any time you supply us with personal information about another person (for example, a referee or a person to whom you may wish a payment to be directed), you should ensure that you are authorized to do so and you must agree to inform that person who we are, that we will use and disclose their personal information and that they may gain access to their personal information should we hold it.

Use and Disclosure of Personal Information

We will only use or disclose personal information in accordance with our Privacy Policy. We will not use or disclose information collected about you other than for a purpose made known to you, a purpose you would reasonably expect, a purpose required or permitted by or under any law or a purpose otherwise authorized by you.

You authorize us to disclose necessary information to related companies and to any agents or contractors who provide services to us in connection with the provision of products or services you have sought from us. These parties are prohibited from using your personal information except for the specific purpose for which we supply it to them.

In some cases, we may need to transfer your personal information overseas. If we believe that the overseas third party is not subject to privacy obligations equivalent to those which apply to us we will seek your consent to transfer the information, except where the National Privacy Principles do not require us to do so.

Advertising and Tracking

We share personal information with our related bodies corporate. We use several advertising companies to devise and deliver our online advertising. This often involves serving banner adverts on third party websites.

When you see one of our ads on a third party website, cookies and, in some cases, spotlight tags are sometimes used to collect information such as:

• the server your computer is logged onto.
• your browser type.
• the date and time of your visit.
• the performance of their marketing efforts.

When you visit our website after seeing one of our ads on a third party website, information is collected on how you use our website. This might include which pages you view, and whether you start and complete an online application.

Cookies

We use cookies to interact with your Internet browser so that we can continually improve our websites and learn how to provide you with a better and more customized service.

A cookie is a small text file placed on your computer by our web page server. We can later retrieve it. Cookies are frequently used on websites and you can choose if and how they are accepted by configuring your preferences and options in your browser. We use cookies for two different purposes.

First of all, we allocate a cookie to each Internet browser that visits our websites. This doesn't allow us to collect personal information which would identify you, and instead, we use it to:

• determine if you have previously visited our website;
• identify pages you have accessed and third party websites you have visited
• manage security measures

So, if you want to make full use of our websites, you'll need to set up your browser to accept cookies.

Secondly, we use cookies for security and personalization. Bear in mind that if your browser is set up to reject all cookies you'll be unable to use the many secure services on our website that require cookies in order to allow you to participate. You may still be able to use some information-only pages if you choose not to accept cookies.

How We Handle Email

We will store the content of any Email you send us. The content may be monitored by us for security issues, such as where Email abuse is suspected, and our response to you may be monitored to help us meet our quality assurance goals.

Acceptance of, and Changes to our Security and Privacy Policy

You acknowledge and accept that your use of our websites indicates your acceptance of our Terms of Use and Security and Privacy Policy.

This is our current Security and Privacy Policy. It replaces any other one which has appeared previously on our websites. We may at any time vary the Security and Privacy Policy by publishing the changed version on the website. By accepting our terms, you agree that we have provided you with sufficient notice of any changes and any subsequent access to, viewing or use by you of our website will constitute an acceptance of those changes. We encourage you to periodically review our Privacy Policy for any changes.

Gaining Access to Information

We will, on request, provide you with personal information we have collected about you unless there is an exception which applies under the Principles. You can gain access to the information we hold about you for the purpose of correcting or updating such information. You can do so by calling us. We may recover from you the reasonable cost in supplying you with this information. We will try and deal with your request within a reasonable time. Under certain circumstances we may not be able to tell you what personal information we hold about you. This includes where:

• it would have an unreasonable impact on the privacy of other individuals;
• the information relates to legal proceedings with you;
• the information would reveal our commercially sensitive decision-making process; or
• we are prevented by law from disclosing the information, or providing access would prejudice certain investigations.

We will take reasonable steps to ensure that your personal information is accurate, complete and up-to-date. If at any time you believe that personal information that we hold about you is inaccurate, incomplete or out of date, please advise us by telephoning us

Security of your Personal Information

We maintain strict procedures and standards and take all reasonable care to prevent unauthorized access to, and modification and disclosure of, your personal information. We will take all reasonable steps to protect your personal information from misuse and loss.

We also protect the security of your personal information when transmitted over the Internet. We use a Secure Socket Layer (SSL) to transfer personal information between you and our web servers with relation to online payment details, and GPG encryption when we transfer data to third parties. However although we regularly review developments in security and encryption, no data transmission over the Internet can be guaranteed as fully secure and accordingly, we cannot guarantee or warrant the security of any information you send to us using our on-line forms or products. You submit information over the Internet at your own risk. Once we have received your information we take reasonable steps to keep it secure while it is in our system. If we no longer need your information, we will destroy or de-identify it.

Government Identifiers

We do not use your tax file number, Medicare number, pension number or any other government identifier as your account, policy or application number. We will only use and disclose these numbers for the purposes required by law.

Complaints about Breaches of Privacy

If you believe that the privacy of your personal information has been compromised or is not being adequately protected, you should contact us by telephoning us. We will make every effort to resolve your complaint internally.

If we do not resolve your complaint to your satisfaction, you may apply to the Federal Privacy Commissioner to have your complaint investigated. For more information about how you may lodge a complaint with the Federal Privacy Commissioner, please contact the Commissioner's hotline service on 1300 363 992.

Contacting Us

If you have any questions regarding this Security and Privacy Policy or would like more information about the way we manage your personal information, contact us via our contact form.