Snug Health Pty Ltd (ABN 47 610 411 473) ("Snug Health", "we", "us" or "our") specialises in the provision of an innovative mobile application that serves as a personal electronic health record and assists with health promotion and disease management (Snug).
Snug Health is committed to protecting your privacy and complying with the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APPs) and other relevant laws in relation to the management of personal information.
What is personal information?
When used in this Policy, "personal information" has the meaning given in the Privacy Act.
In general terms, it is information that can be used to personally identify you such as your name, address, telephone number, email address, profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
When used in this Policy, "sensitive information" has the meaning given in the Privacy Act.
In general terms, it includes information about your health or genetics. Unless required by law, we will only collect sensitive information with your consent.
What personal information do we collect?
As an account holder in Snug, certain personal information will be required to establish and maintain your record, and to provide services to you. We may collect the following types of personal information relating to you:
The choice of how much information you provide to us is yours, but if you want to register as a member of, or have a user account on our websites, we require certain information from you in order to provide those services.
Where possible, you have the option of interacting with us anonymously (for example, as a visitor of the website) or using a pseudonym if you feel more comfortable dealing with us that way. For example, if you contact us by telephone with a general question, we will not ask for your full name unless we need it to answer your question.
How do we collect personal information?
Where possible we will collect personal information directly from you, however in certain circumstances it may be necessary to collect information about you from third parties. If we receive information about you from someone else, we will take reasonable steps to make you aware of the facts and circumstances of that collection. We may collect your personal information in several ways, including:
Collecting personal information through our websites
What happens if we receive unsolicited personal information?
Why do we collect your personal information?
Do we use your personal information for direct marketing?
We may use your personal information to send you direct marketing communication and information about our services and products, and other related services and products if we have your permission or a legitimate interest in doing so. If at any time you no longer wish to receive this information, you can request to "opt out" from receiving this information by contacting email@example.com.
We will NEVER sell your personal information to anyone for direct marketing purposes of otherwise.
Disclosure of personal information
The information Snug Health collects from you or concerning you or your dependents, will be kept strictly confidential and secure at all times. Where your personal information is disclosed, it will be disclosed in a manner that is consistent with the APPs and only for a purpose consistent with the purpose for which the information was originally collected.
Your personal information will only be disclosed to third parties in the following circumstances:
Snug is operated out of Australia. If you access Snug from outside Australia then you expressly consent to the disclosure of your personal information within Australia.
Your rights in relation to your personal information
You may request access to your personal information collected by us and ask that we correct that personal information. You may also ask us to delete your personal information, restrict the processing of your personal information or transfer a machine-readable copy of your personal information to you or a third-party of your choosing. We will need to verify your identity before we are able to action your request.
We may refuse to action your request where actioning the request would:
We may also refuse to action your request where we are authorised to do so by law.
You can make a request in relation to the handling of your personal information by emailing us at firstname.lastname@example.org and we will respond within 30 days. If we refuse to action your request, we will notify you in writing setting out the reasons.
How is your personal information protected and how long is it kept?
Snug Health takes the security of your personal information very seriously and take reasonable steps to protect it from misuse and loss, unauthorised access, modification or disclosure. The methods we use to ensure this includes the implementation or existence of the following measures:
Your information is kept while we need it to provide the services that you have requested from us and where applicable, we are required to keep it to comply with statutory requirements. Where Snug Health determines it is no longer necessary to hold your personal information we will securely destroy, delete or permanently de-identify that information, wherever possible.
In the unlikely event that security of data is compromised, we will take reasonable steps to confirm any possible breach. If a breach is confirmed, and we form the view that the breach is likely to result in serious harm to you, we will notify you and provide you with a description of the breach, the kinds of information involved, and any recommended actions you could take to protect yourself. We will also notify the Office of the Australian Information Commissioner in accordance with the Privacy Act.
Complaints about your privacy
Snug Health will make every attempt to ensure that your privacy is not breached, however, if you believe that your privacy has been breached or you wish to make a complaint about the way we have handled your personal information, you can contact us at email@example.com or lodge a complaint to the address mentioned below:
The Privacy Officer
Snug Health Pty Ltd
GPO Box 714
Hobart TAS 7001
We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. However, if you believe that we have not resolved the issue you may refer the matter to the Office of the Australian Information Commissioner:
Effective Date: 28 August 2019
1 An eHealth record is an electronic summary of your key health information such as prescribed medications, allergies and treatments you have received. For more information please visit www.myhealthrecord.gov.au