NEXA GROUP Pty Ltd
(ABN 63 117 799 676) (“NEXA”)
28 August 2019
This privacy statement is issued by NEXA Group Pty Ltd ABN 63 117 799 676 (“NEXA”, “our”, “we” or “us”) and sets out how we manage your information in connection with your access to and use of the platform and services that NEXA makes available to you.
This statement sets out how we handle personal information, including health information, in accordance with the requirements of the Privacy Act 1988 (Cth), the Australian Privacy Principles and other laws that protect the privacy of individuals.
You are a Registered User of a NEXA Product if you have successfully registered as a user of a NEXA Product (Registered User). References in this statement to ‘you’ or ‘your’ refer to the Registered User.
Importantly, you acknowledge and agree that we may collect, hold and share sensitive information about you, including information about your health. Except as otherwise permitted by law, we only collect sensitive information about you if you consent to the collection of the information and if the information is reasonably necessary for the performance of our functions, as described below.
The kinds of information we collect and hold
The types of information we may collect will include:
- your name, contact details (email address);
- usernames or passwords used to access our services;
- health identifiers;
- usage information about your visit to our website and how you use our products and services;
- records of your communications and interactions with us;
- location information; and
- health information.
How we collect your information
We may collect your information in a number of ways, including:
- directly from you or someone caring for you (such as where you provide information to us when you access a NEXA Product or our other websites, complete an application form or enter an agreement for one of our services, or you contact us with a query or request or to resolve an issue you might be facing);
- from our corporate customers, such as health insurers, hospitals or employers, who make the service available to you;
- from your My Health Record, if you or your representative have provided your consent to this, or we are otherwise legally authorised or required to do so;
- if applicable, from the third parties we list in the section of this statement with the heading “When we disclose your personal information”;
- from any data capture which occurs in relation to how you use our products or services; and
- via other automatic data collection, such as your device location information. Some of our applications collect real-time information about the location of your device, as permitted by you.
If you choose not to provide certain information about you, we may not be able to provide you with the services you require, or the level of service on which we pride ourselves. Some services provided by NEXA require you to opt out with the custodian of the data source.
How we hold your information
Details of your information may be stored by a NEXA Product. We may store your information in hard copy or electronic format, in storage facilities that we own and operate ourselves, or that are owned and operated by our service providers. These facilities are situated in Australia.
We take privacy and confidentiality very seriously and we take reasonable steps to maintain the security of your information and to protect it from unauthorised use and disclosure and to ensure that a recipient of your information protects it in accordance with the Australian Privacy Principles.
How we secure your information
NEXA Products are designed with your security and privacy as our highest priority. NEXA understands that your personal information and health details are private and sensitive information and we’ll ensure it is kept that way.
Account and Password Protection
- NEXA Products are designed so any user account is only accessible by you (or in certain circumstances, people you authorise).
- Your account is password and/or pin protected.
- We enforce a strong password policy and non-reversible hashing for storage of passwords.
- All data containing any personally identifiable or health information accessed or stored by NEXA Products is always encrypted at rest and in transit.
- Our security implementation includes strong cryptographic standards.
- NEXA products are subject to various ongoing security programs. For some products, this includes penetration testing and daily security vulnerability testing.
Network, Infrastructure and Hosting
- Our network and infrastructure is designed with security in mind and is hosted in Australian based data centres.
- Our hosting service is certified by the Australian Signals Directorate – part of the Australian Government’s Department of Defence and meets industry standards for physical security and availability.
- The App is registered on your device and accessed using your Account username, password and pin.
- Data is only accessible by authorised users with their unique username, password and pin.
- After a period of inactivity, your Account requires you to login with your username, password and pin again as an additional means of protecting your information.
- All communication between the App and our servers is handled over SSL secure connections. We utilise methods that ensure our App is talking to the servers.
Your system security
You should be aware that your own email may not be secure, so care should be taken with images and information being sent from your system.
How we may use your information
We may use your information for a range of different purposes, including:
- to provide you with, and support the operation and functionality of, our products and services;
- to enable you to view and monitor your information;
- to administer and manage the products and services we provide, to charge and bill for them, and to collect any amounts owing;
- to provide, evaluate and support our products and services, including health records management, secure communications and technology services;
- to provide you with customer service, including to assist you with enquiries;
- to monitor network use, quality and performance, and to operate, maintain, develop, test and upgrade our systems and infrastructure; and
- as otherwise authorised or required by law.
While we also use some application data to gain a better understanding, through analytics programs, of how users utilise our NEXA Products, this is undertaken on an anonymised or aggregated basis only.
When we disclose personal information
We may provide the personal information of our customers and prospective customers (excluding health or sensitive information) to other health professionals and also to third parties who provide services to us, including organisations and contractors that assist us with the purposes for which we use that personal information. These services include:
- customer enquiries;
- information technology and network services; and
- mailing operations.
We may also exchange personal information of our customers and prospective customers where appropriate:
- with our related entities;
- with third party vendors;
- with law enforcement and national security agencies, and other government and regulatory authorities;
- with third parties who assist us to manage or develop our business and corporate strategies and functions, including our corporate risk functions; or
- for the purposes of facilitating or implementing a transfer/sale of all or part of our assets or business.
We may provide information, including sensitive and health information, about you to your usual medical practitioner and their employing or contracting organisation. This will be done subject to your consent and if applicable, the consent of the custodian of the data source.
Where needed we may also provide information about you in referrals to other healthcare practitioners, such as medical specialists, subject to your consent and if applicable, the consent of the custodian of the data source.
Third party contractors
From time to time, we engage third party contractors to provide support services in relation to particular products and services.
Whenever a third party contractor requires access to personal information in order to provide a particular service, we contractually oblige them to protect the confidentiality of such information.
We take the privacy and confidentiality of customer information very seriously, and have implemented a range of measures to protect that information including, depending on the circumstances:
- strict monitoring and access controls regulating which staff can access particular information; and
- network and premises security.
Access to third party services
Connected with NEXA Products, we may provide you with the opportunity to connect to other third party services or products. We do not endorse these third party services or products and you should review their corresponding terms and conditions and privacy policies before using any third party service or product. We accept no liability in relation to third party services or products.
When you use our location-enabled services or appointment check-in functionality, we may collect and process information about your mobile device’s GPS location (including the latitude, longitude or altitude of your mobile device). We do not store this data and it is only used at the time we are providing services to you. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling location-services functions on your device, provided your device allows you to do this.
If you are a customer or prospective customer, we may also use your personal information so that we can promote and market our products and services that we think will be of interest to you on an ongoing basis. This will only be done with your consent and if applicable, the consent of the custodian of the data source.
This marketing may be carried out in a variety of ways (including by direct marketing by mail, telephone or electronic message or by customising on-line content and display advertising on our websites) and may continue for a period after you cease acquiring any products or services from us.
You may opt-out of this type of marketing by following the steps in the marketing communication or contact us using the contact details set out in the “How to contact us” section of this statement.
We do not sell or otherwise provide personal information to unrelated third parties for their direct marketing purposes.
To ensure that we maintain our high standard of care, we may record calls to our service and we will comply with relevant legislation.
We will comply with all relevant legislation governing health records.
How to access or correct your information or make a privacy complaint
If you wish to access any of your information that we hold, or you would like to correct any errors in that information, please contact us using the contact details set out in the “How to contact us” section of this statement, so that we can respond to your request.
You may also use these contact details to notify us of any privacy complaint you have against us, including if you think that we have failed to comply with the Australian Privacy Principles or any binding APP code that has been registered under the Privacy Act 1988 (Cth). While we hope that we will be able to resolve any complaints you may have without needing to involve third parties, you may also be able to lodge a complaint with a relevant regulator such as the Australian Information Commissioner (www.oaic.gov.au or 1300 363 992).
About this statement
This statement is effective as of 19 July 2019. From time to time, we may need to change this statement. If we do so, we will post the updated version on our website https://www.nexa.com.au/privacy and it will apply to the personal information, including health information, then held by us.
How to contact us
If you have any questions in relation to this statement or our management of your personal information, including health information, please let us know by contacting us at firstname.lastname@example.org