About this policy
This policy covers:
- the kinds of personal information Carpe Vitae collects and hold;
- how Carpe Vitae collects personal information;
- how personal information is secured and stored;
- the purposes for which Carpe Vitae collects, holds, uses and discloses personal information;
- any direct marketing Carpe Vitae may engage in, and your right to anonymity;
- utilizing Carpe Vitae’s website;
- how you may access your personal information and how you may seek to correct any errors in information held;
- how you may make a complaint and the process Carpe Vitae will take to investigate and resolve that complaint; and
- whether Carpe Vitae is likely to disclose personal information to overseas recipients, and if so, the countries any such recipient is located.
What is personal information?
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identified, whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not (personal information).
1. THE KIND OF PERSONAL INFORMATION CARPE VITAE COLLECTS
Carpe Vitae holds personal information such as: full name, address and contact details (i.e. telephone, email, and postal address).
2. HOW DOES CARPE VITAE COLLECT PERSONAL INFORMATION?
Personal information is collected in the following ways:
- electronic forms submitted via the Carpe Vitae website;
- face to face interactions;
- phone calls; and
3. SECURITY AND STORAGE OF INFORMATION
a) Our commitment
Carpe Vitae places a great importance on the security of all information associated with our clients and others who deal with us. We have security measures in place to reasonably protect against the loss, misuse, unauthorised access and alteration of personal information and other data under our control.
b) Security and storage methods
All personal information and other data held is kept securely and that which is held electronically is held on secure servers in controlled facilities.
Personal information is de-identified or destroyed securely when no longer required by us.
Information stored within Carpe Vitae’s computer systems or by our agents who provide electronic storage facilities can only be accessed by those entrusted with authority and computer network password sanctions.
Carpe Vitae consults with IT service providers to implement reasonable levels of firewall, malware detection and data security procedures.
c) Electronic transmissions
No data transmission over the internet can be guaranteed to be absolutely secure. As a result, whilst we strive to protect users’ personal information (including personal information), Carpe Vitae cannot ensure or warrant the security of any information transmitted to it or from its online products or services, and users do so at their own risk. Once Carpe Vitae receives a transmission, we make every effort to ensure the security of such transmission on our systems.
4. THE PURPOSE FOR WHICH WE COLLECT, HOLD AND USE PERSONAL INFORMATION
To enable us to fulfil our responsibilities, we collect personal information about you to enable us to effectively conduct our business.
The personal information we collect may be used as follows:
- we may collect the following types of information: your name, address, phone, email, full bank account details and/or credit card numbers that you link to your account or input when you use our services. We will use this information to communicate with you regarding the services; and
- whenever you contact us or respond to our communications (e.g., letters, email, telephone), we receive your contact information and any other personal information you choose to provide us. We will use such information to fulfil your requests or if you are our customer or the personnel of customers, or our supplier or personnel of suppliers, we will use this information in connection with the services or supply.
We will only collect personal information and/or personal data to the extent that it is required for the specific purposes set out in this policy or notified to you at the time of collection.
5. DIRECT MARKETING
a) We may carry out direct marketing
As part of Carpe Vitae’s functions and business activities and to promote the services we can provide, Carpe Vitae may be permitted to use personal information about individuals that individuals have provided to Carpe Vitae for the purposes of direct marketing. Direct marketing includes, but is not limited to, sending information to and/or contacting individuals in relation to promotions.
b) Opting out of direct marketing
All recipients, including individuals, can opt out of receiving direct marketing communications by sending an email to the Carpe Vitae’s Privacy Officer, at the email address shown in the ‘Contact’ section of this policy.
In any direct marketing communication, we remind recipients of their right to opt out of receiving direct marketing communications.
6. WEBSITE AND LINKS
a) Carpe Vitae website
Carpe Vitae carries on business through https://carpevitae.life.
b) Website terms and conditions
Carpe Vitae website collects personal information pursuant to this policy except as otherwise stated on the website.
A website may display additional terms and conditions for access and use of the website which apply in addition to this policy.
7. ACCESS TO, AND CORRECTION OF PERSONAL INFORMATION
a) Our commitment
Carpe Vitae is committed to and takes all reasonable steps in respect of maintaining accurate, timely, relevant, complete and appropriate information about our customers, clients and website users.
b) Access to information
Any individual may request access to personal information (including personal information) about them held by Carpe Vitae. Such a request for access to personal information is to be made to Carpe Vitae’s Privacy Officer, whose details are set out below.
Carpe Vitae will respond to any requests for access or correction within a reasonable time of receipt of the request, but by no later than 30 days of the request being received.
Please note that Carpe Vitae does require that, as part of any request by an individual for access to personal information (including personal information), the individual verify their identity so that Carpe Vitae may be satisfied that the request for access is being made by the individual concerned.
Please note that Carpe Vitae is not required to give an individual access to personal information about them in circumstances where:
i. giving access would be unlawful; or
ii. denying access is required or authorised by or under an Australian law or a court/ tribunal order; or i
ii. giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
If we refuse to provide an individual with access to their personal information or to correct the personal information held by us about them, then we will provide reasons for such refusal. Such reasons will set out the grounds for refusal, the mechanisms available to complain about the refusal and any other matters that are required by the Act.
c) Correction of information
Inaccurate information will be corrected upon receiving advice to this effect. To ensure confidentiality, details of an individual’s personal information (including personal information) will only be passed on to the individual if we are satisfied that the information relates to the individual.
From time to time, and having regard to the purpose of the collection and use of personal information (including personal information) about individuals, we may contact individuals to seek confirmation that the personal information provided to us by the individual is accurate, up-to-date and complete.
a) Making a complaint
If an individual has a complaint about this policy or/or Carpe Vitae’s collection, use or safe disposal or destruction of personal information about the individual, any complaint should be directed in the first instance to Carpe Vitae’s Privacy Officer at the contact details set out in the ‘Contact’ section of this policy.
b) Investigation and resolution procedure
Upon receiving a complaint, we will, within seven days, give the complainant written notice acknowledging receipt of the complaint and setting out the process of how we will deal with it.
We aim to resolve all complaints within 30 days of receipt. If we cannot resolve a complaint within 30 days we will notify the complainant of the reasons and specify a date when we expect a decision or resolution will be made and seek the complainant’s agreement to extend the 30 period – if the complainant does not agree then we may not be able to resolve the complaint.
It may be necessary (and it may be required by the Act), in order to deal with a complaint, to consult with a CRB or another credit provider. Further, if, while a complaint remains unresolved, we are disclosing information subject to the complaint to a third party, we may be required to advise the third party about the complaint.
If we find a complaint is justified, we will resolve it and do what is required to rectify any breach. Carpe Vitae are committed to fulfilling its obligations as an APP entity and a credit provider under the Act.
The complainant may refer their complaint to the Office of the Australian Information Commissioner. The website for the OAIC is: www.oaic.gov.au
9. TRANSFER OF INFORMATION OVERSEAS
a) Use of cloud services
Carpe Vitae may utilise local cloud services for the purpose of storing information. Your personal information may be disclosed to Carpe Vitae’s cloud service provider for that purpose. Carpe Vitae’s cloud service providers are located in Brisbane, Australia at the time of this policy being published.
b) Other disclosures
Except as provided in clause 9, Carpe Vitae are unlikely to disclose personal information of an individual to overseas recipients. Personal information will only be disclosed by Carpe Vitae to overseas recipients in accordance with Australian Privacy Principle 8, such as if the disclosure is required by Australian law.
10. CHANGES TO POLICY
If Carpe Vitae decides to or are required to change this policy, we will notify you of such amendments on our websites and post changes on this policy webpage so that users may always be aware of what information is collected by us, how it is used and the way in which information may be disclosed. As a result, please refer back to this policy regularly to review any amendments.
For concerns, complaints or further information regarding this policy and our policies and procedures regarding privacy and data security, please contact us at the following address:
Position: Rosalind Wilson, Carpe Vitae’s Privacy Officer
Post: Carpe Vitae Pharmaceuticals Pty Ltd, 3 Grant Street Cleveland QLD 4163 Australia