Collection of personal information by us
We will only collect your personal information where it is reasonably necessary for or directly related to the conduct of our functions or activities. We will typically collect personal information in the course of providing our goods and services to customers and in other dealings with those customers and prospective customers. We may also collect personal information as we determine necessary from time to time for any purpose in connection with the general conduct of our business.
Where we collect your personal information we will do so only by lawful and fair means and not in an unreasonably intrusive way.
Where we collect your personal information, and it is reasonable and practicable to do so, we will collect it directly from you. Where it is lawful or practical to do so, you may choose to deal with us anonymously (for example, when enquiring about our goods and services generally).
There may be occasions where we receive or collect personal information about you from a third party.
Kinds of information collected
The kinds of personal information we collect and hold will depend upon the reasons for, or circumstance of, its collection. It may include, amongst other things:
- Your name, together with your contact or address details;
- Other personal information you give us when you request a good or service from us. This information may include: your requirements with respect to specific goods or services; your opinion or preferences with respect to any of our goods or services; or your credit card details, or your preferred payment method;
- Information contained in any communications between you and us;
- Information contained in an application form or other document given to us;
- Transactional information about your acquisition and use of our goods and services;
- Any information we are required to collect by law.
Collection of other information on our website
If you visit our website, some of the information we and/or our contractors collect about your visit to our website is not personal information because it does not reveal your identity. Information of this nature can include:
Site visit information
When you visit our website, we and/or our contractors collect general information about your visit which may include your server address, the date and time of your visit, the pages you accessed, the information you downloaded and the type of Internet browser you used.
We and/or our contractors may use this information in anonymous, aggregated form, for statistical purposes, to assist us in improving the quality and usability of our website.
A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we and/or our contractors use may identify individual users.
Cookies can either be "persistent" or "session" based. Persistent cookies are stored on your computer, contain an expiration date, and are mainly for the user's convenience. Session cookies are short-lived and are held on your browser's memory only for the duration of your session, they are used only during a browsing session, and expire when you quit your browser.
We and/or our contractors may use both session and persistent cookies. This information may be used to personalise your current visit to our and our contractors' websites. Upon closing your browser, the session cookie is destroyed.
Most Internet browsers can be set to accept or reject cookies. If you do not want to accept cookies, you can adjust your Internet browser to reject cookies or to notify you when they are being used. However, rejecting cookies may limit the functionality of our website.
How your personal information will be used
We collect your personal information so that we can use it for or directly in connection with our functions and activities which include, amongst other things:
- Confirming your identity when you contact us;
- Addressing any feedback or complaints you may have;
- Any purposes for which it was requested and directly related purposes;
- Developing, improving and marketing our goods and services.
If you do not provide us with your personal information, we will be unable to do one or more of the above.
We will not collect, use or disclose sensitive information about you unless it is necessary to provide you with a good or service and we have your consent or unless we are legally required to collect, use or disclose that information.
Sensitive information is any information about a person's racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional, trade or political association or union, sexual preferences or practices, criminal record, health information or genetic information about an individual that is not otherwise health information.
Use of your personal information
We collect your personal information so that we can use it for or in connection with our functions and activities which may include, amongst other things:
- Confirming your identity when you contact us;
- Providing you with information about our goods or services;
- Addressing any feedback or complaints we receive from you;
- Developing, improving and marketing our goods and services;
- Complying with relevant laws, regulations and Codes;
- Using your personal information for any other purpose that it was collected for or any related purpose for which we are entitled to use your personal information.
Where we are not able to collect personal information that we require to conduct a particular functions or activities, it may restrict or limit our ability to conduct or perform that function or activity.
Cross Border disclosure of personal data
The LifeClub database and your personal information is held and managed in Australia and New Zealand.
Use and disclosure of personal information by us
If we use or disclose your personal information for a purpose (the "secondary purpose") other than the main reason for which it was originally collected (the "primary purpose"), to the extent required by law, we will ensure that:
- The secondary purpose is related to the primary purpose of collection (and directly related in the case of sensitive information), and you would reasonably expect that we would use or disclose your information in that way;
- You have consented to the use or disclosure of your personal information for the secondary purpose;
- The use or disclosure is required or authorised by or under law;
- The use or disclosure is otherwise permitted by law (for example, as a necessary part of an investigation of suspected unlawful activity).
Disclosure of personal information to third parties
Where permitted by the Privacy Act, personal information we collect about you may be disclosed to third parties as we determine necessary from time to time for any purpose reasonably necessary or directly in connection with the conduct of our business, including, but not limited to:
- Any service provider we engage to carry out our business functions and activities;
- Our professional advisors and other contractors (for example IT consultants and mailing houses);
- Any person who introduces you to us, or who is acting as your referee or guarantor;
- Your authorised agents or your executor, administrator or legal representative;
- An organisation that is an arrangement or alliance with us (for example, for the purpose of promoting or using our respective goods or services or conducting a seminar or promotion);
- Our business associates and others for purposes directly related to the purpose for which the personal information is collected;
- Our related companies;
- Organisations that are involved in a transfer or proposed sale of our business or assets;
- Any entity to which we are required or authorised by or under law to disclose such information (for instance, Federal or State law enforcement agencies and investigative agencies, courts and various other Federal or State government bodies);
- Others that you have been informed of at the time any personal information is collected from you.
Transborder data flows
We will only transfer personal information to someone who is in a foreign country if:
- we reasonably believe that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the Privacy Act;
- you consent to the transfer;
- the transfer is necessary for the performance of a contract between you and us, or for the implementation of pre-contractual measures taken in response to your request;
- the transfer is necessary for the conclusion or performance of a contract concluded in the interest of you between us and a third party;
All of the following apply:
- The transfer is for your benefit;
- It is impracticable to obtain your consent to that transfer;
- If it were practicable to obtain such consent, you would be likely to give it; or
- We have taken reasonable steps to ensure that the information transferred will not be held, used or disclosed by the recipient of the information inconsistently with the Privacy Act.
Security of your personal information
We protect any personal information that we collect and hold about you from misuse or loss. We also protect it from unauthorised access, modification or disclosure. Where we need to disclose your personal information to a service provider or other agent or contractor, we prohibit them from using the personal information except for the specific purpose that we have provided it.
We will take reasonable steps to destroy or de-identify personal information if it is no longer needed for any purpose for which the information may be used or disclosed in accordance with the Privacy Act.
Keeping your personal information up-to-date
We take reasonable steps to ensure that any personal information collected by us is accurate and up-to-date at the time of collecting, using and disclosing that information.
If you learn that personal information we hold about you is inaccurate, incomplete or out-of-date, you should contact us.
You also have a right to request that a statement be attached to your personal information if we disagree with your request to correct the information.
Access and correction of your personal information
You can ask to obtain access to personal information that we hold about you, although under some circumstances permitted by law, we may not provide such information to you. If we are not able to provide you with access to any of your personal information held by us, we will tell you the reasons why this is the case.
We may ask you to put your request in writing and pay a reasonable fee to us before providing requested access.
How to contact us
If you wish to contact us, for example, to access or correct your personal information, you may contact us at:
instigo (FM Integrated Pharmacy Services trading as instigo)
ABN 50 099 858 081
Level 8, 217 Clarence Street
Sydney New South Wales
AUSTRALIA, 2000 Ph: 61 2 9248 2600
Fax: 61 2 9248 2601
If you have a complaint about the way we have dealt with your personal information, please contact us at the above telephone number and ask to speak with our Company Secretary or visit our website mentioned above. We will make all reasonable attempts to respond to your complaints or requests.
If you are not satisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner at:
Phone: 1300 363 992
Further information about the application of privacy law to the private sector generally can be found by contacting the Office of the Australian Information Commissioner (details above).