We are committed to protecting your personal information and we comply with the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth). The APPs regulate the way that organisations can collect, use, keep, secure and disclose personal information. It also gives individuals the right to know what information an organisation holds about them and a right to correct that information if it is wrong. Personal information includes any information or opinion, whether true or not, about a person who is identified or whose identity can reasonably be established.
1. Collection and Storage of Personal Information and Data
We may collect personal information about individuals. Our usual approach is to collect personal information directly from the individual concerned.
For example, we collect personal information in circumstances including:
- when an individual visits the “Modeus” Website and sends an enquiry through our site or through an email;
- when goods or services are ordered using a credit card or method other than cash;
- when an individual telephones or emails or meets with one of our representatives;
- when you (whether on your own behalf or on behalf of another business) enter into an agreement with us for the supply of goods or services (either from us or to us);
- when you telephone us, visit our website or meet with us and make an enquiry to which a later response is requested and to do so requires your contact details;
- when you ask to be included on email or hard copy marketing distribution lists or interact with us through social media platforms; and
- when evaluating job applicants and personnel, including their contact details, employment history and educational qualifications.
Modeus holds personal information using third party cloud based systems under accounts exclusively controlled by us, and/or on Modeus’ internal IT systems. Modeus maintains appropriate physical, procedural and/or technical security for its offices, information storage facilities and use of third party provider services, so as to prevent any misuse, interference or loss, or unauthorized access, disclosure, or modification of personal information.
2. Use of Personal Information
We use the personal information collected from you for the purpose it was provided or collected (as indicated above), including in the following ways:
- to respond to enquiries received from you;
- to process, confirm, fulfil and update you about your orders and to carry out our obligations arising from any contracts entered into between you and us;
- to perform authorised financial transactions with you;
- to communicate with you and provide you with information (whether by email, post or other means) about our products or services, where you have requested or consented to receiving this from us or where this provision is otherwise permitted under the Australian Privacy Principles;
- to notify you about changes to our goods and services;
- to receive and address feedback or complaints from you; and
- to protect our legal interests and fulfil our regulatory and tax obligations (if and to the extent necessary).
All customers and others with whom we interact have the option to opt-out of receiving marketing communications from us. If you do not wish to continue to receive electronic marketing communications from us and/or selected third parties you should opt-out by clicking on the “unsubscribe” link in any email communications that we might send you.
3. Disclosure of Personal Information
We may provide personal information to third parties outside Modeus for limited purposes, such as to help us in providing goods and services to customers.
Those persons and businesses may include:
- organisations who carry out credit, fraud and other security checks;
- couriers and delivery businesses (where we arrange to deliver goods to you
or persons you have requested us to send deliveries to); and
- marketing businesses engaged by us to disseminate materials to which
recipients have consented (if applicable).
In addition to the above parties, some of our services allow customers to store and maintain health-related information of individuals. This information can include:
- medication supplied to individuals (for example, types of drugs consumed and quantities); and
- personal contact details (including addresses and dates of birth).
Occasionally, Modeus may be required to disclose some or all of this information to the relevant public health authorities (in most cases, this will be the relevant government health department (either state or federal)). Those authorities may need this information in order to monitor our customers’ compliance with the relevant laws and regulations to which they are subject.
We will notify you before we disclose information in the manner described above, unless the relevant authority asking for the information has legally instructed us not to notify you.
We may also disclose your personal information to third parties:
- where we have your express permission to do so;
- where it can reasonably be inferred from the circumstances that you consent to the disclosure to the third parties;
- if we or substantially all of our assets are acquired by a third party, in which case personal information which we hold about our customers may be one of the transferred assets (subject to the same constraints on use and disclosure as under this policy); and
- if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation, in order to enforce or apply our terms and conditions, or to protect our rights, property, or safety of that of our personnel or customers. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We limit the information we provide to third parties to the information they need to help us provide or facilitate the provision of goods and services to you. We deal with third parties that are required to meet the privacy standards required by law in handling your personal information, and use your personal information only for the purposes that we gave it to them.
We will not disclose personal information to businesses or persons located outside Australia, unless you ask us to do so.
4. Security of personal information
We take all reasonable steps to protect your personal information, including internal and external security, restricting access to personal information to those who have a need to know, maintain technological products to prevent unauthorised computer access and regularly reviewing our technology to maintain security. We use secured IT systems.
5. Questions and concerns and access to/ correction or updating of your personal information
You have a right to access the personal information we hold about you and to raise concerns or complaints or ask for corrections. To raise privacy concerns, including to obtain a copy of the personal information we hold about you, please write to us at:
Information Security Manager
Please provide sufficient detail about the personal information in question to help us locate it. We will then use commercially reasonable efforts to promptly determine if there is a problem and take the necessary corrective action within a reasonable time.
You can find further information on privacy and about the APPs at the Office of the Australian Information Commissioner – http://www.privacy.gov.au/.
Last update: 18 September 2018