INTRODUCTION TO MEMOREHAB
The purpose of this is to be able to communicate to you how MEMOREHAB handles your personal information. We aim to give you a comprehensive understanding of how your personal information is handled.
our products and services as described on the MEMOREHAB Website,
any alternative use or interaction with MEMOREHAB, for example, when you communicate with us via email,
collectively referred to as “Services”.
MEMOREHAB respects your right to privacy and is committed to ensuring the privacy and confidentiality of the information that you provide to MEMOREHAB is protected.
MEMOREHAB is bound by the Australian Privacy Act 1988 (Cth) (“Act”) and is compliant with the Australian Privacy Principles contained within the Privacy Act (“APP”). These forms of legislation govern how MEMOREHAB collects, uses, discloses, stores, and manages your personal information.
You may use our MEMOREHAB Products as:
a Health Care User (as defined under clause 4.1);
an Authorised User (as defined under our terms and conditions); or
a person who was invited by the Health Care User to participate in a rehabilitation program using a MEMOREHAB Product i.e. Health Care User’s patient or non-patient who uses the MEMOREHAB Product by invitation (“Participant”).
WHAT IS PERSONAL INFORMATION?
‘Personal information’ is defined in the Privacy Act and means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
whether the information or opinion is true or not; and
whether the information or opinion is recorded in a material form or not.
‘Sensitive information’ is a subset of personal information and is defined in the Privacy Act and includes health information.
Information which is 'sensitive information' attracts a higher privacy standard under the Privacy Act and is subject to additional mechanisms for your protection.
WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT FROM YOU AND WHY?
If your are a Participant, we may have access to your personal information if our clients, consisting of health care providers, clinicians, and health care research institutions/Universities (“Health Care Users”), have data on you and use our Services. In this case, the Health Care Users will have confirmed that they have received your express consent to share such data with us.
Health Care Users access and use any of our Services via their IT systems, websites, software applications, and other methods.
Because the relevant Health Care Users are the controller of your personal information, Health Care Users are responsible for compliance with the Privacy Act when using our Services.
We are not liable for any information disclosed by Health Care Users because of their usage of any of our Services. It is the duty of the Health Care Users to maintain your privacy rights when we have access to or process your personal information on their behalf.
If you are concerned about your privacy while interacting with a Health Care User’s products and services, you should contact them. If you contact us regarding the information provided to us by Health Care Users, we may forward your requests or inquiries to the relevant Health Care User.
The personal information we collect from Participants is for the use of the Services, among other things, to enable Health Care Users to view personal information in relation to specific Participants and track their progress as they engage in the programs offered by the Services.
The personal information MEMOREHAB collects from a Participant includes information required for the reasonable and necessary carrying out of our Services.
For most Services, it is necessary for us to collect personal information such as, but not limited to:
first and last name, identity details, age, gender, mobile phone number, email address, education level, and other data input requirements by the Services.
Health Care Users’ AHPRA registration ID or any other data relevant to validating registration of Health Care Users and Health Care Users’ association with any organisation/clinic.
payment and billing information when you register for our Services. Information such as designated billing contact details, including name and contact information upon registration. As well as payment information including credit card details, which are secured via payment processing services.
User account details and login identification numbers and location data. Please note that for most devices, you can manage or disable the use of location Services for all applications in the settings menu of your device.
relevant health information such as memory issues, neurological condition and comorbidities as well as the time since the onset of the main neurological condition, to assist in providing the reasonable and necessary carrying out of Services.
information regarding interaction with the application may also be collected to better understand how our Services are being utilised and how we could improve user experience. This information includes but is not limited to time spent in rehabilitation exercises, number of logins, materials viewed within the application, and video conferencing sessions attended.
HOW DO WE COLLECT PERSONAL INFORMATION?
In general, MEMOREHAB may collect your personal information from you directly for the reasonable functioning of MEMOREHAB’s business activities, its administrative and internal business purposes including for the provision of MEMOREHAB’s Services (as further described on the MEMOREHAB Website) (“Primary Purpose”) unless consent has been given to receive it from another party or for another purpose.
As part of the acceptance of our terms and conditions in the application, you provide us with express consent to collect your personal information for the following reasons:
We collect your personal information directly from you:
as the user of our Services when you input it into the Services or otherwise provide it directly to us including when interacting with the MEMOREHAB Website, when you provide feedback or when you participate in any interactive features, group-based memory rehabilitation programs with other users, questionnaires, activities or events.
when you register for an account, create or modify your profile, set preferences, including billing information.
where we collect and store content that you post, send, receive and share.
when you visit, use or interact with our Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of MEMOREHAB’s Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.
We collect your personal information from others:
Other users of our Services may provide information about you when they submit content through the Services, for example when users exchange information on group-based memory rehabilitation programs.
Health Care Users provide us with personal information when using the
Services as referenced under clause 4.1 (for example when they invite you to use our Services. In those cases, you as a Health Care User warrant to us that you are acting under the Participant’s direction or with the Participant’s express consent to share Participant’s personal information with us).
HOW DO WE USE YOUR PERSONAL INFORMATION?
Your personal information will be utilised for the reasonable and necessary purpose to carry out of our Services.
We use personal information for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, to enter into or perform a contract with you, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
Specifically, we use personal information for the following purposes:
to track your rehabilitation process if you are a Participant.
for analytics purposes, however, given the importance of personal information being confidential and secure, this will be done in a de-identified format (i.e. a person’s identity is no longer apparent or cannot be reasonably ascertained from the information or data) for the purposes of improving the delivery of rehabilitation or improving the functioning of our Services. Your information may also, with your consent, be used for research purposes with universities as part of research projects to study, compare and analyse Participant outcomes.
to facilitate, operate, and provide our Services.
to authenticate the identity of our user and to allow them to access our Services.
to provide our users with assistance and support.
to gain a better understanding of how users use our Services, and how we could improve their experience, and continue improving our Services.
to ensure we receive payment of any fees owing to us or third parties.
to facilitate and optimise our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our Services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, thereby increasing your engagement and
overall satisfaction with our Services.
to contact our users (whether existing or prospective) with general or personalised service-related messages, as well as promotional messages that may be of specific interest to them;
to post testimonials on the MEMOREHAB Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update or delete your testimonial, please contact us at email@example.com and be sure to include your name, testimonial location, and contact information.
MEMOREHAB may use personal information not required for the Primary Purpose but for another purpose (known as the “secondary purpose”):
where you would reasonably expect the secondary use or disclosure, which is related to the Primary Purpose of collection or, in the case of sensitive information, directly related to the Primary Purpose. The ‘reasonably expects’ test is an objective one that has regard to what a reasonable person, who is properly informed, would expect in the circumstances. This is a question of fact in each individual case. It is MEMOREHAB’s responsibility to be able to justify its conduct. As a general rule, MEMOREHAB will only use or disclose the minimum amount of personal information sufficient for the secondary purpose.
where you have consented for us to use your personal information for another purpose;
where we are required or authorised by law to disclose your information for another purpose;
where our disclosure of your personal information will prevent or lessen a serious and/or imminent threat to somebody's life, health or safety or to public health or public safety; or
where our disclosure is reasonably necessary for the enforcement of a criminal law or
a law imposing a penalty or sanction, or for the protection of public revenue.
for clinical trials relevant to your medical condition. We may use your personal information to assess your suitability for participation in the clinical trial to provide you with initial information about the clinical trial. Other than as authorised by law, we will not disclose your personal information to the clinical trial researcher without your consent.
WHERE IS YOUR PERSONAL INFORMATION STORED?
The personal information which you give to us is stored electronically. Our cloud-based service providers will store personal information in Australia.
There may be certain instances where information processing may occur outside of Australia or our data base. Where this occurs, we take steps to protect the security and integrity of your personal information and is only done so in specific circumstances, with your consent.
WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?
Your personal information may be disclosed as part of our Services for the following reasons:
when you willingly disclose your personal information to other users (i.e. Participants) in connection with the use of the Services s (such as in group-based memory rehabilitation programs as part of the Services). Otherwise, personal information will be de-identifiable so as to protect privacy and confidentiality.
Your personal information will also be disclosed to your referring Health Care User for the use of the Services so that the Health Care Users are fully aware of your personal situation and can treat your rehabilitation accordingly. Your referring Health Care User will have access to any information posted willingly by you and other users in connection with the Services.
Your personal information may also, as previously mentioned, be disclosed to universities or other research institutions for the purposes of research or clinical trials where you have consented to such research being conducted.
More specifically, we may need to share your personal information in the following situations:
in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the MEMOREHAB Websites, which will enable them to collect data on our behalf about how you interact with our MEMOREHAB Products over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it.
with third-party advertising companies to serve ads when you visit or use our MEMOREHAB Websites. These companies may use information about your visits to our MEMOREHAB Websites and other websites that are contained in web cookies and other tracking technologies to provide advertisements about goods and services of interest to you.
with our business partners to offer you certain products, services or promotions.
IS YOUR PERSONAL INFORMATION TRANSFERRED INTERNATIONALLY?
No. Your personal information will be kept on servers within the country relevant to you, except in circumstances where de-identified information may be accessed by our personnel and advisors in other countries.
HOW CAN YOU SEEK ACCESS OR CORRECTION OF YOUR PERSONAL INFORMATION?
You may access your personal information that we have stored upon request. If, upon receiving access to your personal information, you believe the information is incorrect, or you seek correction, please notify us as soon as practicable so we can take reasonable steps to correct your information to ensure it is up to date.
COMPLIANCE WITH THIS POLICY
Our compliance with this policy is mandatory under legislation, and any breach of this policy may result in disciplinary action being taken.
REVIEW OF POLICY
HOW CAN YOU CONTACT MEMO MEMORY REHABILITATION?
Or you may make a complaint to the Office of the Australian Information Commissioner ("OAIC") at :
Office of the Australian Information Commissioner,
GPO Box 5218 Sydney NSW 2001
Telephone: 1300 363 992
Any other information you may need will be available on our website at: