1. Who are we?
Epi-Minder Pty Ltd ACN 616 831 684 (“Epiminder”) is driven by the desire to find a solution for those living with epilepsy, to give them a greater sense of control over their condition and free them from the significant limitations and anxieties that come with epilepsy.
2. Our commitment to privacy
We will review this policy regularly, and we may update it from time to time to ensure we are complying with any legislative changes and reflecting our changing business activities.
3. What kinds of personal information do we collect?
The kinds of information we collect will depend on the nature of our relationship with you, and how we engage with each other.
In this policy, “personal information”:
- refers to information from which a person’s identity can reasonably be ascertained. This information may include information or an opinion about you; and
- includes “Health information”, which is personal information regarding someone’s physical or mental health. It includes information or an opinion about your medical history, your current state of health and symptoms which you are experiencing.
We may collect Personal Information about you, including:
- identity information such as name, title, company name, job title, gender and date of birth;
- contact information, including email and/or postal address, telephone number(s);
- employer details and business address (if you are an individual employed by or representing an organisation with whom Epiminder is doing business);
- your work history and qualifications (if you contact us about employment opportunities or your work history with us); and
- technical and usage information, being details of your visits to this website or our physical premises, including traffic data, location data, website usage, IP address and other communication information.
We may collect health information about you:
- when discussing your possible participation in a clinical investigation being sponsored by us,
- during your participation in a clinical investigation; and
- as agreed with you after your participation in a clinical investigation.
4. How do we collect your personal information?
Generally, we will collect this information directly from you. We may also:
- (in connection with your possible or actual participation in a clinical investigation) collect information from family members or carers, or health professionals involved in your treatment.
- (where you are nominated as an emergency contact person) collect your contact information from a person who is considering, participating in or a former participant in a clinical investigation.
If we need to get information from persons other than these, we will ask your permission to do so.
We may collect this information through a variety of ways including completing of forms (including on our website, or via iPad or tablet), telephone, email, or SMS. If you are participating in a clinical investigation, we may collect information through:
- consent forms;
- the recording function of the Minder® investigational device; and
- photographs and CT scans taken in the course of or after the clinical investigation.
5. Why do we collect and use your personal information ?
We collect and use your personal information for purposes related to our business activities. We collect your personal information when you interact with us including when you:
- apply for a job with us;
- request information about our clinical investigations;
- communicate with us as a representative of a provider of goods or services or of a customer;
- attend our educational events;
- participate in our clinical investigations;
- report complaints, adverse events or other quality events involving a Minder product; or
- contact an Epiminder representative for the return of a Minder product
We use your personal information to conduct our business including when we:
- respond to your inquiries;
- update software running on your Minder products;
- conduct educational events;
- consider job applications;
- improve and develop our products and services;
- analyse clinical investigation outcomes;
- report on clinical investigation outcomes or adverse events to therapeutic goods regulators; or
- review and manage your returned Minder product
We may also share de-identified information from clinical investigations with other parties for the purpose of research and publications.
6. With whom do we share your personal information?
We may disclose your personal information to:
- third party providers of goods or services (including product suppliers, logistics companies, professional advisers, insurers and auditors) engaged to assist us with conducting our business activities;
- entities such as government bodies, regulators, law enforcement agencies and other parties where authorised or required by law, and other parties to which we are legally required to disclose your personal information; and
- parties identified at the time of collecting your personal information (for example, in consent forms for participants in clinical investigation of the Minder device) or as otherwise authorised by you from time to time.
Due to legislative requirements or a court order (e.g. subpoena), we may be required to disclose information about you to therapeutic goods regulators, law enforcement bodies or other parties without your prior knowledge or consent. Subject to any legal constraints, we will use reasonable steps to let you know of these requests.
7. How do we store and protect your personal information?
We will take all reasonable steps to keep secure and protect any Personal Information which we hold about you, including:
- Securing our physical premises and digital storage media; and
- Placing password protection and access control over our information technology systems and databases to limit access and protect electronic information from unauthorised interference, access, modification and disclosure.
Data which is collected by our Minder investigational device is stored and processed in a secure cloud server based in Melbourne, Australia.
Please note that we cannot eliminate security risks associated with the storage and transmission of personal information (including transmission of information via the Internet).
We use “cookies” to enhance functionality and to keep track of visits to our website.
A cookie is a small data file that contains information about your visit to a website. Your computer provides this information, including your IP address, during your first visit to a web server. The server records this information in a text file and stores this file on your hard drive. When you visit the same website again, the server looks for the cookie and structures itself based on the information provided. A cookie only identifies your computer to a web server when you visit the site.
If you visit our website to browse or download information, our web server will record the date and time of your visit to our site, the pages viewed and the information downloaded. We generally use this information for statistical purposes.
If your browser is configured to reject all cookies, you will be unable to use services on the website that require cookies in order to participate. You may still be able to use some information-only pages if you do not accept cookies.
9. Links to other sites
10. How can you access and correct your personal information or make a complaint?
If you wish to access or correct the personal information we hold about you, or you have a complaint about the way we handle your personal information, please contact our Privacy Officer (firstname.lastname@example.org).
We will endeavour to resolve complaints quickly and informally, if you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Privacy Officer, by email as above. We will investigate your complaint and endeavour to resolve it within a reasonable period, not usually exceeding 30 days.
If you consider that we have not dealt with your complaint adequately, you may escalate the matter to the Office of the Australian Information Commissioner:
11. Associated References
1. Privacy Act 1988, N0. 119, Federal Register of Legislation