The Institute Of Health Privacy Policy

Respecting Your Privacy

Your privacy is important to The Trustee for Carter Family Trust trading as The Carter Institute (We, Us or Our). This privacy policy sets out how We collect, hold, use and disclose your personal information.

By interacting with Us (including enrolling in Our courses or creating an Account with Us), or otherwise providing your personal information to Us, you consent to Us collecting, storing, using and disclosing your personal information in accordance with this policy, or as otherwise disclosed by Us at the time of collection.

We may amend this policy from time to time, and the most current version will be published on Our website. Your continued interaction with Us (including participating in Our courses or using Your Account) or your provision of further personal information to Us once this policy has been amended, will constitute your acceptance of the amended policy.

This policy should be read together with Our Terms, where they have been made available to you.

Collection

The personal information We collect and hold about you will depend on the nature of your interaction with Us, including whether you are a prospective, current or past student. The information will generally include your name and contact details (such as your phone number, address and email address) and any other personal information you provide Us (such as your gender, date of birth, occupation, activities and interests). If you enrol in Our course, the information will also generally include your financial details (such as credit card or bank account details) and your feedback and opinions. We may also collect health information about you (which is “sensitive information” under Australia’s privacy laws). However, We will only collect health information about you with your consent and if it is reasonably necessary for Us to do so, or where We are otherwise authorised by law.

Generally, We collect personal information directly from you. This may occur in a number of ways, including:

• when you enquire about, or enrol in, one of Our courses;
• when you request a consultation with Us;
• when you create an Account with Us;
• when you attend one of Our events;
• when you download Our resources;
• when you click on one of Our online advertisements;
• when you send Us an enquiry or provide feedback to Us, for example, by email or through Our website or social media accounts;
• if you sign up to one of Our mailing lists;
• when you fill out polls or surveys on Our website;
• when you agree to participate in a study We are conducting or in which We are involved; or
• when you otherwise communicate or interact with Us by telephone, email or on Our website or social media accounts.

Sometimes We collect personal information from a third party or from a publicly available source, but only if you have consented to your information being used in this way, or would reasonably expect Us to collect it in this way. We only collect this information from companies or sources that are allowed to disclose it to Us.

You do not have to provide your personal information to Us if you do not wish to, but if you do not provide all the information We request, We may not be able to provide you with the services or information you have requested.

Accounting Software and Credit Card Processing Providers

We use accounting software and credit card processing providers such as Stripe and Xero to process your payments through Our website and to store your financial details. These providers may be located overseas, in Ireland or other countries. These providers will handle your personal information in accordance with their own privacy policies. The information they collect may include (among other things) your name, email address, billing address, shipping address, payment method information (such as credit or debit card number, bank account information or payment card image selected by you), merchant and location, purchase amount, date of purchase, information about what you have purchased, your phone number, and other information to verify your personal information or identity. Where you provide the information directly to our provider, some of that information (for example, what you have purchased) will be provided by them to Us. You can access the privacy policies for Stripe and Xero on their websites.

Social Media and Communication Services

We also use social media and communication services such as Facebook, Instagram, YouTube, LinkedIn, Apple Podcasts and other podcast channels to communicate with the public about Our goods and services. The social networking and communications service will also handle Your personal information for its own purposes. These services have their own privacy policies. You can access the privacy policies for Meta Platforms, Inc. (covering Facebook and Instagram), YouTube, LinkedIn, Apple Podcasts and other podcast channels on their websites.

Your Online Activity

We may also collect data from you by using ‘cookies’, which are small data files deposited by Our website on your phone, computer, or other device, that allow Us to track your use of Our website. Cookies are sent back only to the servers that deposited them when a visitor returns to the relevant site/page. We use cookies to make Our website easier to use and to provide a better, more customised service. With the information We receive through cookie technology, We also hope to improve Our website and your experience.

In addition, We may gather information about you that is automatically collected by Our server, such as your IP address and domain name. We may use this information to customise Our offerings, to make information more readily accessible to you, and to make Our website easier for you to use.

Cookies can be accepted or disabled at your preference. If you disable the use of cookies, please bear in mind that this may affect how some items are displayed on Our website.

Providing Personal Information of Others to Us

You must not provide Us with personal information about any other individual unless you have the express consent of that individual to do so. If you do provide Us with such information, before doing so, you:

must tell that individual that you will be providing their information to Us and that We will handle their information in accordance with this privacy policy;
must provide that individual with a copy of (or refer them to) this privacy policy; and
warrant that you have that individual’s consent to provide their information to Us.

Use of Your Personal Information

We use the personal information We collect for the purposes for which it is collected and for other related purposes, and as permitted or required by law. Our general purposes may include:

to provide the services you request, and to administer and manage those services;
to communicate with you, including where We are required to provide notice to you under Our Terms;

• to respond to your enquiries or requests for assistance from Us;
• to verify ownership of the email address provided when you create an Account with Us;
• to verify your identity;
• to provide information to you about improved or additional services that might be of interest to you;
• to send marketing material to you;
• to improve and develop Our website or Our courses; and
• to otherwise facilitate Our business operations and processes.

We may also use your personal information to deliver advertising which is more customised or relevant to your interests or location. This does not mean that you will receive more ads, it just means that We will do Our best to make them relevant and tailored to your interests.

Disclosure of Your Personal Information

Generally, We will obtain consent before We disclose any personal information other than as specified in this policy. Such consent may be given expressly or it may be implied by conduct.

Your personal information may be disclosed to:

• Our related entities and representatives for Our business purposes only;
• Our independent contractors and other third parties to enable Us to provide Our services, and otherwise, comply with Our obligations under Our Terms;
• Our third party service providers to permit them to provide services to Us such as hosting services, provision of infrastructure, IT services, data analysis, email delivery services, customer services and other similar services;
• Our external advisers and service providers who have been engaged to provide Us with legal, administrative, financial, insurance, research, marketing or other services;
• other parties as permitted or required by law or as We believe to be appropriate: (1) to enforce Our Terms; (2) to protect Our operations or those of any of Our related entities; (3) to protect Our rights, privacy, safety, confidentiality, reputation or property and/or that of Our related entities, you or others; (4) to prevent fraud or cyber-crime; (5) to permit Us to pursue available remedies or limit the damages that We may sustain; and (6) in connection with a merger or sale involving all or part of Our business;and
  any other person authorised, implicitly or expressly, when the personal information is provided to or collected by Us.
• We reserve the right to disclose any personal information to law enforcement or other government officials where We reasonably believe that this may be necessary or appropriate.

We will never sell, trade, lease or rent your personal information to third parties.
Some of the third parties to whom we may disclose your personal information may be located outside Australia or may hold your data on servers located outside Australia. Those third parties may be located in the United States of America, New Zealand, or other countries. If we disclose personal information to a third party located overseas, we will take reasonable steps to ensure that the recipient will handle the personal information in accordance with the Privacy Act 1988 (Cth).

Direct Marketing

As indicated above, We may use your personal information to send you marketing material, including advertising that is customised to your interests, characteristics or general location.

Opt-out: If you prefer not to receive marketing communications from Us, you can opt out by contacting Us using the contact details below. For direct marketing correspondence that you receive from Us via email or other electronic means, there will be an unsubscribe button or link which you can use to manage which messages you receive from Us.

Data Security

We take the security of your personal information seriously. We take reasonable steps to protect the personal information We hold against loss, unauthorised access, use, modification or disclosure, and against other misuse.

When no longer required or when requested by you, We will take reasonable steps to destroy, delete or permanently de-identify personal information in a secure manner.

Access and Correction

You may request access to the personal information We hold about you by contacting Us using the contact details below. We will process such requests within a reasonable time. If We deny an access request as permitted or required by law, We will provide reasons for doing so.

We will take reasonable steps to ensure the personal information We hold about you is up to date and accurate. Please let Us know promptly if any changes are required to be made to the personal information We hold about you by contacting Us using the contact details below.

You may ask Us at any time to correct personal information We hold about you. On request, We will take reasonable steps to correct the information so that it is accurate, complete and up to date, or will provide reasons for not doing so.

Complaints Handling

If you wish to make a complaint about a breach of this policy or the Australian Privacy Principles, you can contact Us using the contact details below. You will need to provide sufficient details regarding your complaint, together with supporting evidence and information. We will investigate your complaint and determine what steps We need to take to resolve your complaint. We will contact you if We require further information from you, and will notify you in writing of the outcome of Our investigation.
If you are not satisfied with Our determination, you can contact Us to discuss your concerns or contact the Australian Privacy Commissioner through its website at www.oaic.gov.au.

How to Contact Us

If you have any questions or concerns about this policy or Our practices you may contact Us using the following details:

Email: hello@carterinstitute.com

Version No: 1
Date: 3 November 2022