Disclaimer and General Privacy Policy

1. Our Privacy Commitment

Medtech Healthcare Pty Ltd ACN 095 303 781 and its related companies (Medtech, we, us, our) are committed to being open and transparent about how we manage your personal information.

Our Privacy Policy aims to communicate, in the clearest way possible, how we treat your personal information. We encourage you to read this Privacy Policy carefully. It will help you make informed decisions about sharing your personal information with us.

At Medtech, we have a few fundamental principles:

• We will always collect, store, use and disclose personal information in accordance with all applicable privacy laws. However, we have also put in place this Privacy Policy to protect the personal information you submit or we collect.
• We will only use your personal information when it is necessary for us to deliver you our services or perform other necessary business functions and activities.
• We will not use or disclose your personal information for purposes unrelated to our business activities and the services we provide unless we first obtain your consent.

2. Privacy Policy

This Privacy Policy sets out how we comply with our privacy obligations to those persons with rights under the Privacy Act 1988 (Australia), including those whose personal information is received through our website and Insight (customer portal).

We are bound by the requirements of those laws, which regulate how we may collect, store, use and disclose your personal information. Those laws also specify other requirements, such as how individuals may access, correct and delete information held about them.

When we say “personal information” we mean information or an opinion about an identifiable individual, or in individual who is reasonably identifiable, whether true or not, and whether or not recorded in a material form: for example, your name, email, address, telephone number, work experience, qualifications and so on. When we say “sensitive information” we mean: (a) personal information about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, membership of a professional or trade association or trade union, sexual orientation or practices, criminal record; or (b) health or genetic information.

When you use our services or otherwise provide your personal information to us, we will – if necessary – seek your consent to our collection, storage, use and disclosure of your personal information (including any sensitive information you provide) in accordance with this Privacy Policy and any other consents/disclosure statements we make available to you at the time.

3. Changes to this Privacy Policy

We may amend the terms of this Privacy Policy from time to time and will notify you of any changes by posting an updated version on our website or by sending you a notice via email. It is your responsibility to keep your email address current.

4. WHAT INFORMATION DO WE COLLECT?

Information you provide to us directly: Our usual practice is to collect personal information directly from you, when you complete any form, including online forms, register to use our services, provide any other information in connection with your use of our services, or otherwise interact with us, for example as a professional contact or as a job applicant. A few examples include:

• Personal details: given name(s); customer account details (such as your customer number, password and customer name).
• Demographic information: gender; date of birth; age; nationality; title; language.
• Contact details: correspondence address; telephone number; email address.
• Services: information relating to the goods or services that you wish to obtain.
• Consent records: records of any consent you may have given and the subject matter of that consent.

Information we get from third parties: We collect or obtain personal information from authorised third parties (e.g. administrators of our services, medical practice managers or any parties we engage to assist us with functions such as mail-outs or to assist us to provide our services).

Information we collect automatically: We may collect personal information about you automatically when you visit our websites or use our services, like your IP address and device type. Some of this information may be collected using cookies and similar tracking technologies.

Information we create in the performance of the services: We may also create or obtain personal information, such as evaluative records about your interactions with us. Evaluative information may be confidential to us.

You can always choose not to provide your personal information to us, but it may mean that, if you are a customer, we will be unable to provide you with our services and if you are dealing with us in another capacity, we will be unable to do what we were intended to do.

5. HOW IS YOUR PERSONAL INFORMATION HANDLED?

Where we collect personal information (including sensitive information), we will only handle it:

• to perform our services or, where we collected the personal information for another purpose, for that purpose; or
• for a related secondary purpose (or in the case of sensitive information, a directly related secondary purpose) that is within your reasonable expectations;
• the handling is required or authorised by or under an Australian law or a court/tribunal order or is otherwise permitted under the Privacy Act; or
• where we have your consent.

Where we collect your personal information so that we can provide you with services we may use the personal information we have collected from you for purposes related to the services including:

• to process and administer the services, and to help us develop, improve, manage, administer and facilitate our services and business operations;
• to contract with authorised individuals (such as medical practice managers);
• to process your personal information for our internal business purposes;
• for general internal purposes (such as record keeping, database management, training, billing);
• assist with the resolution of any issues relating to services;
• comply with all laws and regulations in all applicable jurisdictions; and
• communicate with you.

Your personal information (including sensitive information) will be collected, stored, used and disclosed in the ways described above and in any other ways that you authorise.

6. IN WHAT VERY LIMITED CIRCUMSTANCES MIGHT WE DISCLOSE YOUR PERSONAL INFORMATION?

Your personal information will not be sold, traded rented or otherwise provided to others without your consent.

We will only disclose your personal information outside Medtech and its related companies if it is necessary and appropriate to facilitate the purpose for which your personal information was collected pursuant to this Privacy Policy, including the provision of services, or a related purpose (or a directly related purpose in the case of sensitive information). This may include, for example, disclosure of personal information to:

• different parts of the Medtech group of companies to enable the development and marketing of other products and services and to improve our customer service in general;
• third-party service providers, including any sub-contractors, to enable us to provide our services;

We will not otherwise disclose your personal information unless we believe on reasonable grounds that you have provided your authorisation. However, you should be aware that we may be required to disclose your personal information without your consent in order to comply with any court orders, subpoenas or other legal process or investigation including by tax authorities if such disclosure is required by law. Where possible and appropriate, we will notify you if we are required by law to disclose your personal information.

7. INTERNATIONAL DATA TRANSFERS

We do not presently disclose personal information to overseas recipients. If at any time in the future it appears likely that we will do so:

• we will take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles (other than the requirement to have a privacy policy that complies with Australian Privacy Principle 1); and
• we will update this policy to indicate the countries in which the overseas recipients are likely to be located if it is practicable to specify those countries.

8. STORAGE AND SECURITY

We are committed to protecting the security of your personal information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure.

Medtech implements and maintains security measures that are designed to provide reasonable protection against the loss, interference or misuse of your personal information and to prevent unauthorised access, modification or disclosure of that information. These steps include technical and organisational measures.

9. WHAT ABOUT LINKS TO OTHER WEBSITES?

Our website may contain links to other websites that are not under our control. These other websites may use cookies. It is the responsibility of those third parties to collect appropriate consents from you in order to permit their own cookies (to the extent this is required by law) and to inform you about the cookies they use. You should check the privacy policy on all third party websites to ensure you are comfortable with third party cookies.

We have no responsibility for linked websites, and provide them solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or warranties about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.

10. EMAIL, TEXT AND TELEPHONE COMMUNICATIONS

We are committed to full compliance with the Spam Act 2003 (Australia).

By subscribing to emails and/or text communications, or otherwise providing your consent to receiving emails and/or texts (as the case may be), you agree that we may send you emails and/or texts which promote and market our products and services, or the products and services of others, from time to time.

Where required, we will ensure we have your express consent before sending you such messages, unless your consent can reasonably be inferred from conduct and the business and other relationships you have with us. And you will always be able to unsubscribe from our email communications and/or text communications at any time by clicking the “Unsubscribe” link in any promotional or marketing email or text received or by emailing hq@medtechglobal.com.

Once you have unsubscribed from the email or text communications, you will be removed from the corresponding marketing list as soon as is reasonably practicable or, where there is a mandatory period within which the law says that you need to be removed, within that mandatory period.

11. HOW YOU CAN ACCESS OR CORRECT YOUR PERSONAL INFORMATION

It is your responsibility to ensure that the personal information you provide is accurate, complete and up-to-date.

You may request access to the information we hold about you, or request that we update or correct any personal information we hold about you, or ask us to restrict or cease processing your personal information or even delete your personal information, by setting out your request in writing and sending it to us at hq@medtechglobal.com.

We will review your request as soon as reasonably practicable to comply with our legal obligations. If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.

12. RETENTION

The length of time we keep your personal information depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you’ve requested or to comply with applicable legal requirements such as money laundering and financial reporting legislation).

We’ll retain your personal information for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our internal retention policies and practices. Following that period, we’ll make sure it’s deleted or de-identified. Otherwise, as a general rule, we only keep your personal information for as long as we require it for the purposes of providing you with our services or other purpose for which we collected the information in the first place.

13. NOTIFIABLE DATA BREACH SCHEME

If there is a loss, or unauthorised access to, or disclosure of, your personal information that is likely to result in serious harm to you. We will investigate and notify you and the Office of the Australian Information Commissioner as soon as practicable, in accordance with the Privacy Act 1988.

14. PRIVACY OFFICER

We take your concerns seriously. If you have any concerns about privacy or the use or collection of your personal information by Medtech please contact our Privacy Officer at:

Level 7, Kings Club, 80 Dorcas Street, Melbourne, Victoria, 3006

We will respond as quickly as possible and handle all complaints in a way that is fair and consistent. In general, we will manage the complaint process by finding out your concerns and grievances about our handling of your personal information, engaging with you about ways in which we can remedy the situation and (if applicable) putting an action plan in place to resolve your complaint and improve our personal information handling procedures.

However, if you remain dissatisfied, you can make a formal complaint with Office of the Australian Information Commissioner.

This represents our Privacy Policy as at 01/06/2025.