Frank Uccellini

PRIVACY POLICY

DISCLAIMER

Your use and engagement with zamilsolanki.com, our Material and our Social Media accounts is at your sole risk.

The information on zamilsolanki.com and our learning platforms is not medical advice.

DEFINITIONS

‘Personal information’ refers to 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 is recorded in a material form or not.

‘Us’ or ‘We’ or ‘Our’ refers to Z Corporation Pty Ltd and zamilsolanki.com

‘zamilsolanki.com’ or ‘Service’ means all of the websites that we own and/or operate from time to time, regardless of how those websites are accessed by users (including via the internet, mobile phone or any other device). This includes all dashboards, e-learning portals, membership areas and downloads.

PURPOSE

The Privacy Act 1988 (the Privacy Act) requires entities bound by the Australian Privacy Principles to have a privacy policy. This Privacy Policy outlines the handling practice of Z Corporation Pty Ltd (ABN 69 150 925 750).

We take your privacy seriously. In dealing with personal information, we comply with the Privacy Act and any relevant State and Territory privacy legislation. We also recognise that you have an interest in the use of your personal information via our Service, and how we collect and manage this data. We have implemented this Privacy Policy in order to be open and transparent about how we collect, hold, and use your personal information, and under what circumstances we may disclose or transfer your personal information. This Privacy Policy also outlines your rights to gain access to, and seek corrections of, your personal information we hold. Finally, this Privacy Policy provides information about how you can approach us about your privacy-related concerns and complaints, and how we will deal with such communications.

COLLECTION OF PERSONAL INFORMATION

Personal information is collected either:

• Directly from you – We primarily aim to collect personal information about you directly from you. We primarily collect information about you when you use or request a product or service, complete a survey, questionnaire or enrolment form or when you communicate with us by email, telephone, in writing or in person. We also collect information about you if you are providing services to us or if you apply for employment with us.
• From others – We may obtain personal information from a third party, such as a partner organisation, supplier, distributor, wholesaler, franchisor, clinical service specialist, medical practitioner, allied health professional, a member of your family, a friend or your carer.
• From public sources – We may collect personal information from the public domain, for example, from professional registration boards.

The types of personal information that we collect will vary depending on your relationship with us. Sometimes we may need to collect sensitive information about you such as medical history of the consumer. Please note that we try and collect only the information that we need for a particular function and only hold it for as long as it remains necessary for the purposes for which it was collected. We only disclose your personal information (including sensitive information) for the purposes for which you gave it to us or for directly related purposes you would expect or if you agree.

IP addresses are used by your computer every time you are connected to the Internet. Your IP address is a number that is used by computers on the network to identify your computer. IP addresses are automatically collected by our web server as part of demographic and profile data known as traffic data so that data (such as the Web pages you request) can be sent to you.

USE OF PERSONAL INFORMATION

We may use your personal information to:

• conduct evaluations of our products, materials, programs and services;
• assist us in conducting or participating in pilot programs;
• invite you to participate in research or to inform you of our educational programs;
• subject to consent, create individual business performance and/or health stories which are published and/or broadcast to promote our products and/or services (including the individual’s consent to appear in the same);
• promote educational activities including events and conferences;
• improve our products and/or services;
• allow you to utilise our products and/or services;
• contact individuals for feedback on products, materials, programs and services; and
• assist us to perform our corporate and contractual obligations.

Imagery

We will seek your consent prior to any taking of a photograph/image and the use (i.e. the publication) of the photo/image. In some cases that consent may be implied, for example, the taking of photos at functions to be used in printed or digital publications. If the photo or image contains sensitive information about a person (for example, information relating to their health), we will obtain the relevant person’s consent to take the photo/image and specify the uses to which it may be put.
This consent should be informed and freely given and signed by the individual whose information is to be collected and disclosed.

Child protection legislation requires that where the photo or image is that of a child, the child’s parent or guardian must give permission.

Where the person under 18 years is sufficiently mature to consent on their own behalf, that person’s consent should also be obtained.

Under the Privacy Act consents can be revoked at any time. If this occurs, we will take all reasonable steps to cease using the image or photo from the time the consent is withdrawn.

Social Media

Zamil Solanki has a number of social media pages, including but not limited to LinkedIn, Facebook, Instagram, YouTube and Twitter. Comments posted on these are open to the public. If you upload content to these pages, you should be aware that your information is collected by the company operating the social media platform. You should refer to the privacy policy of that social media company for information on how the organisation collects, uses and discloses personal information. We may collect personal information from published social media posts that you have uploaded to those platforms.

PROTECTION AND SECURITY

We take preserving and protecting a person’s identity very seriously and it is a key responsibility and right of all our staff, customers and partners.

We maintain the confidentiality and security of personal information by restricting access to only those staff and service providers with a legitimate need to access it.

In our organisation, personal information may be stored both electronically and in hard-copy form. We are committed to keeping your personal information secure regardless of the format in which we hold it and we take all reasonable steps to protect your information from misuse, interference, loss, and unauthorised access, modification or disclosure. However, you use our website and related online platforms at your own risk and we accept no responsibility, whether we are deemed to have been negligent or not, in the event of a security that affects your privacy.

Note that no information transmitted over the Internet or any Internet enabled device can be guaranteed to be completely secure. However, we will endeavour to protect your personal information as best as possible, but we cannot guarantee the security of any information that you transmit to us, or receive from us. The transmission and exchange of information is carried out at your own risk.

USE AND DISCLOSURE OF PERSONAL INFORMATION

When we hold your personal information, it will be used for the following primary purposes:

• to ensure the proper functioning of the Service;
• to ensure the proper functioning of our business and operations; and
• to assist us with our auditing, marketing, planning, billing, product development and research requirements
• to provide or administer education or participation activities for health professionals or health professional students
• to allow for monitoring the participation and use of content and materials

We will not use or disclose (or permit the use or disclosure of) information that could be used to identify you in any circumstances except:

• to ensure the proper functioning of our organisation and our Services;
• to communicate promotional offers and special events to you;
• where the law requires us, or authorises us, or a company holding data on our behalf, to do so; or
• where you have given express consent to us for a prescribed purpose.

Personal information incorporated into health stories may be disclosed to the general public when the health story is published and/or broadcast. The information disclosed in these circumstances would not include an individual’s address, phone number, email address or other contact details.

Third Parties

We will not sell, distribute, rent, licence, disclose, share or pass your personal information onto any third parties, other than those who are contracted to us to keep the information confidential whether subject to a statute or a scheme which imposes similar restrictions to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth), as amended, regarding the handling of personal information.

Third parties must undertake not to disclose to any person or entity any confidential information without prior approval in writing from us unless the confidential information is required by law to be disclosed or a court or government department. Should a third-party approach us with a demand to access your personal information, we will take reasonable steps to redirect the third party to request the information directly from you, wherever it is lawful and reasonable for us to do so.

We may disclose your information to contractors to whom we outsource certain functions or which provide services to us, such as, bodies that assist in conducting or analysing research and print, data capture, mailing and distribution houses. We take all reasonable measures with our contractors to ensure they comply with the privacy standards set out in the Privacy Act and any relevant state and territory legislation.

If we are compelled to disclose your personal information, to a third party we will take reasonable steps to notify you of this in advance, wherever it is lawful and reasonable for us to do so.

Where disclosure is required or authorised by law, courts or government departments we may also disclose personal information in circumstances where it has statutory obligations or is otherwise required to do so by law, a court or a government department (including the Department of Health).

Free Offers and Opt-Ins

Participation in providing your email address in return for an offer from this site is completely voluntary and the user therefore has a choice whether or not to disclose your information. You may unsubscribe at any time so that you will not receive future emails.

ACCURACY AND ACCESS OF PERSONAL INFORMATION

We will take all such steps as are reasonable in the circumstances to ensure that:

• all information collected from you is kept accurate, up to date and complete; and
• the personal information that we use or disclose is, having regard to the purpose of the use or disclosure, accurate, up-to-date, complete and relevant.

Under the Privacy Act you have the right to access the personal information we hold about you. There are some limited exceptions to this set out in the Privacy Act.

If you make an access request, we will ask you to verify your identity and to specify what information you require. We may ask the reason for your request so we can assist you most effectively. However, you are under no obligation to provide a reason if you do not wish to. If you wish to access your personal information, please contact us via our Contact page.

We will deal with all requests for access to personal information as quickly as possible. Requests for a large amount of information, or information which is not currently in use, may require further time before a response can be given.

We may charge you a reasonable fee for access if a cost is incurred by us in order to retrieve your information, but in no case will we charge you a fee for your application for access.

Whenever a fee will be applied, you will be notified of how that fee will be calculated, or where possible, the total amount that will be charged. You will then have the option to decide whether to proceed with your access request.

In some cases, we will refuse to give you access to personal information we hold about you. This includes, but is not limited to, circumstances where denying access is required or authorised by or under an Australian law or a court/tribunal order or where giving you access would be:

• unlawful;
• have an unreasonable impact on other people’s privacy; prejudice an investigation of unlawful activity;
• reveal our intentions in relation to negotiations with you so as to prejudice those negotiations;
• prejudice enforcement related activities conducted by, or on behalf of, an enforcement body;
• reveal evaluative information generated within our business in connection with a commercially sensitive decision-making process.

We will also refuse access where the personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discovery in those proceedings. Further, we will refuse access where your request is frivolous or vexatious, and where we reasonably believe that:

• giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety;
• unlawful activity; and/or
• misconduct of a serious nature, is being or may be engaged in against us and giving access would be likely to prejudice the taking of appropriate action in relation to that matter.

If we refuse to give you access we will provide you with reasons for our refusal, unless doing so would be unreasonable in the circumstances. We will also take reasonable steps to give you access in a way that meets your needs without giving rise to the reasons of our refusal. Further, we will provide details of how you may make a complaint about our decision.

These mechanisms for accessing your personal information operate alongside, and do not replace, other informal or legal procedures by which you may be provided with access to your personal information.

CORRECTION

You have a right to request that we correct information held by us that you consider is not accurate, complete or up-to-date. If we make a correction and have disclosed the incorrect information to others including third-parties, you can ask us to tell them about the correction. We must do so unless there is a valid reason not to.

The accuracy of the personal information we have requested from you is important to us. Should you suspect, or become aware of, that your personal information we hold is inaccurate, out of date, incomplete or misleading, please contact us via the Contact page.

We will deal with all requests for correction of personal information as quickly as possible. Requests relating to a large amount of information, or information which is not currently in use, may require further time before a response can be given.

If we refuse to change the personal information as you request, we will provide you with reasons for our refusal, unless doing so would be unreasonable in the circumstances. We will also provide details of how you may make a complaint about our decision. Further, in case of our refusal, you may request that we take reasonable steps to associate, with the relevant information, a statement that you view it as inaccurate, out of date, incomplete or misleading.

These mechanisms for correcting your personal information operate alongside, and do not replace, other informal or legal procedures by which you may be provided correction of your personal information.

OVERSEAS DISCLOSURE

We do not disclose any personal information to overseas entities however information stored on our servers may be hosted overseas. The policies related to storage of data and information is detailed under Protection and Security.

DISPOSAL OF PERSONAL INFORMATION NOT REQUIRED

If we hold personal information about you, and we do not need that information for any purpose for which the information may be used or disclosed, we will take reasonable steps to destroy or de-identify that information unless we are prevented from doing so by law.

UNSUBSCRIBE FROM DATABASE

To unsubscribe from our e-mail database, please send us a request via the Contact page noting your request to unsubscribe from our database including your email address.

COMPLAINTS

If you believe that there has been a breach or potential breach of this Privacy Policy or the privacy legislation, please contact us via the Contact page. We take breaches seriously and have procedures to help identify and resolve a breach, potential breach or complaint as quickly as possible. You will be notified of the process for dealing with the breach or potential breach. Your complaint will be thoroughly investigated and a response provided within 30 business days. If you are not satisfied with the resolution of your complaint you may contact the Office of the Federal Privacy Commissioner at its website www.oaic.gov.au or by telephone on 1300 363 992 who may investigate your complaint and has the power to award compensation against us in appropriate circumstances.

FURTHER INFORMATION

If you have any questions, concerns or ideas about how we could improve our Privacy Policy, please contact us via the Contact page. Where you provide suggestions, materials or feedback it is considered non-confidential and we may, at our complete discretion, use it to improve our Service, products, offerings and/or how we handle personal information without any obligation to compensate you regardless of how we use, implement, copy, modify, display, distribute and/or otherwise benefit from your suggestions, materials or feedback.

AMENDMENTS OF THIS PRIVACY POLICY

We are obligated to regularly review and update this Privacy Policy. We therefore reserve the right to amend this Privacy Policy at any time. Should any significant amendments occur, notification will be provided by publication on our website, fourteen (14) days prior to the changes being implemented (‘Notice Period’) unless the circumstances of the amendments makes it unreasonable to provide such a Notice Period. Your continued use after the Notice Period has lapsed indicates your consent to be bound by the amended Privacy Policy.

For further information about privacy in general, please refer to the Office of the Australian Information Commissioner’s website located at http://www.oaic.gov.au.

This Privacy Policy was last updated on 1st March 2021.