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1. Introduction
Our commitment to protecting your personal information
Everlight Radiology Limited ACN 120 630 784 (‘Everlight Radiology’, ‘us’ or ‘we’) is committed to protecting your personal privacy and complying with our obligations under relevant privacy legislation, as set out in the Privacy Act 1988 (Cth) and embodied in the Australian Privacy Principles under that legislation (and to the extent they apply, in the other jurisdictions in which we operate) and other relevant State/Territory health privacy legislation.

2. Aim/Objectives
By accessing our website or using our services, you agree to be bound by the terms of this Privacy Policy. We encourage you to read this Policy carefully.
This Privacy Policy sets our commitment to protecting your personal information, including sensitive information. It outlines how we collect, use, hold and disclose personal information, and how you can contact us if you have any concerns, questions or complaints about our management of your personal information, or if you want to access it.
We may update this Privacy Policy from time to time so please periodically check and review the policy for changes. You can access the current version of the Privacy Policy at https://www.everlightradiology.com/au/privacy-policy/
Should you require a copy of the Privacy Policy in another form please contact us via the contact details provided in section of this policy to request a copy.

3. Personal Information & Sensitive Information
A reference to “personal information” means any information or opinion about you from which your identity is apparent or can reasonably be ascertained, from the information or opinion regardless of whether the information or opinion is:
• true or not; or
• recorded in a material form or not.
Personal information can also include sensitive information. “Sensitive information” means information or an opinion (that is also personal information) about matters such as your racial or ethnic origin, religion, political persuasion, membership of a trade or professional association or trade union, sexual orientation or practices, criminal records, or your health, genetic or biometric information. We only hold and collect sensitive information where it is necessary for the purpose for which it is being collected and with your consent unless the collection is required or authorised by law.

4. Application of this Policy
We collect a variety of information from individuals, some of which may be personal information. This Privacy Policy explains the types of information we collect and what we do with that information.
This Policy applies to personal information we receive or collect from or about you. This may occur when you:
• visit or use the Everlight Radiology Website or any related software or applications (including any mobile applications);
• request or use any of our services;
• make an enquiry, request information or register your interest with Everlight Radiology;
• become or remain a client of Everlight Radiology;
• contact and interact with us or our personnel by any means, such as by email, phone, mail, online communications or in person;
• apply for a job with us or express interest in employment or providing services to us or become or remain an employee or service provider with us;
• make or receive a payment of any tax invoices we issue; or
• provide your personal (including health) information to us in any other way.
When you provide Everlight Radiology with personal information, you consent to Everlight Radiology using, handling and processing your personal information for the purposes and in the ways outlined in this Policy or such other purposes as we may communicate to you from time to time.
You do not have to provide us with your personal information, but if you do not provide us with the personal information we need, we may not be able to provide our services or assistance to you, or on your behalf, or to process your application, enquiry or request, and you may not be able to enjoy the full benefits of our Website or our services.

4.1 What kinds of information do we collect?
The types of personal information we collect will depend on what activities you are engaging in or the type of product, service or other activity used or requested by you.
We collect personal information that is necessary to manage our relationships with our clients, employees, service providers and other stakeholders and to assist us in providing our services and other functions and activities. The types of personal information commonly collected for these purposes include:
• identification and contact information (e.g. name, age, date of birth, address, phone number, email address etc.);
• employer details;
• Medicare card numbers or Medicare provider numbers;
• country of residence;
• enquiry, information request or complaint details;
• your IP address for your interaction with various parts of our Everlight Radiology Website. Your IP address is the identifier for your computer / site when you are using the internet;
• educational qualifications, employment history and other employee data in connection with a job application or expression of interest; and
• employee or contractor details to include in their personnel files.
In certain circumstances, we may also be required or permitted by law, court or tribunal order to collect certain personal information about you. Where required to do so, we will notify you in accordance with relevant privacy legislation when we collect your personal information and for what purpose.
We only collect sensitive information about you with your consent and if it is necessary for, or directly related to, our functions or activities, except where we are otherwise required or permitted by law to collect, use or disclose it.
We may also collect some statistical information about visitors to the Everlight Radiology Website (for example, the number of visitors, pages viewed, your type of browser and geographic location, types of transactions conducted, time online and documents downloaded, how you came to the site, and information that will help us trouble-shoot problems, analyse our resources and improve our services). Some of this statistical information is collected by using cookies, but none of the statistical information we collect allows us to identify a visitor. We use this information to evaluate our website performance and continually improve our services. Importantly, we do not store any identifying information in any cookies on your computer. You can set your browser to refuse cookies but this may mean you cannot log in or take full advantage of our website.

4.2 Personal information about employees, contractors or job applicants
Everlight Radiology may also collect personal information from you if you apply for a job (or a position as a contractor) with and/or become employed by (or contract with) us. In these circumstances, you:
• authorise us to collect any personal information (whether written or verbal) from any referee or previous employer specified in your application for employment or curriculum vitae for evaluation of your application for employment and to hold such information on your personal file for future evaluation of your employment by us;
• acknowledge that your personal information is collected for the purpose of evaluating your application for employment by us and, if you accept employment with us, the assessment of your continued employment by us, and the administration, monitoring and management of your employment by us, and the processing of your remuneration and any PAYG tax obligations; and
• acknowledge that a failure by you to provide the requested personal information will have a detrimental effect on our ability to give your employment application proper consideration.
You can request to access and/or correct your personal information in accordance with this Policy.

4.3 How we collect your Personal Information
We will collect personal information directly from you unless:
• it is not reasonable or practicable to do so;
• you consent to us collecting it from other sources; or
• collection is otherwise permitted under relevant privacy legislation.
You must not provide us with the personal information about another person unless you have first obtained that person’s prior consent to do so (except where permitted by law) and you have told them their personal information will be handled in accordance with this Privacy Policy (including where they can find it).

4.4 Purposes of collecting and using your Personal Information
We collect your personal information so that we can manage our relationships with our clients, employees, service providers and other stakeholders, provide our services to you and our clients, and to perform our other functions and activities. We may use your personal information in the following ways:
• communicating with you, including by email, mail, phone, online or in person;
• responding to your requests or queries;
• operating and improving Everlight Radiology’s Website, content, offers and services;
• sending you news and information about Everlight Radiology and our products, services or promotional communications, including newsletters, surveys and information about security updates, or information that is related to you as a customer or service provider of Everlight Radiology;
• occasionally sending you marketing, advertising or promotional material about our products and services (or the products and services of our partners) that we think may be of interest to you;
• providing you with more effective customer service;
• enabling us to conduct customer research;
• to compile data and conduct analysis of Everlight Radiology member/user statistics;
• performing research and analysis aimed at improving our products, services and technologies;
• establishing, maintaining and administering your account and customising the service we provide to you;
• verifying your identity, profiles and products, checking your credentials;
• monitoring and reporting as permitted or required under any applicable laws, including under applicable privacy legislation;
• investigating any complaints made by you or about you, or if we have reason to suspect that you are in breach of any of our Terms of Use or Code of Conduct (where applicable) or that you are or have been otherwise engaged in any unlawful activity;
• to communicate with regulators or government departments in respect of Everlight Radiology’s functions and activities;
• to assess a job applicant or to allow us to carry out any monitoring activities which may be required or permitted of us under applicable law as an employer;
• ensuring our internal business operations are running smoothly, which may include fulfilling legal requirements and conducting confidential systems maintenance and testing;
• quality assurance and training purposes;
• any other uses identified at the time of collecting your personal information;
• using personal information as otherwise required or permitted by any law, (including the Privacy Act 1988 (Cth) and the Spam Act 2003 (Cth)) or for purposes of monitoring, meeting or reporting on our obligations under the Privacy Act and other applicable privacy legislation.
Personal information that we collect is not traded, sold, leased or rented. You consent to us using and disclosing your personal information in the manners that could reasonably be contemplated by this Privacy Policy, our Website Terms + Conditions or by the relevant activities you are engaged in when providing us with your personal information (e.g. as a website user, job candidate, service provider or customer).

5. Disclosure of your Personal Information
Any personal information provided to us may be disclosed, if appropriate, to other entities in order to facilitate the purpose for which the information was collected. Such entities generally include:
• third-party service providers for the purpose of enabling them to provide a service such as (but not limited to) payroll, superannuation administration, IT service providers, data storage/processing, IT security, web-hosting and server providers; debt collectors, maintenance or problem-solving providers; security services; credentialing service providers; professional advisory (including legal, accounting, financial and business consulting); mailing house and delivery services; HR Service providers; and banking, payment and insurance providers;
• any applicable or relevant regulator or third party for the purpose of legislative or contractual compliance and/or reporting;
• any related entities of Everlight Radiology; or
• other entities if you have given your express consent.
We may also disclose your personal information to third parties in the following circumstances:
• where we are under a legal or regulatory obligation to do so (for example, to a court or tribunal in response to a legal request, to a subpoena or to the Australian Taxation Office), or for purposes of monitoring, meeting or reporting on our obligations under applicable privacy legislation, or to protect the rights and interests, property, or safety of Everlight Radiology, our employees and contractors, our clients, members and users, or others;
• if all, or substantially all, of the assets of Everlight Radiology are merged with or acquired by another party, in which case your personal information may form part of the transferred or merged assets.
Where possible, we will inform you, at or before the time of collecting your personal information about other types of organisations to whom we may, with your consent, disclose your personal information. Prior to such disclosures, Everlight Radiology will take all reasonable steps to satisfy ourselves that:
• the organisation has a commitment to protecting your personal information; and
• where necessary, you have consented to such disclosure.
From time to time, these parties may reside outside of Australia including in the United Kingdom and India. Our contracts with these parties generally include an obligation for them to comply with Australian privacy law and this Privacy Policy. However, you acknowledge that, by agreeing to the disclosure of your personal information to parties located outside of Australia, we will no longer be required to take reasonable steps to ensure the overseas recipient’s compliance with the Australian privacy law in relation to your personal information and we will not be liable to you for any breach of the Australian privacy law by these overseas recipients. On this basis, you consent to such disclosure of your personal information to other entities located outside of Australia as described in this section

5.1 Direct Marketing
From time to time we may use your personal information to contact you about, among other things:
• particular Everlight Radiology products and services being offered to Everlight Radiology members / users which we believe may be of interest to you;
• changes to our organisation or our services; or
• your use of Everlight Radiology’s Website or services.
We will generally only do this with your prior consent (where practical) and we will always give you the opportunity to opt out of receiving such communications at any time. Direct Marketing from Everlight generally takes the form of emails or telephone calls.
Every directly addressed marketing communication sent or made by Everlight Radiology will include a means by which you may unsubscribe (or ‘opt out’) of receiving further marketing communications. You may also instruct us at any time to remove any previous consent you provided to receive marketing communications from us. Requests should be directed to us via the contact details provided in the 'Contacting us' section of this policy.
If you request not to receive direct marketing or market research information, please note that we will still contact you to provide you with relevant information in respect of your ongoing health care. For example, we will continue to send you relevant statements, invoices, reminders, notices, etc.

5.2 Links to Third Party Websites
Our website may contain links to the websites of other entities. If you click on such links, you will be transferred to the website of those third-party entities. We have no control over, and are not responsible for, the privacy practices of these entities. You should read the privacy policy of those entities to find out how they handle your personal information when you visit their websites.
We accept no responsibility or liability whatsoever for the content, actions or policies of third party sites. The inclusion of links to third party sites on our site in no way constitutes an endorsement of the third party sites' content, actions or policies: you access them at your own risk.

5.3 Updating or correcting your Personal Information
We will take reasonable steps to ensure the personal information (including sensitive (health) information) we collect is accurate, up to date and complete. We will also take reasonable steps to ensure that when we use or disclose your personal information it is accurate, up to date, complete and relevant, having regard to the purpose of the use or
disclosure. However, we also rely on you to advise us of any changes to your personal information by maintaining and updating your profile or information with us.
During the course of our relationship with you, we will from time to time ask you to confirm whether your personal information is correct or has changed.
You may also inform us of any changes to your personal information (such as your name, address or Medicare number) or correct any inaccuracy or errors in the information we hold by contacting us via the contact details in the ‘Contacting us’ section of this policy so that we can update your file accordingly. However, where there are grounds to refuse to correct the information as requested, we will provide you with reasons for not complying with your request where we are able to do so in accordance with applicable laws.

5.4 Accessing your Personal Information
You may request access to any of the personal information we hold about you at any time by contacting us via the contact details provided in the ‘Contacting Us’ section of this Policy.
While we do not generally charge you for requests to access your personal information, you should be aware that there may be reasonable charges (which will be notified to you when you make a request) for our time and cost associated with processing your request to access your personal information in the following circumstances:
• if an extended amount of time is required to collate and prepare material for you; or
• if you wish to have your files photocopied and / or printed for you.
Your request to access to your personal information may be denied on certain grounds including, for example:
• it is unlawful;
• it may have an unreasonable impact upon the privacy of other individuals; or
• your request is frivolous or vexatious.
If we deny your access or correction request, we will advise you of the reasons for doing so as soon as practicable, (except if it is unreasonable to do so) and we will inform you of the mechanisms available to complain about the refusal (see Complaints section below).

5.5 Dealing with us anonymously or by pseudonym
In order for us to effectively do business with you or make our Website, services and associated content available to you, it will not, in most circumstances, be practical for us to deal with you without you providing relevant personal information to us. However, where it is lawful and practicable to do so, you may deal with us anonymously or by using a pseudonym. Such a situation might include where you make general enquiries about current or potential Everlight Radiology Services or promotional offers or the content on our Website.
6. Storage & Security
We store personal information in both electronic and hard copy form and we will keep your personal data for no longer than is necessary for the purpose(s) it was provided for and to meet our legal obligations. Further details of the periods for which we retain data are available on request.
When the information is no longer needed for any purpose for which it was collected, used or disclosed, it will be destroyed or permanently de-identified.

We will also take reasonable steps to protect any personal information, including by implementing security procedures for access to our business premises and within our offices, as well as IT security procedures including encryption, password protection, firewalls, storing personal information on servers that utilise security software and systems, and site monitoring
Although we aim to create a safe, secure environment by trying to limit access to the Website to legitimate users, we cannot guarantee that unauthorised parties will not gain access. We will not have any liability arising from any unauthorised access to your personal information.
Please contact us immediately if you become aware of any unauthorised use of your account by anyone else or any other breach of security (see the contact details section in this policy).

7. Contacting us
Please contact us via the contact details provided below if you want to:
• obtain further information about the way we manage your personal information;
• access your personal information held by us;
• raise a concern or make a complaint regarding how we collect or handle of your personal information, including about a breach of this Privacy Policy or the Privacy Act 1988 (Cth);
• correct or update your personal information held by us; or
• unsubscribe from any Everlight Radiology mailing list or have any questions or complaints regarding unsolicited electronic communications which you may have received or are concerned about.
We will endeavour to:
1. provide an initial response to your query or complaint within 5 business days; and
2. resolve your query or complaint within 21 business days.
If you are still not satisfied, you can contact the Australian Privacy Commissioner (see http://www.oaic.gov.au/about/contact.html or call 1300 363 992)
Contact us at:
Website - https://www.everlightradiology.com/au/contact-us/


Write to us at:
The Privacy Officer Everlight Radiology L11, 70 Phillip Street Sydney NSW 2000

8. Changes to our Privacy Policy
We regularly review all of our business policies and may change this Privacy Policy from time to time, or as the need arises, without prior notice. The amended Privacy Policy will apply between us whether or not we have given you specific notice of any change. You should periodically check the page on the Everlight Radiology Website containing our Privacy Policy and review the policy regularly to ensure that you are aware of any changes to its terms. This is the current Privacy Policy and may replace any other privacy policy previously published for Everlight Radiology.
This Privacy Policy was last reviewed on [9 December 2019].

Need more information about privacy?
For more general information regarding privacy in Australia, visit the website of the Office of the Australian Information Commissioner