Privacy Policy

NWO Group Pty Ltd

 

Effective Date 1 December 2021

1.                  Our Commitment to Your Privacy

1.1                NWO Group Pty Ltd, ABN 57 114 626 345 (We/Us/Our) respects Your privacy. So that You may understand how We deal with Your Personal Information, We have set out how and why We collect, hold, use, manage, process and disclose Personal Information in this Privacy Policy. You may print a copy of this Privacy Policy without charge.

1.2                Please read the entire Privacy Policy carefully to understand Our views and practices regarding Your Personal Information and how We will treat it. We will update this Privacy Policy from time to time at Our discretion, so You should visit Our Service regularly to see the latest copy of the Privacy Policy.

1.3                Our business activities and functions include:

(a)                 providing a SAAS based technology platform (the myeyes Service) that allows Optometrists and other health myeyes Service providers to:

(1)      market and provide their myeyes Services to individual patients;

(2)      operate their business, including providing health advice, diagnosis, prescriptions, glasses, frames, contact lenses and allied services to patients (including managing the supply of these goods and services through their supply chains, e.g. ordering glasses from manufacturers) as well as automating their marketing activities;

(b)                 appointing business associates to resell, distribute or provide the myeyes Service directly or indirectly to Optometrists and other health myeyes Service providers;

(c)                 providing Optometrists and other health myeyes Service providers and business associates with consulting and training services to assist them implement, customise, use and market the myeyes Service.

1.4                The myeyes Service also provides users with access to third party myeyes Services and provides third parties with the ability to advertise and promote their information, goods and myeyes Services to users of the myeyes Service

1.5                Our myeyes Service also enables You to communicate via online chat and other technologies with Us.

1.6                This Privacy Policy relates to how We collect, hold, use, manage and disclose Personal Information that We collect in Our own name. Where We are providing the myeyes Service to You, Our systems are used to hold and process Personal Information, and Our merchant myeyes Service providers (such as PayPal and Stripe) will also hold and process Personal Information. This information is subject to the privacy policies of Our myeyes Service providers (and not Us), and Our myeyes Service providers are responsible for its collection, storage, use, processing, management and disclosure.

1.7                Some of the key phrases that are used in this Privacy Policy include “Personal Information” and “Sensitive Information”. Both of these terms are defined in the Privacy Act 1998 (Cth).

2.                  What Personal Information do We Collect and Hold?

2.1                We may collect and hold the following types of Personal Information:

(a)                 information, including data, images, video and sound recordings, which may include Sensitive Information about Your health that You, or people authorised by You:

(1)      enter into Our myeyes Service (other than numbers, date of expiry and CCV of credit/debit/charge card or other payment mechanisms which collected and managed directly by Our merchant myeyes Service providers and are subject to their privacy policies and legal regulation). Where You are a patient of an optometrist, this may include information about Your health, the health history of Your family members, any medications that You are taking or have taken, age, date of birth, Your ability to see and other information that a health professional may require to provide the services that you require;

(2)      create when using Our myeyes Service (including meta data);

(3)      otherwise provide to Us; or

(4)      use the features in Our myeyes Service to import from other software applications;

(b)                 information about the information, goods or myeyes Services that You purchase or consider purchasing from Us, Our suppliers or business associates;

(c)                 information You provide when You raise a support enquiry or when We are working with You to resolve a technical or administrative query;

(d)                 information that You provide in response to market research, surveys or competitions that are conducted by or for Us;

(e)                 name, honorific or title and gender;

(f)                  personal and business address, phone number, fax number, email address, video call applications address and other business or personal addresses/contact details/identifiers and social media identifiers;

(g)                 individual’s business or vocation status, including job role, job description, job title, employment status, education status, educational institute, courses, status and identifiers;

(h)                 voicemail recordings left in Our phone system and images that individuals have made publicly available or provided to Us;

(i)                  demographic information such as location at any point in time, preferences or interests;

(j)                  information about enquiries made to Us, Our suppliers or business associates;

(k)                 information that is provided in respect of employment, contract work, work experience or similar, whether solicited or unsolicited;

(l)                  other Personal Information that is independently provided by You without Us requesting it;

(m)               Personal Information that We access in systems that We are permitted to access as a result of Us conducting Our business activities and functions;

(n)                 cookies, metadata, pixels and other information set out in section 7 below, which may identify You when used by itself or in conjunction with any of the information set out above. 

2.2                We may collect or hold Sensitive Information. The circumstances where We do this include:

(a)                 where You voluntarily provide Sensitive Information to Us, such as when You enter details about Your health into Our myeyes Service and We use the myeyes Service to process that information;

(b)                 where the Sensitive Information is directly linked to the individual’s employment records and Our collection, holding and use is permitted by the Privacy Act 1988 (Cth) for the purpose managing the individual’s employment record;

(c)                 where Sensitive Information is provided to Us in connection with the individual seeking employment, contract work, internships, work experience or similar, whether solicited or unsolicited.

3.                  How do We Collect and Hold Personal Information?

3.1                We collect Personal Information in a number of ways, including:

(a)                 through Our myeyes Service;

(b)                 through Our website;

(c)                 through communications with You, including letters, emails, telephone calls, facsimiles, voicemail messages, online chat, surveys, competitions, events and via social media applications;

(d)                 through communications with others;

(e)                 in the course of Our business functions and activities;

(f)                  in the course of You visiting Our offices;

(g)                 where Our suppliers or business associates provide Us with that Personal Information;

(h)                 through communication which We conduct such as email, microsites, surveys, online chat, competitions and customer feedback.

3.2                We hold Personal Information:

(a)                 in Our hard copy files;

(b)                 in other systems that We use in connection with Our business, some of which may be owned and operated by Our suppliers;

(c)                 in the database associated with Our myeyes Service;

(d)                 in the database associated with Our website.

3.3                Providing it is lawful and practical, We will give You the option of not identifying Yourself, using a pseudonym, or not providing Personal Information when You enter into a transaction or deal with Us.

3.4                If You elect not to provide Us with Personal Information then We may not be able to provide You with the information, products, services or support that You may want, including the myeyes Service.

3.5                We may receive other unsolicited Personal Information in the course of Our business. We will deal with this unsolicited Personal Information in accordance with the Privacy Act 1988 (Cth).

3.6                Where We have given You (or where You have chosen) a password which enables You to access Our myeyes Service or systems, You are responsible for keeping this password confidential. You must not to share a password with anyone.

3.7                Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect Your Personal Information, We cannot guarantee the security of Your Personal Information transmitted to/from Our myeyes Service or Our website; any transmission is at Your own risk. Once We have received Your Personal Information, We will use appropriate procedures and security features to prevent unauthorised access.

4.                  The Purposes for which We use Personal Information

4.1                We collect, hold, process, use and disclose Personal Information for the following purposes:

(a)                 pursuing Our business activities and functions. This includes providing any Personal Information (including Sensitive Information about Your health) that You include in Our myeyes Service for transmission to any other users of Our myeyes Service;

(b)                 facilitating interactions between You (or other people who You are acting for) and Us or between You (or other people who You are acting for) and other people and organisations who are accessible via Our myeyes Service or any electronic means (including Our suppliers and business associates);

(c)                 facilitating payment for the purchase of Our myeyes Service or information, goods or services provided by Our suppliers or business associates through Our myeyes Service or otherwise. In this case You will be directed to (or We may use to facilitate the transaction) a third party website (a secure internet payment gateway) approved by the relevant financial institution to enter Your credit/debit/charge card or other payment mechanism details.  This third party may in turn integrate the payment software with a third party payment application provider who assists in managing the payment transaction. Where You are redirected in this way, You will be subject to the privacy policies of the third party providers;

(d)                 performing any of the features in Our myeyes Service, e.g. Contact Us or any other data collection form, online chat, conducting surveys, market research, competitions, mail outs or using social media;

(e)                 allowing the technical support personnel to provide assistance to You if needed;

(f)                  statistical analysis of the usage of Our myeyes Service or applications or tools that are accessed via Our myeyes Service;

(g)                 improving the quality or user experience of Our myeyes Service and information, goods or services provided by Our suppliers or business associates;

(h)                 developing or adding additional products and myeyes Services from Us or existing or new people and organisations;

(i)                  training and quality assurance purposes;

(j)                  security purposes;

(k)                 administrative purposes;

(l)                  allowing technical support personnel to manage Our myeyes Service, infrastructure, systems, databases other applications or tools;

(m)               statistical analysis of the usage of Our myeyes Service or applications or tools that are accessed via the website; and/or

(n)                 complying with the law, including privacy legislation.

4.2                We may also may use the Personal Information to provide You with direct marketing communications where You have given Us Your consent.  In this case We may collect, hold, process, use and disclose Personal Information in accordance with that consent to enable Us to provide You (or other people who You are acting for) information about, and offer You (or other people who You are acting for), other products and services that We offer and which We consider may be of interest to You.

4.3                You consent to Us using any Personal Information (including any Sensitive Information) that We collect for any one of the purposes in this Privacy Policy for any of the other purposes stated in this Privacy Policy, other than for direct marketing for which We will seek Your consent separately. 

4.4                We do not provide Personal Information to third parties except as in accordance with this Privacy Policy, any agreement We have with You or as required by law.

4.5                If We sell some or all of Our business or its assets then We will transfer any Personal Information to the acquirer as part of that transaction.

5.                  Disclosure of the Personal Information Interstate and/or Overseas

5.1                Our myeyes Service and Our website are hosted in Australia.

5.2                We may send Personal Information interstate and/or overseas in the following circumstances:

(a)                 where We have a supplier assisting Us with providing assistance with Our business activities and functions. We have no control over where these suppliers hold or process their data and it is impractical for Us to be able to advise You of the states, territories or countries where the Personal Information may be held or processed;

(b)                 where a third party application is being used in connection with Our interactions with You, e.g. when We use email or video call applications the third party providers of the relevant application have their applications hosted overseas. We have no control over where these third party providers host their applications and it is impractical for Us to be able to advise You of the states, territories or countries where the Personal Information may be held or processed.

6.                  Use of Social Media

6.1                Our website uses social media includes blogs, Twitter feeds, and links to other social media, including Facebook, Linked In, Twitter, etc.  The nature of social media is that these applications actively enable the collection, use and personal profiling of You for many purposes, including targeted marketing and the disclosure and distribution of that information to third parties for those third parties (or the organisations that they on-transfer Your Personal Information to) to use for targeted re-marketing or many other purposes, including many uses or purposes that You may not appreciate the potentially significant adverse impact on You (especially when Your Personal Information is matched with other large data sets), as set out in the terms of use of those applications.

6.2                All information that is posted by You in a third party application, blog, twitter feed or other social media in connection with any of Our websites should be considered as public information that may be used, copied, adapted by any person for any means, transferred to any third party for any purpose, including targeted re-marketing to You and others, either alone or matched with other data sets and should not be posted unless You are prepared to allow others to do any of the things that are stated in their terms of use or privacy policies (if any).

6.3                We accept no responsibility or liability for any Personal Information that You publish on any third party application or social media application.

7.                  Cookies, Metadata and Site Data Activity

7.1                A cookie is a small piece of computer code which remains on Your computer, mobile phone or other access device and contains information which helps identify Your browser. A cookie can be used to identify You, either by itself or with other data that is generated by Our website or Our myeyes Service or that We or others may have access to.

7.2                If You do not want Us (or third parties) to use cookies then You may be able to stop them, or be notified when they are being used, by adopting the appropriate settings on Your browser.

7.3                If You do not allow some of the cookies to be used some or all of Our website or Our myeyes Service or other applications or tools on it might not be accessible to You.

7.4                Sometimes information that You upload is provided with associated metadata.  If You do not want Us (or third parties) to use the metadata You must remove it by erasure from the underlying document/materials properties before uploading it onto the website and other applications and tools.

7.5                We may collect data that is associated with Your visit to Our website or Our myeyes Service, including the pages Your visit, the activities You undertake on Our website or Our myeyes Service, the preferences You indicate, the applications and tools You use, the purchases You make, and the competitions You enter, etc.  We may also collect information relating to the computer, mobile phone or other device including the device type, browser, location, IP address and search words used.  We may collect, use, disclose, process and store such information in any of the ways set out in this Privacy Policy.

8.                  Links to other websites and applications

8.1                Our website includes links to other websites, applications and tools that are not owned or operated by Us. We not responsible for the content of those websites, applications or tools, nor for any products, services or information contained in them or offered through them. You should review the privacy policies and terms and conditions of use of those websites, applications and tools when You visit them. We do not endorse, recommend, condone or represent the companies or any content on any third party linked website and may terminate the link or linking program at any time.

9.                  How to access and seek correction of Your Personal Information or complain

9.1                Under applicable privacy legislation, We must ensure that Your Personal Information is accurate and up to date. Therefore, please advise Us of any changes to Your Personal Information promptly.

9.2                If You want to find out what Personal Information We hold on You or You believe any of Your Personal Information that is held by Us is inaccurate, out of date, incomplete, irrelevant or misleading or it is not necessary for Us to continue to hold it, You can contact Us, and We will either provide You with access to the Personal Information (in so far as We are required to do so by law,) or We will correct it, as applicable, within a reasonable period. We may make a reasonable charge for giving You access to Your Personal Information, but We will not charge for You making the request, correcting Personal Information or making a statement as to why We are not correcting Your Personal Information. You can contact Us by:

(a)                 email at the following email address: info@myeyes.net.au;

(b)                 using the Contact Us feature in Our website or in Our myeyes Service.

9.3                If You wish to complain about a breach of any Australian Privacy Principle that binds Us, a registered privacy code that binds Us, or this Privacy Policy You should contact Us by:

(a)                 email at the following email address: info@myeyes.net.au;

(b)                 using the Contact Us feature in Our website or in Our myeyes Service.

9.4                We will use Our best efforts to respond to any complaint within 10 business days of the date of receipt.  We will attempt to resolve Your complaint to Your satisfaction. If You are not satisfied with how We deal with Your complaint You may contact the Australian Information Commissioner, whose contact details can be found at http://www.oaic.gov.au/.