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1. Privacy Policy for Users of Website

[] is operated by [I. C. Mirth Sydney PTY Limited] who is referred to in this Privacy Policy as “we”, “us”, “our” and similar grammatical forms.

By registering for an account with us, you are accepting the terms of this Privacy Policy, and you are consenting to our collection, use, disclosure, retention and protection of your personal information as described in this Privacy Policy.

We appreciate that your privacy is important to you, [I. C. Mirth Sydney PTY Limited] will continue to protect the personal information you provide us and we will manage your personal information in compliance with the Privacy Act and the Australian Privacy Principles (APPs).

We will take all reasonable steps to ensure that all information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment.


1.1 When Do We Collect Information?

We do not automatically collect personal information from you, such as your name, address, phone number, email address or other personally identifiable information about you (personal information). We collect three categories of information when you use our website:

(a) the personal information you voluntarily provide — that is, we collect personal information with your informed consent;

(b) anonymous non-personal information about how you use our website; and

(c) “cookie” based information (see below) that makes your use of our website easier by recording your preferences so that when you return to our website the cookie re-loads that information into your web browser.

For example, we will collect personal information from you when you register on our websites, place an order, subscribe to our newsletter, respond to a promotional offer, competition or survey or fill out a form related to any customer service feature operating on our websites.

1.2 Why Do We Need To Collect Personal Information?

We collect personal information when you volunteer that information in order to receive a service from our website. The personal information collected on our websites will be used to provide the services you have requested, such as setting up and managing your account in the Platform.

1.3 What Information Do We Collect?

The type of information we collect from you will depend on what services on our website that you use. The personal information we may collect includes your name, postal address, email address, telephone numbers and contact details and information for identification purposes. If you pay for goods and/or services by credit card or debit card or direct debit from your bank account we will collect your card or bank account details.

General information about visits to our websites is collected by our computer servers, with small files (cookies) that our websites transfers to your computer’s hard drive through your Web browser (if you allow the delivery of cookies). The cookies are used to follow the pattern of movements of users by letting us know which pages on our websites are visited, in what order and how often and the previous website visited. The anonymous non-personal information that when collect and analyse is not personal information as described in the Privacy Act.

1.4 Why Do We Use Cookies and Other Web Use Tracking Technologies?

When you access our website, a small files containing a unique identification (ID) number may be downloaded by your web browser and stored in the cache of your computer. The purpose of sending these files with a unique ID number is so that our website can recognise your computer when you next visit our website. The cookies that are shared with your computer can't be used to discover any personal information such as your name, address or email address they merely identify your computer to our websites when you visit us.

We can also log the internet protocol address (IP address) of visitors to our website so that we can work out the countries in which the computers are located.

We collect information using cookies and other tracking technologies for the following reasons:

(1) to help us monitor the performance of our website so that we can improve the operation of the website and the services we offer;

(2) to provide personalised services to each user of our website to make their navigation through our website easier and more rewarding to the user;

(3) to sell advertising on the website in order to meet some of the costs of operating the website and improve the content on the website; and

when we have permission from the user, to market the services we provide by sending emails that are personalised to what we understand are the interests of the user.

Even if you have given us permission to send you emails, you can, at any time, decide not to receive further emails and will be able to unsubscribe from that service.

If you are unhappy about having a cookie sent to you, you can set your browser to refuse cookies or choose to have your computer warn you each time a cookie is being sent. However, if you turn your cookies off, some of our services may not function properly.

1.5 How Do We Store Your Information?

We use different technologies and procedures to help protect personal information from unauthorized access, loss, alternation, disclosure or use. Some of the safeguards we use are physical access controls, information firewalls and access authorisation controls to where your personal information is held in data centres. We also use data encryption when personal information is transferred to and from our service providers. Our commitment to data security means:

(1) we have procedures to limit access to personal information within our organisation;

(2) we use security measures and technologies within our organisation to protect your personal information; and

(3) we use service providers that can establish that they have secure controls relating to software security, access security and network security, including where credit card information is being transferred.

1.6 What Use Do We Make of Your Personal Information?

We will communicate with you in relation to the management of your account with the Platform which will include providing you with information about Online Services.

We may send you information and updates about any other product, service or information that we provide to our customers; in addition we may send you occasional company news and information about other products and services or special promotional offers of our affiliated companies. If at any time you would like to stop receiving future commercial messages from us, we include detailed unsubscribe instructions at the bottom of each email.

We may also release your personal information when we believe release is appropriate to comply with the law, enforce our subscription agreements, website policies and terms & conditions, or protect ours or others rights, property, or safety.

1.7 How Can I Access The Personal Information That You Collect?

We are happy to provide you with details of personal information held about you. APP 12 allows you to get access to, and correct, the personal information we hold about you.

To access this information, you need to email or write to us using the contact details below. Please also include your account number if you are a Patient.

APP 13 allows you to ask us to take reasonable steps to correction any personal information that is inaccurate, out of date, incomplete, irrelevant or misleading.

If you believe that your personal information has been misused, you can inform us of your complaint by writing to our address and we will attempt to resolve the matter.

[I. C. Mirth Sydney PTY Limited]


If you are not satisfied with the outcome of your complaint you may refer the matter to the Office of the Australian Information Commissioner (OAIC). Telephone: 1300 363 992

OAIC complaints page:

1.8 Third Party Links

Our websites may include links to websites operated by third parties. We have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of our websites and welcome any comment about linked websites.

1.9 Terms of Use of the Platform

Please also visit our Terms of Access and our Terms of Use of the Platform which sets out the conditions of use and limitations of liability governing the use of our Website.

1.10 Your Consent

By using our Website, you consent to this Privacy Policy.

1.11 Changes to Our Privacy Policy

If we decide to change this Privacy Policy, we will post those changes on this page, and update the Privacy Policy modification date below.

This Privacy Policy was last modified on 28/9/2019.

2 Privacy Policy for Patients

2.1 Introduction

(a) Patient privacy is extremely important to us. This statement (Patient Privacy Policy) contains details of our policies, procedures and practices regarding the collection, use and disclosure of any sensitive information and/or health information that you provide through the Platform.

(b) The Patient Privacy Policy is part of our Terms of Use of the Platform which can be found at. The terms in the Patient Privacy Policy (such as, but not limited to, "we", "our", “us", "Platform", etc) have the same meaning as in our Terms of Use of the Platform. When you use our Platform you accept and agree to both the Terms of Use of the Platform and to the Patient Privacy Policy. If you do not agree to be bound to the Patient Privacy Policy you should stop using the Platform immediately. By accessing and using our Platform you affirm that you have read the Terms of Use of the Platform and the Patient Privacy Policy and that you understand, agree and acknowledge to all the terms contained in both of them.

2.2 Information Collection, Use, and Disclosure

(a) To let us operate the Platform effectively and to let you use the Platform, including the Online Services, we may have to collect your personally identifiable information (such as, but not limited to, your name, phone number, email address, and address), billing and payment information, profile information, log data (information such as your computer, IP address, pages that you visit and the amount of time spent on those pages, actions you take and other statistics), information related to the Online Services or your need for Online Services, and any information which is exchanged between you and your Therapist (collectively the Information). In some cases, some of the Information that you give to us is considered sensitive information and/or health information. You may decide which Information, if any, you would like to share with us, but some functions of the Platform or Online Services may not be available to you without providing us the necessary Information. By deciding to provide the Information you agree to our methods of collections and use, as well to other terms and provisions of this Patient Privacy Policy.

(b) Protecting this Information is a top priority for us. We will never sell or rent any Information you shared in the Platform. Other than in the limited ways detailed in this Patient Privacy Policy, we will never use or disclose any Information except for the Primary Purpose of a Permitted Secondary Purpose (see Terms of Use of the Platform paragraphs 2.2 and 2.4) unless you specifically and explicitly requested or approved us to do so.

(c) The Information may be used for the following purposes:

(i) To create your account on our Platform and let you log in to your account and use the Platform.

(ii) To manage your account, provide you with customer support, and ensure you are receiving quality service.

(iii) To contact you or provide you with information, alerts and suggestions that are related to the service.

(iv) Billing-related purposes.

(v) To reach out to you, either ourselves or using the appropriate authorities, if either we or a Therapist have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.

(vi) To match you with a Therapist or other health services provider.

(vii) To enable and facilitate the Online Services.

(viii) To supervise, administer and monitor the Platform.

(ix) To measure and improve the quality, the effectiveness and the delivery of the Online Services.

2.3 Cookies and Web Beacons

Like many websites, we use "cookies" and "web beacons" to collect information. A "cookie" is a small data file that is transferred to your computer's hard disk for record-keeping purposes. A "web beacon" is a tiny image, placed on a Web page or email that can report your visit or use. We use cookies and web beacons to enable the technical operation of the Platform, to administer your log-in to your account. You can change your browser's settings so it will stop accepting cookies or to prompt you before accepting a cookie. However, if you do not accept cookies you may not be able to use the Platform. The Platform may also include the use of cookies and web beacons of services owned or provided by third parties that are not covered by our Patient Privacy Policy and we do not have access or control over these cookies and web beacons. We may also use third party cookies for the purposes of web analytics, attribution and error management.

2.4 Social Media Tools

We use several publicly-available tools and information exchange resources, such as (but not limited to) a blog, YouTube, a Facebook page, a Twitter account, and others (collectively Social Media Tools). Any information you provide or share while using Social Media Tools may be read, accessed, and collected by that site and users of that site according to their privacy policy.

2.5 Phishing

Online identity theft and account hacking, including the practice currently known as "phishing", are of great concern. You should always be diligent when you are being asked for your account information and you must always make sure you do that in our secure system. We will never request your login information or your credit card information in any non-secure or unsolicited communication (email, phone or otherwise).

2.6 Links

The Platform may contain links to other websites, services or offers which are owned, operated or maintained by third parties. If you click on a third party link, you will be directed to that third website or service. The fact that we link to a website or service is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not have control over third party websites and services and we do not have control over their privacy policies and terms of use.

2.7 Security

While using any Internet-based service carries inherent security risks that cannot be 100% prevented, our systems, infrastructure, encryption technology, operation and processes are all designed, built and maintained with your security and privacy in mind. We apply industry standards and best practices to prevent any unauthorized access, use, and disclosure. We comply with or exceed all applicable federal laws, state laws, and regulations regarding data privacy.

2.8 Service Providers

We may employ third party companies and individuals to facilitate the Platform, to perform certain tasks which are related to the Platform, or to provide audit, legal, operational or other services for us. These tasks include, but not limited to, customer service, technical maintenance, monitoring, email management and communication, database management, billing and payment processing, reporting and analytics. We will share with them only the minimum necessary information to perform their task for us and only after entering into appropriate confidentiality agreements.

2.9 Children's Privacy

We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to become our user. The Platform is not directed and not intended to be used by children under the age of 13. If you're aware that we have collected Information from a child under age 13 please let us know by contacting us and we will delete that information.

2.10 International Transfer

Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction. Regardless of where your data is stored, it will be maintained securely as outlined in this policy. Your consent to our Terms of Use of the Platform followed by your submission of such information represents your agreement to such transfers.

2.11 Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose information necessary or appropriate to protect the safety of the public or any person, to respond to claims and legal process (including but not limited to subpoenas), and to prevent or stop activity that may be illegal or dangerous. You should also be aware that Therapists may be obliged to disclose information to law enforcement or other authorities to conform to their professional and legal responsibilities. Specifically, and without limitation, you should be aware that the law requires mental health professionals to disclose information and/or take action in the following cases:

(a) reported or suspected abuse of a child or vulnerable adult;

(b) serious suicidal potential;

(c) threatened harm to another person;

(d)court-ordered presentation of treatment.

2.12 Changes to the Patient Privacy Policy

We may update this privacy statement at our sole discretion. The date of the last revision of this policy appears at the end of this page. We encourage you to periodically review this page for the latest information on our Patient Privacy Policy and practices. Regardless of changes to our Patient Privacy Policy, we will never use the information you submit under our current privacy notice in a new way without first notifying you and giving you the option to opt out.

2.13 Contacting Us

If you have any questions or concerns about this Patient Privacy Policy or our privacy-related practices, please contact us at:

[I. C. Mirth Sydney PTY Limited]


Last Updated: 28/9/2019

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