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Privacy policy – Hearing Choices www.hearingchoices.com.au is operated by by Hearing Choices Hearing Australia Pty Ltd (ACN 610 674 818) in its capacity as trustee for the Hearing Choices Unit Trust (trading as “Hearing Choices”) who is referred to in this Privacy Policy as “we”, “us”, “our” and similar grammatical forms. By using the Hearing Choices website, 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. Hearing Choices will continue to protect the personal information you provide us and we will manage your personal information in compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). We are bound by the Australian Privacy Principles contained in the Privacy Act 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. 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:

• the personal information you voluntarily provide — that is, we collect personal information with your informed consent;
• anonymous non-personal information about how you use our website; and
• “cookie” based information 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 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. We also collect information when you communicate with us through correspondence, chats, email, or when you share information with us from other services or websites;

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 contact you and provide more information on the services you have requested. Your personal information may be used in relation to any survey, promotional offer or any competition you may enter on our websites.

3. What information do we collect?

The type of information we collect from you will depend on which services on our website you use. The personal information we may collect includes your name,  email address, telephone numbers, details about your hearing loss and contact details and information for identification purposes.  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 and also to process orders. The anonymous non-personal information that we collect and analyse is not personal information as described in the Privacy Act.

4. Why do we use “cookies” and other web use tracking technologies?

When you access our website, a small file 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:

• to help us monitor the performance of our website so that we can improve the operation of the website and the services we offer;
• to provide personalised services to each user of our website to make their navigation through our website easier and more rewarding to the user;
• 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.

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:

• we have procedures to limit access to personal information within our organisation;
• we use security measures and technologies within our organisation to protect your personal information; and
• 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.

Our website is hosted in Australia. In addition, web traffic information we collect, such as data collected by Google Analytics may be stored overseas.

6. What use do we make of your personal information?

We will communicate with you in relation to any contact enquiry you make. We use your personal information to give you advice on hearing aids and other suitable products. After we receive authorisation from you, we will also pass on your information to a partner clinic who will contact you to arrange a consultation. We may send you information and updates about any other services 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 disclose personal information about customers to a range of third parties.  For example, depending on the type of product or service, we may disclose customer information to a wholesaler or other third party who provides or assists to provide the service. Personal information may also be disclosed to the relevant industry Ombudsman (for complaint management purposes) or relevant Government regulator in its servicing of regulatory obligations. Personal information may also be disclosed to third party agents and service providers who we engage to assist in the provision of products and services.  These include:

• sales agents and representatives;
• printers, mail distributors, couriers and dispatch centres;
• call centres operated by entities outside of Hearing Choices;
• IT service providers and data managers; and
• legal, accounting, insurance and business advisory consultants services.

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 the rights, property, or safety of us or others.

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. APP 13 allows you to ask us to take reasonable steps to correct 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 the following address and we will attempt to resolve the matter: email: hearing@hearingchoices.com.au 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 Email: enquiries@oaic.gov.au Website (OAIC complaints page): http://www.oaic.gov.au/privacy/privacy-complaints

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.

9. Terms and Conditions

Please also visit our Terms of Access to our Website http://www.hearingchoices.com.au/terms/ which sets out the conditions of use and limitations of liability governing the use of our Website.

10. Your consent

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

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 1 January 2020