Privacy Policy

We care about you and your privacy

At Oqea, we're committed to protecting your personal and sensitive information. That's why we've put together this policy. We want to ensure we provide a safe, trusted and secure environment to streamline the care coordination journey for all our users. We want to explain this in simple terms, however recognising the importance of your privacy, if we need to disclose information then the reason we are doing that is outlined in this policy.  

Introduction

In this Privacy Policy, we will refer to Oqea Pty Ltd (ACN 628 016 491) as "Oqea", "we", "us" and "our".

The term "Member" refers to a person accessing Oqea.me services.

Because we take your privacy seriously, we have designed this policy with careful reference to the  Australian Privacy Principles' and related privacy laws. We may also reference to related, third-party service providers' relevant privacy policies and associated documents.  It explains how we approach the important issues of privacy and the management of your personal information (as defined in the Privacy Act ("Personal Information").

Please contact Oqea's Privacy Officer (details are at the end of this Privacy Policy) if you require any further information regarding our Privacy Policy.

Oqea provides two platforms:

Oqea.me:

• a two-sided marketplace, digital and AI platform for people (a "Member") to facilitate an on-demand hybrid mental healthcare between trusted people and professionals (the Member's "Care Team");
• A streamlined care coordination supporting a seamless user experience (efficiently and integrated) with curated wellbeing resources, peers and the Care Team; and
• Safe and secure communication tools, connecting the Member's Care Team.

Oqea.net:

• a secure online digital and AI platform for professionals to support a hybrid model of care coordination of a Member, to store, administer and share personal and sensitive information;
• a platform to assist professionals to automate onboarding sequences, Secure Care Team communications, referrals and appointment management, treatment tracking, biometric data, medication, medical history and connection with healthcare.

(together, our "Services")

Oqea is affiliated with Oqea Clinical Pty Ltd (ABN 73 653 194 640) ("Oqea Clinical" or "Oqea Cares"), a professional healthcare provider and a separate legal person. For Oqea Clinical's privacy policy, please visit https://oqeacares.au/privacy/.

In recognition of the critical importance of health information and it being kept confidential is to a Member, the way we collect, store and use the personal information and sensitive information of a Member is different from how we collect, store and use personal information of other individuals who interact with us.

We have divided this Privacy Policy into two parts:  Part A which relates to Members' personal information and Part B relates to individuals interacting with us other than as Members.

Where a person who is a Member also interacts with us and our Services other than via the Oqea.me platform, they do not do so as a Member, and that information is not associated with their information as a Member. The Member's sensitive information remains confidential.

This privacy policy applies to information we collect and use:

• for the purpose of and in the course of providing you and third parties the Services;
• in email, text, and other electronic messages between you and us;  
• when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this privacy policy; and
• when you interact with us.

This policy is not intended to cover categories of personal information which are not covered by the Privacy Act.

By choosing to use or interact with our Services, or visit our websites (including oqea.com, oqea.me, and oqea.net, ("Sites"), or otherwise interact with us, you consent and agree to this Privacy Policy of Oqea ("Policy").

The Australian Privacy Principles

The Australian Government introduced updated legislation in 2014 to the Privacy Act (1988), to further enhance the protection and handling of an individual's privacy and personal information.  These principles replace the previous National Privacy Principles that operated from 2001.  You can find out more about the Australian Privacy Principles by calling the Office of the Australian Information Commissioner on 1300 363 992 or through their website at www.oaic.gov.au

We respect and uphold your right to privacy protection under the Australian Privacy Principles in regulating how we collect, use, disclose and hold your Personal Information. We have procedures so only our authorised staff (being System Administrators) have access to your Personal Information and ensure that it remains confidential and is only used and disclosed for appropriate purposes, where you have consented, when there is a legal obligation to do so (e.g., subpoena or significant and imminent risk of harm), and in accordance with this policy.  

Part A – Management of personal information of Members

The personal information we collect, and why we collect it:

Information we receive when you as a Member uses our Services or Sites

The types of Personal Information we collect and hold about Members includes:

• your contact details, including your name, gender, date of birth, address, telephone numbers and email address;
• how you use and interact with Oqea.me; and
• Sensitive Information, either from you as a Member, from your medical professionals who use Oqea.net to share information with your Care Team, or from others in your Care Team.

Information about a Member on Oqea.Net
We do not collect, use or disclose a medical professional's records which they choose to store on Oqea.Net. With your consent as a Member, a medical professional who is part of your Care Team may make available records or information via Oqea.me which, will be in accordance with your chosen settings.  You should direct (and we will direct) any requests and enquiries relating to personal information in any such records to the relevant medical professional. They may have their own privacy policy and obligations for use, disclosure, modification and destruction of records.

Aggregated and Statistical Information
We may de-identify or anonymise Personal Information such that it is no longer Personal Information) and use it in aggregate. This aggregated information may be disclosed to third parties, including researchers, regulators and industry bodies.

When you visit our Sites or use our Services, we collect information about which of those services you have used and how you have used them. We might know, for instance, that you visited a certain page, or saw a specific advertisement for a certain period of time. Here's a fuller explanation of the types of information we collect when you use our services:

• Usage Information. We collect information about your activity through our Services. For example, we may collect information about how you purchase or interact with our Services or which queries you submit.
• Content Information. We collect information you provide directly via our Services and Sites, including how you engage with our Services and Sites. This includes both the obvious information you provide, and metadata relating to that information and engagement.
• Information Collected by Cookies and Other Technologies. Like most online services and mobile applications, we may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. We may also use these technologies to collect information when you interact with our Sites we may offer through one of our partners, such as advertising and commerce features.

Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that removing or rejecting cookies could affect the availability and functionality of our Services. To learn more about how we use cookies and your choices, please check out "Visiting our Site and Cookie Policy" below. To learn more about how third parties use these technologies on our Services, please read the "Analytics" section of this Policy.

• Log Information. We also collect log information when you use our Sites or Services. That information includes, among other things:
  • details about how you have purchased or used our Services;
  • device information, such as your web browser type and language;
  • access times;
  • pages viewed;
  • IP address;
  • identifiers associated with cookies or other technologies that may uniquely identify your device or browser; and
  • pages you visited before or after navigating to our Sites.

When the Law Authorises or Requires us to Collect Information
We may collect information about you because we are required or authorised by law to collect it. This includes mandatory reporting of child sexual abuse in Western Australia under the Children and Community Services Act 2004, and to Medicare under the Health Insurance Act 1973.

Information We Collect from Third Parties
We may collect Personal Information about you from other users, our clients, and third parties such as recruiters, or your employer if:

• you consent to us collecting Personal Information from them; or
• we are authorised to do so under the law, or a court or tribunal order; or
• it is unreasonable or impracticable for us to collect personal information only from you.

Opting-Out or Modifying Your Information
If you want to change any information that you have previously given us, or if you want to opt out of future communications please contact Oqea's Privacy Officer as detailed below.

How We Collect Your Personal Information
As a Member, we collect your Personal Information when you or your Care Team provides it to Oqea in a number of ways including:

• directly from you through our Sites or the Services;
• as authorised or consented to by you providing us with your Personal Information;
• by voluntary completion of questionnaires on our Sites or the Services;
• by your family, carers, guardians, friends and peer supporters, in which case we ask them to obtain your consent prior to disclosing it to us;

Sometimes we collect information about you from other sources. We do this only if it is necessary to do so. Instances of when we may need to include where:

• ▪ we cannot readily contact you and we rely on publicly available information to update your contact details; and
• ▪ at your request, we exchange information with your medical or other representatives.

Also:

• ○ we may ask for other information from you from time to time to enable us to improve the Services.

In some cases, you might provide Personal Information to us by entering it into forms which stores the information in our cloud-based servers. Alternatively, your information may be disclosed to us by an organisation with whom you interact and to which we provide a cloud-based Service (including Oqea.Net).

When we collect or hold Personal Information in this way, it is only used or disclosed for the primary purpose as described in this Privacy Policy, or the organisation that has disclosed that information to enable us to provide the Services.

Personal Information may be stored on our web servers but will only be accessed by us to provide technical support, or to carry out other functions reasonably necessary to provide the Services. This Personal Information will not be disclosed in any other way without your written consent.

What Do We Do When We Get Information We Did Not Ask For?
People sometimes share information with us we have not sought out (referred to as ‘unsolicited information').

Where we receive unsolicited Personal Information about you, we will check whether that information is necessary for our Services, functions or activities. If it is, we will handle this information the same way we do with other information we seek from you. If not, we will ensure we do the right thing and destroy or de-identify it.

When Will We Notify You That We Have Received Your Information?
When we receive Personal Information from you directly, we either have already taken or we will take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint.

Sometimes we collect your Personal Information from third parties. You may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.

How do we use your Personal Information?

Using and disclosing your Personal Information as a Member

As a Member, you direct how your health information is used and disclosed, including by:

• including and removing the people in your Care Team; and
• choosing what information each individual in your Care Team can include, access and share.

To remove a medical professional from your Care Team, please contact us on [email protected]

We may use your Personal Information (other than Sensitive Information) to:

• send you information about our Services. Each time we send you a direct marketing communication we will provide you with a simple way to "opt out" of receiving similar communications in the future.
• allow us to run our business and perform administrative and operational tasks, such as:
  • training staff;
  • developing and marketing products and services;
  • risk management;
  • systems development and testing, including our Sites, Services and other online channels;
  • undertaking planning, research and statistical analysis;
  • preventing or investigating any fraud or crime, or any suspected fraud or crime;
  • as required by law, regulation or codes binding us;
  • managing our relationship with our clients;
  • investigating and dealing with suspected or actual unlawful activity;
  • assisting with recovering amounts owing to us; and
  • for any purpose for which you have given your consent.

Use of Technology
We use, in addition to our own proprietary technologies and systems, various third-party software and technologies, each of which may have their own privacy policies and terms of use.

Please also note, owing to the ever-changing nature of technology and to provide optimal support to you, we may use different third-party support software and platforms from time to time.  To that, any such Personal Information data stored or processed will also be subject to the privacy policies of those relevant individual third parties and platforms.

We may use your Personal Information to the extent that is reasonably necessary to carry out the Services including for the following purposes:

• to deliver and improve our Services and our Sites;
• to provide personalised and direct marketing content to your email address, mobile phone, portable computing and other digital technology devices;
• to compile analytics in sizing or quantifying market opportunity;
• to predict market opportunity forecasting and resource allocation; and
• to disclose to other businesses who assist us or our customers in providing services or who perform functions on our customers' behalf.

How We Keep Your Personal Information Secure
Our IT infrastructure is in secure buildings with restricted access. Our IT systems are password protected and we conduct regular audit and data integrity checks.

We frequently update and review our IT security software in order to protect our systems (and the data contained in those systems) from cyber security threats. In addition, all our employees are required, as a condition of employment, to treat Personal Information held by Oqea as confidential.

We store your Personal Information in cloud-based servers. These cloud servers are situated in Australia. The cloud server providers are required to keep all information stored confidential.

If we store your Personal Information on a remote, "Cloud" or offsite server we will endeavour to protect your Personal Information through security measures such as password protection and encryption.

Destroying Personal information
We may destroy or de-identify the Personal Information provided by you once it is no longer needed for our Services. However, we may, in addition to the reasons already disclosed in this Privacy Policy, in certain circumstances be required by law to retain Personal Information after our Services have been completed.

In this case, the Personal Information will continue to be protected in accordance with this Privacy Policy. If we destroy Personal Information we will do so by taking reasonable steps and using up-to-date techniques and processes.

Our Site's Security
By using our Site and Services you acknowledge and agree that the internet is inherently insecure and that you use the internet at your own risk.  You acknowledge that you do not hold Oqea or its directors, representatives, employees, contractors, suppliers or clients liable for any security breaches, viruses or other malicious software that may infect your computer or other internet browsing device, or any loss of data, revenue or otherwise that may occur as a result of using our Site.

We strive to ensure the security of your Personal Information and we take reasonable steps to protect your Personal Information from:

1. a) misuse, interference and loss; and
2. b) unauthorised access, modification or disclosure.

We will review and update our physical and data security measures in light of current technologies. Unfortunately, no data transmission over electronic, mobile data and communication services can be guaranteed to be totally secure.

Our employees and contractors who provide services related to our information systems are obliged to respect the confidentiality of any Personal Information held by us.

We will do everything reasonably our power and control to prevent unauthorised use or disclosure of your Personal Information. However, we will not be held responsible for events arising from any unauthorised use or access to your Personal Information.

Certain sections of our Site are secured using industry-standard SSL/TLS technology to encrypt data between your browser and the Site.

Social Networking Services
We may use social networking services such as Facebook, Instagram, and LinkedIn to communicate with you and the public about our Services. When you communicate with us using these social networking and digital media services we may collect your Personal Information, but we only use it to help us to communicate with you and the public.

We will not use social networking services in connection with you as a Member without your express consent.

The social networking and digital media services will also handle your Personal Information for its own purposes. These services have their own privacy policies. You can access the privacy policies for Facebook, Instagram, LinkedIn and other social media platforms, on their respective Sites.

Spam Act
We adhere to the Spam Act 2003 (Cth). The Spam Act prohibits the sending of unsolicited emails, SMS and MMS messages for commercial purposes from or within Australia or to people in Australia. The Spam Act also bans the supply and use of software designed to harvest email addresses.

How to Access, Correct or Update Your Personal Information
If you have any complaints, questions or concerns about what information we hold or about the accuracy of that information, please contact Oqea's Privacy Officer.

If you would like to access the information that we hold about you, or to complain about a possible breach of the Australian Privacy Principles, you can write to Oqea's Privacy Officer at the address provided below.

We will respond to your complaint or endeavour to give you access to the information requested within two weeks. In order to maintain the confidentiality of your personal information, we will ask you to meet with us so we can review your specific identification documents before we give you access. If it is not practical for you to meet us in person, we will arrange to check your identification before we mail the information out to you.

If the information that we hold about you is incorrect or not up-to-date, we will update it as soon as possible after you have shown us how and why it is incorrect.

In the unlikely event that we are unable to provide you with access to your personal information for legal reasons as specified in the Privacy Act, we will provide you with reasons for denying access.

If you are not satisfied with our response to your complaint, question or concern, you may wish to lodge a complaint with the Office of the Australian Information Commissioner. Further information can be found on the Commissioner’s Site or by calling 1300 363 992.

We do not collect, use or disclose a medical professional's medical records which the medical professional chooses to store on Oqea.Net. Accordingly, we will direct any requests and enquiries relating to personal information in any such records to the relevant medical professional. They may have their own privacy policy and obligations for use, disclosure, modification and destruction of records.  

Part B – management of personal information of individuals other than as Members

Please remember that where a person who is a Member also interacts with us and our Services other than via the Oqea.me platform, they do not do so as a Member, and that the information collected and stored is not associated with their information as a Member. The Member's sensitive information remains confidential.

Information We Receive When You Use Our Services or Sites
The types of Personal Information we collect and hold about individuals other than as Members relates to the contact details of users of Oqea.net, individuals in a Care Team, clients, suppliers and other business contacts. This will typically not include health information. Typically, this information includes names, birth dates, addresses, telephone numbers, e-mail addresses and job titles. In the course of providing the Services, we may collect and hold more detailed personal information, for example:

• government identifiers such as Tax File Number, drivers' license, passport and Medicare numbers and visa/work permit status;
• ID information such as your name, postal or email address, telephone numbers, and date of birth;
• other contact details such as social media handles;
• credit information such as details relating to credit history, credit capacity and eligibility for credit (‘credit worthiness');
• details of superannuation and insurance arrangements;
• educational qualifications, employment history and salary; and
• personal information about your spouse and dependents.

We will otherwise not collect Sensitive Information unless you have consented to give this information and it is relevant to our Services.

We will always collect such information in a non-intrusive, lawful and fair manner, and only when you have consented to the collection of such information.

Your Personal Information and Sensitive Information is only collected as is necessary for us to carry out our work and deliver our Services.

Aggregated and Statistical Information
We may de-identify or anonymise Personal Information (such that it is no longer Personal Information) and use it in aggregate. This aggregated information may be disclosed to third parties, including researchers, regulators and industry bodies.

When you visit our Sites or use our Services, we collect information about which of those services you have used and how you have used them. We might know, for instance, that you a visited a certain page, saw a specific ad for a certain period of time. Here’s a fuller explanation of the types of information we collect when you use our services:

• Usage Information. We collect information about your activity through our Services. For example, we may collect information about how you purchase or interact with our Services or which queries you submit.
• Content Information. We collect content, queries, and responses that you engage with via our Services and Sites, such as custom content and information about the content you create or provide, such as if the recipient has viewed the content and the metadata that is provided with the content.
• Information Collected by Cookies and Other Technologies. Like most online services and mobile applications, we may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. We may also use these technologies to collect information when you interact with our Sites through one of our partners, such as advertising and commerce features.

Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that removing or rejecting cookies could affect the availability and functionality of our Services. To learn more about how we use cookies and your choices, please check out “Visiting our Site and Cookie Policy” below. To learn more about how third parties use these technologies on our Services, please read the “Analytics” section of this Policy.

• Log Information. We also collect log information when you use our Sites or Services. That information includes, among other things:
• details about how you have purchased or used our Services
• device information, such as your web browser type and language
• access times
• pages viewed
• IP address
• identifiers associated with cookies or other technologies that may uniquely identify your device or browser
• pages you visited before or after navigating to our Sites

When the Law Authorises or Requires us to Collect Information
We may collect information about you because we are required or authorised by law to collect it. There are laws that affect financial institutions which may require us to collect personal information, like the National Consumer Credit Protection Act and The Anti-Money Laundering and Counter-Terrorism Financing Act.

Information We Collect from Third Parties
We may collect Personal Information about you from other users, our clients, and third parties such as recruiters, or your employer if:

• you consent to us collecting Personal Information from them; or
• we are authorised to do so under the law, or a court or tribunal order; or
• it is unreasonable or impracticable for us to collect personal information only from you.

Opting-Out or Modifying Your Information
If you want to change any information that you have previously given us, or if you want to opt out of future communications please contact Oqea's Privacy Officer as detailed below.

How We Collect Your Personal Information
For individuals other than as Members, we collect your Personal Information when you provide it to Oqea in a number of ways including:

• directly from you through our Sites or the Services;
• as authorised or consented to by you providing us with your Personal Information;
• by voluntary completion of questionnaires on our Sites or Services;
• from public domain;
• from authorised third-party data sources and data lists for the purposes of providing our Services;
• from your personal or business, health and medical professionals, advisors, partners, associates, employers, recruiters, and potential employers; and
• by your usage of the Sites e.g. the pages that you visit, what links you click by contacting us by post, telephone, email, or other electronic methods.

Sometimes we collect information about you from other sources. We do this only if it is necessary to do so. Instances of when we may need to include where:

• ▪ we cannot readily contact you and we rely on publicly available information to update your contact details; and
• ▪ at your request, we exchange information with your medical or other representatives.

Also:

• ○ we may ask for other information from you from time to time to enable us to improve the Services.

In some cases, you might provide Personal Information to us by entering it into forms which stores the information in our cloud-based servers. Alternatively, your information may be disclosed to us by an organisation with whom you interact and to which we provide a cloud-based Service (including Oqea.Net).

When we collect or hold Personal Information in this way, it is only used or disclosed for the primary purpose as described in this Privacy Policy, or the organisation that has disclosed that information to enable us to provide the Services.

Personal Information may be stored on our web servers but will only be accessed by us to provide technical support, or to carry out other functions reasonably necessary to provide the Services. This Personal Information will not be disclosed in any other way without your written consent.

What Do We Do When We Get Information We Did Not Ask For?
People sometimes share information with us we have not sought out (referred to as ‘unsolicited information').

Where we receive unsolicited Personal Information about you, we will check whether that information is reasonably necessary for our Services, functions or activities. If it is, we will handle this information the same way we do with other information we seek from you. If not, we will ensure we do the right thing and destroy or de-identify it.

When Will We Notify You That We Have Received Your Information?
When we receive Personal Information from you directly, we either have already taken or we will take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint.

Sometimes we collect your Personal Information from third parties. You may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.

How do we use your Personal Information?

Using your Personal Information other than as a Member.
We may use your Personal Information when:

• providing our Service to our clients, including:
  
  • considering whether you may be suitable for a particular role in that regard;
  • processing your Personal Information and compiling a report for our clients; or
  • administering the Services we provide to our clients.
• we may send you information about our Services. Each time we send you a direct marketing communication we will provide you with a simple way to "opt out" of receiving similar communications in the future.
• assisting in arrangements with other organisations in relation to a service we make may available in future;
• allowing us to run our business and perform administrative and operational tasks, such as:
  
  • training staff;
  • developing and marketing products and services;
  • risk management;
  • systems development and testing, including our Sites and other online channels;
  • undertaking planning, research and statistical analysis;
  • preventing or investigating any fraud or crime, or any suspected fraud or crime;
  • as required by law, regulation or codes binding us;
  • managing our relationship with our clients;
  • investigating and dealing with suspected or actual unlawful activity;
  • assisting with recovering amounts owing to us; and
  • for any purpose for which you have given your consent.

Use of Technology
We use, in addition to our own proprietary technologies and systems, various third-party software and technologies, each of which may have their own privacy policies and terms of use.

Please also note, owing to the ever-changing nature of technology and to provide optimal support to you, we may use different third-party support software and platforms from time to time. To that, any such Personal Information data stored or processed will also subject to the privacy policies of those relevant individual third parties and platforms as may vary.

We may use your Personal Information to the extent that is reasonably necessary to carry out the Services including for the following purposes:

• to deliver and improve our Services and our Sites;
• to provide personalised and direct marketing content to your email address, mobile phone, portable computing and other digital technology devices;
• to compile analytics in sizing or quantifying market opportunity;
• to predict market opportunity forecasting and resource allocation;
• to disclose to other businesses who assist us or our customers in providing services or who perform functions on our customers' behalf; and
• to conduct credit checks (if and where necessary).

How We Keep Your Personal Information Secure
Our IT infrastructure is in secure buildings with restricted access. Our IT systems are password protected and we conduct regular audit and data integrity checks.

We frequently update and review our IT security software in order to protect our systems (and the data contained in those systems) from cyber security threats. In addition, all our employees are required, as a condition of employment, to treat Personal Information held by Oqea as confidential.

We store your Personal Information in cloud-based servers. These cloud servers are situated in Australia. The cloud server providers are required to keep all information stored confidential.

If we store your Personal Information on a remote, "Cloud" or offsite server we will endeavour to protect your Personal Information through security measures such as password protection and encryption.

In other cases, we retain and store your Personal Information (whether onsite, offsite or on the cloud) indefinitely, unless you instruct us otherwise.

Destroying Personal information
We may destroy or de-identify the Personal Information provided by you once it is no longer needed for our Services. However, we may, in addition to the reasons already disclosed in this Privacy Policy, in certain circumstances be required by law to retain Personal Information after our Services have been completed.

In this case, the Personal Information will continue to be protected in accordance with this Privacy Policy. If we destroy Personal Information we will do so by taking reasonable steps and using up-to-date techniques and processes.

Disclosing your Personal Information

Using your Personal Information other than as a Member
We may disclose your Personal Information to third parties but only for the purposes of providing the Services and for the purposes contemplated by your use of the Site. These third parties may include:

• industry bodies of which we are a member;
• those involved in providing, managing or administering the product or service we provide to you;
• authorised representatives and staff of Oqea who sell products or services on our behalf;
• other financial institutions, such as banks;
• organisations involved in debt collecting, including purchasers of debt;
• fraud reporting agencies (including organisations that assist with fraud investigations and organisations established to identify, investigate and/or prevent any fraud, suspected fraud, crime, suspected crime, or misconduct of a serious nature);
• government or regulatory bodies (including ASIC and the Australian Tax Office) as required or authorised by law (in some instances these bodies may share it with relevant foreign authorities);
• our accountants, auditors or lawyers and other external advisers;
• organisations that maintain, review and develop our business systems, procedures and technology infrastructure, including testing or upgrading our computer systems;
• organisations that participate with us in payments systems including merchants, payment organisations and organisations that produce statements for us;
• organisations that assist with our product planning, research and development;
• other organisations involved in our normal business practices, including our agents and contractors;
• where you've given your consent;
  • other digital technology services and platform-providers;
  • our partners, agents or contractors (worldwide);
  • data collection and marketing providers (worldwide);
  • our related entities; and
  • our professional advisers.

We may disclose your personal information:

• when specifically authorised by you;
• to professional and insurance advisors;
• to regulatory bodies and government agencies;
• to training partners;
• to your guardian; and
• as required by law or court order.

We may disclose Personal Information for the following purposes:

• reporting to government agencies;
• to obtain professional or insurance advice;
• to comply with training requirements;
• to comply with regulatory or legal requirements;
• credit reporting and checks; and
• to comply with laws or court orders.

When we disclose your Personal Information with a third party, we will require the third party to handle your Personal Information in accordance this Policy and the Australian Privacy Principles.

Oqea may sometimes use third party service providers to conduct surveys and facilitate information collection. Some of these service providers conduct all or part of their business overseas and so your personal information may be transferred overseas as a result.

Oqea conducts a due diligence process before entering into an agreement with these service providers and will take all reasonable steps to ensure that your information is not used in a manner inconsistent with the Australian Privacy Principles.

Web traffic information is disclosed to Google Analytics when you visit any of our Sites. Google stores information across multiple countries. When you communicate with us through a social network service such as Facebook or X/Twitter, the social network provider and its partners may collect and hold your personal information overseas.

Visiting our Site and Cookie Policy

Our Site may use ‘cookies' to improve your experience on our site, to display content more relevant to you within the Site, and to display items added while using online facilities. If you are concerned about the use of these cookies, your browser can be configured to notify you when you receive a cookie, and provide you with the opportunity to accept or reject it. You may refuse all cookies from our Site, however some functions may be unavailable.

Our Site may use statistical information collection tools (such as Google Analytics) to track site visits, navigation and performance within our Site for the purpose of monitoring and improving the site. If you are concerned about the use of these tools, you can configure your browser to send a "Do Not Track" request with your browsing traffic.

Our Site may also use third party cookies and Google Analytics Advertising Features including: Remarketing with Google Analytics, and Google Analytics Demographics and Interest Reporting.

Visitors can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Settings. Further information regarding behavioural advertising, including ways to manage your online privacy, is available at https://www.staysmartonline.gov.au/.

Where you provide your email address to us, we will only use it for the purpose provided unless you have consented to us using it for additional purposes, and we will not pass it on to any other person or organisation unless we have disclosed this to you. We may also disclose your information where required by law to do so.

Our Site may contain links to other sites of interest.  We do not control, and are not responsible for, the content or privacy practices of those Sites. Please check the Privacy Policies on other Sites before you provide your personal information to them.

Our Site's Security
By using our Site and Services you acknowledge and agree that the internet is inherently insecure and that you use the internet at your own risk.  You acknowledge that you do not hold Oqea or its directors, representatives, employees, contractors, suppliers or clients liable for any security breaches, viruses or other malicious software that may infect your computer or other internet browsing device, or any loss of data, revenue or otherwise that may occur as a result of using our Site.

We strive to ensure the security of your Personal Information and we take reasonable steps to protect your Personal Information from:

1. a) misuse, interference and loss; and
2. b) unauthorised access, modification or disclosure.

We will review and update our physical and data security measures in light of current technologies. Unfortunately, no data transmission over electronic, mobile data and communication services can be guaranteed to be totally secure.

Our employees and contractors who provide services related to our information systems are obliged to respect the confidentiality of any Personal Information held by us.

We will do everything reasonably within our power and control to prevent unauthorised use or disclosure of your Personal Information. However, we will not be held responsible for events arising from any unauthorised use or access to your Personal Information. Certain sections of our Site are secured using industry-standard SSL/TLS technology to encrypt data between your browser and the Site.

How to Access, Correct or Update Your Personal Information

If you have any complaints, questions or concerns about what information we hold or about the accuracy of that information, please contact Oqea's Privacy Officer.

If you would like to access the information that we hold about you, or to complain about a possible breach of the Australian Privacy Principles, you can write to Oqea's Privacy Officer at the address provided below.

We will respond to your complaint or endeavour to give you access to the information requested within two weeks. In order to maintain the confidentiality of your personal information, we will ask you to meet with us so we can review your specific identification documents before we give you access. If it is not practical for you to meet us in person, we will arrange to check your identification before we mail the information out to you.

If the information that we hold about you is incorrect or not up-to-date, we will update it as soon as possible after you have shown us how and why it is incorrect.

In the unlikely event that we are unable to provide you with access to your personal information for legal reasons as specified in the Privacy Act, we will provide you with reasons for denying access.

If you are not satisfied with our response to your complaint, question or concern, you may wish to lodge a complaint with the Office of the Australian Information Commissioner. Further information can be found on the Commissioner's Site or by calling
1300 363 992.

We do not collect, use or disclose a medical professional's medical records which the medical professional chooses to store on Oqea.Net. Accordingly, we will direct any requests and enquiries relating to personal information in any such records to the relevant medical professional. They may have their own privacy policy and obligations for use, disclosure, modification and destruction of records.

Changes to our Privacy Policy

We may, without notice, amend or modify this Privacy Policy by posting the amended Privacy Notice to our Site or our Services.

Privacy Officer's contact details

Oqea's Privacy Officer can be contacted by:

• Email: [email protected]
• Office Address: 224 Rokeby Road Subiaco, Western Australia 6008

Version: 10.0
Last Updated: August 2024