Privacy Policy

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1. Background

 

ADHD Brainstorm (“Brainstorm”) is committed to the protection of the Personal Information of individuals and is bound by the Privacy Act 1988 (Cth), and the APPs contained therein; where applicable to a particular individual, GDPR; and any successor or related legislation as amended from time to time.

 

This Policy provides an overview of how Brainstorm collects, stores, and uses your Personal Information, where applicable. This Policy also details how you can access and update your Personal Information or make a complaint.This Policy applies to the Brainstorm Corporate Site and Brainstorm’s use of Personal Information collected by or through it.

 

2. Definitions

 

APPs means the Australian Privacy Principles, as outlined in Schedule 1 of the Privacy Act 1988 (Cth);

 

Corporate Site means the website accessible at: https://www.adhdbrainstorm.com.au

 

Data Subject means an identifiable or natural person that is subject to and protected by GDPR;

 

GDPR means the Data Protection Act 2018 (UK) and Regulation (EU) 2016/679 as applied therein;

 

Personal Information means any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true. For UK Data Subjects, Personal Information has the meaning prescribed by Article 4 of GDPR;

 

Privacy Laws means the Privacy Act 1988 (Cth), GDPR (where applicable), and any successor or related legislation that may apply from time to time.

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3. What Personal Information do we collect

 

The Personal Information that Brainstorm collects about you through the Corporate Site may include information in the following categories:

- Name;

- Email address; and

- Personal Information collected by our use of Cookies (described below).

 

4. Why and how Brainstorm collects Personal Information

 

Purpose of Collection

Personal Information is collected through the Corporate Site for the primary purpose of providing customers and clients with information regarding the Brainstorm business, and to facilitate communication as requested. For Data Subjects, the lawful bases for processing your Personal Information are that: you have given your consent to the processing for the above purposes; that the processing is necessary to take steps at your request prior to entering into a contract with you; and/or that the processing is necessary for compliance with a legal obligation to which we are subject, as applicable in the circumstance.

 

Means of Collection

Personal Information is collected from you in the following ways:

- by interacting with the Corporate Site;

- through communications between you and us by correspondence (such as email, fax, letter, phone); and

- through registering interest via the “Contact Us” facility.

 

5. Cookies

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What are Cookies? Our Corporate Site uses essential Functional “Cookies”.Cookies are alphanumeric identifiers that are placed on your computer’s hard drive through your web browser.Cookies enable our system to recognise your browser and maintain your details.Functional Cookies are used to:Facilitate your ability to navigate through the Corporate Site;Ascertain whether the Corporate Site is operating effectively;Maintain confidentiality and security as you move through secure or password protected areas of the Corporate Site.Most internet browsers are pre-set to accept Cookies. If you prefer not to receive them, you may adjust your browser to disable Cookies or ensure you are warned when they are used. Turning off Non-Functional Cookies may impair the operation of our Corporate Site and present you with a less convenient or navigable experience. Functional Cookies cannot be disabled, as they are required to be used to enable the Corporate Site to function.Cookies do not routinely collect Personal Information as defined by the APPs. However, they may collect Personal Information as defined by GDPR (for example, IP addresses). Any Personal Information collected by our use of Cookies will be handled and treated in accordance with the provisions of this Privacy Policy.

 

6. Personal Information Security

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Brainstorm is committed to the protection of your Personal Information from unauthorized access, and takes all reasonable efforts to ensure your Personal Information is stored securely both in electronic and physical forms. Personal Information that is no longer required to be processed for the purposes for which it was collected will be destroyed, in accordance with and when required by applicable Privacy Laws.

 

7. Use and Disclosure of Personal Information

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Your Personal Information may be used to:

- Verify your name, address and identity;

- Research and develop our services;

- Maintain and develop our business systems and infrastructure, including testing and upgrading of these systems;

- Address any query, feedback or complaints you may have; and

- Contact you for any other reason.

 

Subject to Brainstorm’s obligations under the Privacy Laws, Brainstorm may disclose your Personal Information to:

- Your authorised representative (e.g. legal advisers) following receipt of your written authorisation to such disclosure;

- Courts, Government and regulatory authorities as required or authorised by law;

- Other third-parties located inside or outside Australia, whether internal or external, as further described in section 8.

 

8. Third-party and Cross Border Disclosures

 

Brainstorm may share your Personal Information with external third-parties for the purposes set out in section 7 above. External third-party and unrelated entities who act as data processors, situated within Australia, the UK/EU and/or the US, who may provide Brainstorm with:

- IT and system administration services; professional advice (including but not limited to accountants, auditors and legal advisers);

- Courts, government or regulatory bodies as required or authorised by law.

 

Brainstorm ensures that any third-parties described above are engaged subject to appropriate safeguards with respect to the receipt and disclosure of your Personal Information, specifically by ensuring that third-parties are engaged in a manner compliant with APPs 6 and 8.

 

9. Access to Personal Information

 

You have the right under the APPs (APP 12) and GDPR (as applicable) to seek access to the Personal Information held by Brainstorm about you. If you wish to exercise this right or any other right, if you believe that the information is incorrect, incomplete or out-of-date, you should address your request the Brainstorm Privacy Officer nominated in Section 12.

 

All requests to access Personal Information should be made in writing or by email and addressed to the Privacy Officer. Brainstorm shall respond to any such request within a reasonable period of time after the request is received.

 

Brainstorm will not charge you for making requests to access any information held about you, however, we reserve the right to undertake cost recovery for the provision of such information where it is permitted by law. We will notify you prior to undertaking work where costs are to be charged.If there is a reason for not granting you access to your information, we will provide you with a written explanation of the reasons for the refusal and inform you of your further options.

 

For UK Data Subjects:

As provided by GDPR, you have additional rights in relation to your Personal Information over and above Australian-based individuals, including the right to erasure and the right to restrict the processing of your Personal Information. You may seek to exercise these additional rights by similarly contacting the Brainstorm Privacy Officer.

 

10. Enquiries and Complaints

 

Information about the Privacy Act 1988 and the Australian Privacy Principles is available from the Office of the Australian Information Commissioner: https://www.oaic.gov.au/ or by telephone: 1300 363 992.

 

Information regarding the GDPR is available from the relevant Information Commissioner; for UK Data Subjects, this is the Information Commissioner’s Office (UK): https://ico.org.uk/ or by telephone: 0303 123 1113.If you have a query regarding Brainstorm’s management of your Personal Information, wish to correct information held by us or require further information, please contact us using the details listed in section 12. Brainstorm shall respond to your correspondence within a reasonable period of time following receipt.

 

If you are not satisfied with the outcome of your complaint, you may refer your complaint to the Office of the Australian Information Commissioner or, for UK Data Subjects, the Information Commissioner’s Office.

 

11. Changes to the Privacy Policy

 

Brainstorm reserves the right to make changes to this Privacy Policy. Any changes made to the Privacy Policy will be effected by Brainstorm changing this Policy and such changes will become effective upon publication of the revised Privacy Policy. If we make any material or substantial changes to this Privacy Policy we will use reasonable endeavours to inform you by email or other agreed communications channels.

 

12. Brainstorm Privacy Officer Contact Details

Attention: Privacy Officer, ADHD Brainstorm

Email: contact@adhdbrainstorm.com.au