Privacy Policy

16th June, 2018

Privacy Policy

Here at TravelDialysisReview we are committed to protecting your personal information when you use our services or otherwise interact with us.

Who we are

TravelDialysisReview.com. ("TravelDialysisReview", "we", "our", "us") is an online service that provides users ("you") with recommendations for dialysis patients travel to dialysis units other than their own. It also provides those dialysis units with a means of engaging with travellers. Our website, mobile properties and related applications (collectively, our "Website") are owned and operated by TravelDialysisReview.com on behalf of Advanced Productivity Systems Pty Ltd.

By accessing our Website and using our services, you acknowledge that you have read and understood this Privacy Policy and the information collection and handling practices outlined in it.

This Privacy Policy was last updated on May 23, 2018. We may change this Privacy Policy from time to time so please check back regularly to keep informed of any updates.

TravelDialysisReview is a not-for-profit online facility created by dialysis patients, for dialysis patients. TravelDialysisReview.com is responsible for all TravelDialysisReview campaigns and the development of TravelDialysisReview policy.

Where TravelDialysisReview is processing your information, including in relation to our campaigns, policy work and your membership, is, for the purposes of data protection legislation, a controller of your personal information.

All our operations are carried out through TravelDialysisReview.com. These activities include our website and other digital products.  Where we are processing your information, in relation to these products and services, including in relation to our campaigns, policy work and your membership, for the purposes of data protection legislation, TravelDialysisReview.com is a controller of your personal information. Its registered address is 52 Christowel Street, Camberwell, Victoria, Australia 3124

Advanced Productivity Systems Pty Ltd and TravelDialysisReview.com will together be referred to in this Privacy Policy as "TravelDialysisReview", "we", "us" or "our".

What this policy applies to: This policy applies to personal information we collect about you when you interact with us (for example when you use our website (TravelDialysisReview.com), or that we collect from third parties, as described in this Privacy Policy.  It sets out:

  1. What information we collect, and from whom;
  2. How we use that information;
  3. Who we share your information with;
  4. How your information is protected;
  5. Your rights in relation to the information we hold about you; and
  6. How long we keep your information.

Changes to this Privacy Policy: We keep our Privacy Policy under regular review, and we encourage you to periodically review this page for the latest information on our privacy practices. Any material changes will be notified to you by updating them on our website together with any such other methods as may be appropriate.

1. What information does TravelDialysisReview collect?

Information you provide to us voluntarily

You may give us your personal information when you:

  • Use our products and services
  • Use, or provide a comment or write a review on, our website
  • Correspond with or contact us
  • Enter into any of our competitions, promotions or surveys
  • Contact our helpline
  • Interact with us on social media platforms
  • Sign up to one of our newsletters or other communications
  • Take part in our research
  • Request a call back through our websites
  • Apply to become a Member
  • Get involved with one of our campaigns, TravelDialysisReview conversations or blog
  • Otherwise interact with us or provide information to a third party to be referred to us

Where we request information from you we will collect the information set out in the relevant forms or pages.  You may choose to provide additional information to us when you contact us or otherwise interact with us or provide information to a third party to be referred to us.  We store customer feedback and information on our customer information databases.

Information we collect automatically

We, or the organisations which work on our behalf, collect certain related data of visitors to our website automatically including what pages you have viewed, for how long and your website journey.

Information is also collected about how you arrived at our websites in the first place, including what links or posts of ours you have viewed or clicked on to reach us, or any search terms you have used.  Where you see a post outside of our website we, or an organisation working on our behalf, will place a cookie on your browser so that, when you access our website, we recognise that you have seen an advert of ours elsewhere. Information collected automatically using cookies or other tracking technologies includes your IP address, and if you have logged in, your log-in details.

For further information see Section 11 - Cookies. 

Information we collect from third party sources

On occasions, we acquire information from another company, for example to supplement the data that TravelDialysisReview holds.  Where this happens, we will take appropriate steps to assure ourselves that your information was collected legally. 

For example. we use Google Analytics to collect information about how visitors to our website use the site, including collecting information on how long customers spend visiting our content items, how often they return to visit our websites and what demographic categories they fall into.

Information which is available publicly

Your personal information may be available to us from external publicly available sources: for example, geo-demographic information and information from public registers such as listed directorships, information from the electoral roll and press reports.  In addition, depending on your privacy settings for social media services, we may access information from those accounts or services.

2. What type of information does TravelDialysisReview process?

We collect, store and use the following types of information:

  • Your name and contact details (including your postal address, telephone number, email address(es), your membership number and social media identity)
  • Details about the products and services we provide to you
  • Details about how you use our products and services
  • Information you provide on other individuals (for example dependants)
  • Information provided when you use our products or services, including where you are seeking guidance or advice
  • Correspondence you have had with us
  • Comments and reviews you have left on our websites
  • Your contribution to any research you take part in
  • Information about your computer / mobile device and your visits to and use of our websites, including for example your IP address
  • Details about you that are stored in documents in different formats, or copies of them
  • Any other information shared with us as described in section 1 above.

In order to receive certain services via the website (e.g. access to dialysis unit reviews and recommendations), you will need to register to set up a TravelDialysisReview ID. The information that you provide when setting up your TravelDialysisReview ID includes your name and email address and a unique password which enables you to access your account.

3. How does TravelDialysisReview use my information, and on what legal basis?

The following sections describe in more detail how TravelDialysisReview may use your information, and in particular the legal grounds on which we rely in doing so.

What we use your personal information for

We use the information collected for a number of purposes, including to:

  • Deliver our products and services
  • Verify your membership
  • Manage our relationship and communicate with you
  • Provide you with advice or guidance about our products and services
  • Respond to complaints and seek to resolve them
  • Enhance your online experience
  • Conduct research and surveys
  • Develop and carry out marketing activities and competitions
  • Develop and manage our products and services and test new products and services
  • Better understand our members in general, and study how they use products and services from us and other organisations
  • Research member views and experiences for research and editorial purposes, including through requests for help and surveys
  • Respond to individual experiences shared with us and for editorial content
  • Understand your website journey, including what pages you have viewed and for how long
  • Communicate with regulators, legislators and community stakeholders
  • Conduct and commission research into member opinions
  • Administer and keep safe and secure our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
  • Train our volunteers and measure the quality of the service we give you
  • Obey laws and regulations that apply to us

4. The legal grounds we rely on to process your information.

The legal grounds on which we rely are to:

  • Fulfil our contractual obligations (for example in order to provide the products or services requested and to contact you if a problem arises with them)
  • Pursue our legitimate interests (for example to facilitate your use of our website, including obtaining products or services via our website, or for marketing)
  • Your consent; and/or
  • Fulfil a legal duty

Legitimate interests

When we rely on our legitimate interests, these are as follows:

  • Keeping our records up to date
  • Developing products and services
  • Marketing our products and services
  • Administering our website and keeping it safe and secure
  • Ensuring that content is presented in the most effective manner for you and your devices
  • Facilitating your use of our website, including obtaining products or services via our website
  • Measuring the use of our website and improving its content and accessibility
  • Tailoring content and our communications so that they are most relevant to you
  • Carrying out campaigns work and developing TravelDialysisReview policy
  • Complying with legal and / or regulatory requirements
  • Identifying member trends
  • Understanding products, services and the member experience
  • Informing and generating content (for our editorial outputs and other channels).

5. Who does TravelDialysisReview share my information with?

We, or one of the organisations who work on our behalf, share your personal information with the following third parties:

Data processors

We do not share your personal information with marketing companies or data collectors.

Social media companies and search engines

Personal information about our existing members may be used to further our legitimate interests, in particular to better understand our target audience on social media sites and search engines (such as Google, Facebook and YouTube) and to promote our services on those platforms to prospective new members of a similar profile.

The information that we provide to these platforms for such purposes does not directly identify you and is used solely to establish whether you are also a member of the social media site and, if so, to identify users of the social media site that have a similar profile to you.

The information we provide to the social media platform is destroyed once the matching exercise is complete.  If you do not wish your personal data to be used in this way, please contact preferences@traveldialysisreview.com

A social networking widget may be found in many of our pages.   This widget gives you the tool to bookmark our websites, blog, share, tweet and email our content to a friend.  Your interaction with this tool or being on the same webpage while being logged into these services, will result in further cookies from these social media companies being placed on your system. Section 10 – Cookies provides further information about this.

Third parties involved in corporate transactions

TravelDialysisReview may share your information with third parties involved in any reorganisation, restructuring, merger or sale, or other transferring of assets, provided that the receiving party agrees to respect such personal information in a manner that is consistent with this Privacy Policy.

Other third parties

These third parties may be companies with which we have a relationship in relation to products and services provided to you, companies through which you have contacted TravelDialysisReview or companies you ask us to contact on your behalf.

Other circumstances in which we will disclose your information

We will disclose your information to local and foreign regulators, governments, law enforcement authorities, advisors, courts, tribunals and arbitrators when we have a legal obligation to do so or when we believe our compliance with the request to be fair, reasonable and lawful, e.g. to detect, prevent or investigate security breaches, fraud or other crimes.

We will also disclose your information to establish, exercise or defend legal claims, for example: (i) to enforce our Terms and Conditions; (ii) to ensure the safety and security of our users, consumers and third parties; and (iii) to protect our rights and property and the rights and property of our website visitors, consumers and third parties.

Location of third parties

Some potential recipients of your information might be located outside the European Economic Area (“EEA”), in jurisdictions which do not have the same data protection laws as those in the EEA. If we do transfer your information outside the EEA we will take appropriate steps to protect that information, which include:

  • Transferring to third parties in jurisdictions that the European Commission has determined offers adequate protection for your information (and information relating to adequacy decisions made by the European Commission are available here)
  • Entering into an agreement with the recipient, which includes clauses that the European Commission has determined offers adequate protection for your information (a template copy of which is available here).

6. What are my data protection rights?

You have the following rights in relation to your personal data:

  • Access:The right to request access to and a copy of your personal information (which can be done by emailing preferences@TravelDialysisReview.com)
  • Restriction:You can ask us to pause processing your information in certain circumstances (e.g. you are disputing its accuracy)
  • Rectification:You can have any inaccuracies in your personal information corrected
  • Deletion:You can ask us to delete all your personal information in certain circumstances (e.g. if the information is no longer necessary for the purposes for which it was collected)
  • Objection:You can object to us processing your personal information in certain circumstances
  • Objection to marketing:Please see section 7 (Marketing and advertising) below, for information about how to opt-out of direct marketing communications
  • Portability:You can ask us to transfer your information electronically to you or another organization in certain circumstances
  • Withdrawal of consent:Where we rely on your consent to process your information, you can withdraw consent at any time, although this will not affect our uses of your personal information prior to the withdrawal of your consent.

Complaints Regarding the Handling of Your Personal Information

If you believe your privacy may have been prejudiced, or if you have concerns about whether we have complied with the Privacy Act or our Privacy Policy when collecting or handling your personal information you have the right to make a complaint about the matter. You should do so by contacting us by email preferences@TravelDialysisReview.com.

We will respond to your complaint and investigate the matters raised in accordance with our Data Breach Policy and respond in accordance with our Data Breach Response Plan.  We will endeavour to resolve your complaint within 30 days.  If we are unable to resolve your complaint within this time, you may take your complaint to the Office of the Australian Information Commissioner (OAIC)

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Tel: 1300 363 992
Web: www.oaic.gov.au

Please be aware that you are under no obligation to provide us with your personal information. However, failure to do so may, in some circumstances, prevent us from being able to provide you with products and services, or otherwise interact with you.

When exercising your data protection rights, we may ask you to verify your identity in order to help us respond efficiently to your request.

If you would like to exercise any of the above rights, please email or write to us using the details outlined in section 12, below.  All of these rights are free to exercise and we will do our best to respond to you as quickly as possible and in any event, within one month of receipt of your written request.  We will inform you within one month of receipt of such request if we will need longer to respond, for example due to the complexity of the request.

We want to make sure that your personal information is accurate and up to date.  Please always let us know if you think that it is not and needs updating.  Details of how to get in touch are in section 12, below. 

7. How long is my information retained?

Whenever we collect or process your personal data, we will only keep information about you for as long as we need to fulfil the purposes for which we are processing your information.  At the end of that retention period, your data will either be deleted or anonymised.  Examples of our retention periods are:

  • Where you are a member, we would normally keep your information for the duration of your membership and then a period of up to two years after you cease being a member.
  • Where we need to keep your information for dealing with legal claims or complaints, we would normally keep it for seven years from the end of that matter.
  • Where you have sent us correspondence, we would normally keep that for one year after the issue has been dealt with.
  • Where you have engaged with us in relation to campaigns, we will normally keep your information for up to four years after the closing of the campaign.
  • Where you have provided information that informs and/or generates content for our editorial outputs and other channels, we will normally keep that information for up to seven years (but usually for one year after publication of the relevant content).

8. Marketing and advertising

We may use the information you provide to send you communications about TravelDialysisReview's products and services and/or campaign work. This might be by email or SMS, with your consent.

You can change your marketing preferences at any time by writing to us or emailing us.  All details can be found in section 12, below. You can also unsubscribe from receiving any further marketing communications.

We may analyse the information we collect about you to improve the targeting of communications. We use profiling and screening techniques to ensure that our communications to you are relevant and timely, and to provide an improved experience for you. When building a profile, we may analyse geographic, demographic and other information relating to you in order to better understand your interests and preferences so we can contact you with the most relevant communications.  In doing this, we may use additional information from third party sources when it is available. If you do not wish your data to be used in this way, please contact us at preferences@TravelDialysisReview.com or using the details in section 12 below.

We engage in the following forms of advertising on other websites which are part of the same advertising network or affiliate network as we are.

Performance Advertising

We engage in a form of advertising which is called ‘performance advertising’ on other websites and on our websites.  This is a form of advertising where we only pay the advertiser when there are measurable results.  We have a series of partner sites, or ‘affiliates’ who will host our adverts and links, and if you come to our website and decide to buy something from us via those adverts or links, then we will then pay them a small fee.

Cookies help us to do this – to find out more about our use of cookies, and the advertising companies which help us do this, please see Section 10 - Cookies. This will help you understand what information is being collected and for what purpose. 

Display/contextual advertising

We carry out display and contextual advertising on other websites.

These are usually in the form of banner adverts of varying sizes and formats that appear on pages within these external sites that may run across the top of your computer screen or can be a piece of text.

We work with an advertising company who decides where it’s best to place our adverts, and we usually don’t know where our ads will appear.  The advertising company will place a cookie on your computer when you see the ad so they can monitor its effectiveness and not show you the same ad too many times. To find out more about our use of cookies, and the advertising companies which help us do this, please see Section 10 - Cookies. 

Retargeting

We, third party advertising networks which work on our behalf and search platforms we work with, may show you adverts on other websites or within their platforms about things which you’ve previously shown an interest in on our website.  The adverts may highlight other products or services which we think you’d be interested in too.

Cookies (as well as tools such as Google Tag Manager) help us to do this – to find out more about our use of cookies, and the advertising companies which help us do this, please see Section 11 - Cookies. 

9. Links to other websites and social media

Where we provide links to other websites, we do so for information purposes unless otherwise indicated. The other websites are outside our control and are not covered by this Privacy Policy. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their Privacy Policy, which may differ from ours.

On some pages of our websites, third parties that provide content, applications or plug-ins through our Website may track your use of content, applications and plug-ins or customise content, applications and plug-ins for you.  For example, when you share an article using a social media sharing button on our websites (e.g., Facebook, Twitter, or Google Plus), the social network that has created the button will record that you have done this.  For more information on social media plug-ins on our Website, see Section 11 - Cookies. 

10. Use of our Website by minors

If you are aged 13 or under, please get your parent's/guardian's permission before you provide information to us via our websites. Users without this consent are not allowed to provide us with information and, in the event that they do so, we will cease to process their information as soon as we find out.

11. Cookies

At TravelDialysisReview, we want to ensure that your visit to our Web site is smooth, reliable and as useful to you as possible. To help us do this, we use cookies and similar technologies (together referred to as “cookies” in this policy).

By continuing to use the site, you consent to our use of cookies. However, you can change your cookie settings, and choose whether or not to accept cookies, at any time via a browser plugin.

What are cookies?

Cookies are small text files that are automatically placed on your computer or mobile device when you visit almost any Web site. They are stored by your Internet browser. Cookies contain basic information about your Internet use, but they do not normally identify you personally. Your browser sends these cookies back to the site every time you revisit it, so it can recognise your computer or mobile device and personalize and improve your site experience.

For instance, we use cookies on our Web site to remember your login details, so you don’t have to re-enter them repeatedly during your visit to the site. Other cookies help us to understand what did and didn't interest you about our site, so we can provide you with features that are more relevant and useful to you next time you visit. We also use cookies to analyse how visitors use the site.

Please note that our use of any information we collect about you through your use of cookies is subject to this Privacy Policy.

What types of cookies do we use?

The cookies we use fall into 3 categories. These categories are described below.

Essential cookies

These cookies are necessary to help you access and move around our site and use all its features. Without these cookies, our website would not work properly and you would not be able to use certain important features. For example, we use a cookie to keep you logged in during your visit, so the site does not require you to log in repeatedly to access different pages. We also use essential cookies for fraud detection and prevention purposes.

You will see that you cannot turn off essential cookies through the browser plug-in. The reason for this is that such cookies are necessary for you to access and use the content and features of the Web site.

Analytics and customisation cookies

At TravelDialysisReview, we want to make your experience on our website as helpful, smooth and as enjoyable as possible. We use cookies to help us understand how our website is being used and how we can improve your experience on it. This type of so-called "analytics" cookies can provide us with anonymous information to help us understand which parts of our Web site interest our visitors and if they experience any errors. We use these cookies to test different designs and features for our sites and we also use them to help us monitor how our visitors reach our sites.

Social network cookies

We want to make it as easy as possible for you to share content from TravelDialysisReview with your friends through your favourite social networks. Social networking sites, such as Facebook, may set cookies that recognise you when you view content on our Web site and allow you to share content across both sites via the use of sharing settings. For further details, please see your social networking site’s terms of use and privacy policy.

Managing your cookie settings

You have the right to choose whether or not to accept cookies and we explain how you can exercise this right below.

You can manage cookies through the settings of your Internet browser. You can have the browser notify you when you receive a new cookie, delete individual cookies or delete all cookies.

Most advertising networks offer you a way to opt out of advertising cookies. See www.aboutads.info/choices/ and www.youronlinechoices.com for useful information on how to do this.

Please note that, if you choose to delete TravelDialysisReview cookies, your access to some functionality and areas of our Web site may be degraded or restricted.

How you can contact us

If you have questions about our use of cookies, please send us an email, at please contact us at preferences@TravelDialysisReview.com or using the details in section 12, below.

12. How to contact TravelDialysisReview about its Privacy Policy

You can contact us by email, post and telephone as follows:

Email:
Postal address

TravelDialysisReview.com, 52 Christowel Street, Camberwell Vic Australia 3124

Telephone Number

+61 (0)418 330 239

To find out more about TravelDialysisReview and who we are, please read the 'About Us' section of our website.

TravelDialysisReview.com’s role in this respect is limited solely to being a contact person for questions on data protection from EU citizens and data protection supervisory authorities. For the avoidance of doubt, TravelDialysisReview.com cannot field other communications or legal process on behalf of Advanced Productivity Systems Pty Ltd.

Call Recording and Monitoring

Please be aware that calls to and from TravelDialysisReview may be recorded. We may use the call recordings to monitor our customer service for quality or compliance purposes, to check the accuracy of the information you provide us, for fraud prevention purposes or to provide training to our staff. We will retain the call recordings for as long as reasonably necessary to perform such activities and then delete them. Any personal data obtained from you during the call will be treated in accordance with the provisions of this Privacy Policy.

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