16th June, 2018
Here at TravelDialysisReview we are committed to protecting your personal information when you use our services or otherwise interact with us.
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.
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
You may give us your personal information when you:
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.
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.
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.
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.
We collect, store and use the following types of information:
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.
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.
We use the information collected for a number of purposes, including to:
The legal grounds on which we rely are to:
When we rely on our legitimate interests, these are as follows:
We, or one of the organisations who work on our behalf, share your personal information with the following third parties:
We do not share your personal information with marketing companies or data collectors.
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 firstname.lastname@example.org
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.
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.
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.
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:
You have the following rights in relation to your personal data:
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
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.
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:
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.
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.
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, 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.
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.
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.
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.
The cookies we use fall into 3 categories. These categories are described below.
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.
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.
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.
You can contact us by email, post and telephone as follows:
TravelDialysisReview.com, 52 Christowel Street, Camberwell Vic Australia 3124
+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.
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