YOUR TWO JUGS PRIVACY POLICY
This privacy policy applies to the management of your personal information (“Your Information”) by or on behalf of Your Two Jugs Pty Ltd (ACN 645 222 975 ) (“Your Two Jugs”/ “we” / “us”/ “our”).
Your Two Jugs is an online education platform based in Melbourne, Australia that provides information, guidance and products to aid women’s breast care (our “services” and “products”) including via its website at https://yourtwojugs.com.au/ (“website”).
We have created this privacy policy in order to demonstrate our commitment to the Privacy Act 1988 Cth (“Privacy Act”), the Australian Privacy Principles (“APPs”), and relevant State based health privacy legislation that applies to the handling of health information by private sector health service providers (together, the “Australian Privacy Laws”). It sets out how we may collect, hold, use or disclose Your Information.
What information do we collect?
We collect and hold Your Information, which may include your name, phone number, email, mailing address, age, sex, gender, medical history, current medications, preferences and interests, and other information relevant to the supply of our products and services that is collected by us or that you choose to provide to us. If you purchase products or services from us, we may also collect your bank or credit card details for payment.
Some of Your Information may also be considered “sensitive information” (SI) as defined under Australian Privacy Laws, such as your “health information” (which includes information about your physical health, medical history and current medications), and other personal information collected for the purpose of providing you with a health service (e.g. assessing or improving your health).
How we collect Your Information
We collect Your Information as part of us providing and offering our services and products. This includes when you provide Your Information to us in person, via our products (including our website), registrations of interest, signing up with us, during phone and skype calls, by email, via social media, or otherwise via customer enquiries or communications.
Generally, we collect Your Information directly from you but we may also collect Your Information from other people or organisations if you have given your consent. To the extent that any additional obligations arising under the Australian Privacy Laws apply to our collection of your SI, we also comply with those obligations and will only collect health information from you directly unless it is not reasonable or practical do so.
Why do we need Your Information?
We only collect or hold Your Information where it is reasonably necessary for our business functions or activities.
In particular, we need Your Information to provide you with our products and/or services, which includes filling your product orders, providing medical assessments and treatment management advice, internal record keeping, communicating with you about our products and/or services, creating and updating our database(s) and other records, ensuring compliance with our contractual and other legal obligations to you, and administering our relationship with you by responding to your enquiries (Main Purposes).
If you do not provide us with Your Information we may not be able to carry out some or all of the Main Purposes.
How do we use or disclose Your Information?
By submitting Your Information to us, you consent to us using or disclosing Your Information for:
- the Main Purposes;
- any purpose related to the Main Purposes that could be reasonably anticipated at the time Your Information was collected (Secondary Purpose);
- any purpose to which you otherwise consent (including as disclosed to you in an information collection statement at the point where we collect Your Information); and
- any other purpose required or authorised by law (including the Australian Privacy Laws).
Secondary Purposes may include: improving our products or services; sending you direct marketing about our products or services, deals and promotions; conducting customer surveys; managing our relationship with you; monitoring how you interact with us on our website or other contact points; or helping you to complete an activity that you have chosen to undertake.
We may use certain non-personally identifiable information (such as anonymous usage data, IP addresses, browser or platform type etc.) to improve the quality and design of our products and services, and to create new features, promotions, functionality and services by storing, tracking, analysing and processing user preferences and trends as well as user activity and communications.
To the extent that our obligations under the Australian Privacy Laws in relation to our use of your SI vary from our obligations with respect to use of Your Information that is not SI, we will comply with the obligations applicable to SI.
Can you remain anonymous or use a pseudonym?
We will, if practicable, allow you to use a pseudonym or to not identify yourself (unless this is impractical or against the law (including the Australian Privacy Laws)).
In some instances, if you do not provide us with some of Your Information we may not be able to provide you with the relevant product, service or information. This may have an effect on whether we can begin or continue a relationship with you.
What disclosures do we make?
Generally speaking (and as described above under the heading “How do we use or disclose Your Information”) we will disclose Your Information for the Main Purposes. We may also disclose Your Information in other ways with your consent or to any other party where we are authorised or required to do so by law (including the Australian Privacy Laws).
We may disclose Your Information to our partners, suppliers and distributors in order to assist us in providing our products or services to you. Some of our service providers (including the payment facility provider), or the services they provide (like cloud storage services), may be based outside Australia. In order to protect Your Information, we take care where possible to work with service providers who we consider maintain acceptable standards of data security compliance, and we do our part to meet those standards as they apply to us. By providing us with Your Information, you consent to Your Information being used, stored and disclosed overseas (and acknowledge that no additional obligations that may apply to the overseas disclosure of personal information under Australian Privacy Laws will apply).
Is Your Information confidential and secure?
We take all reasonable steps to keep Your Information secure and to ensure it is protected against misuse, loss, unauthorised access, modification or inappropriate disclosure. We may hold Your Information in both hard copy and electronic forms, but will store it in secure systems accessible only to authorised personnel.
Do we use “cookies”?
When you visit our website, the server may attach a "cookie" to your computer's memory. A “cookie” assists us to store information about how you use our website and to make assumptions about what information may be of most interest to you. This information is generally not linked to your identity. We may use knowledge of your user experience to better understand what products or services may be of interest to you and to collect statistical information.
Using other sites
Our site may contain links to other websites, platforms or applications. Unless the other website, platform or application is one of our products, we are not responsible for the privacy practices of the owners of those websites, platforms, or applications. We recommend that you read the privacy policy of any website, platform, or application that asks you to provide Your Information.
Changes to our Privacy Policy
We may need to change this privacy policy from time to time. When we do amend it, the changes will be effective immediately upon being made public on our website. We will use reasonable measures to notify you of any relevant changes to this privacy policy, but please be aware that it is your responsibility to review our privacy regularly and make sure you keep up to date with any changes.
Managing Your Information
You are responsible for ensuring that Your Information is accurate, current and complete and we encourage you to contact us to update Your Information if it changes.
You may ask us to access Your Information in accordance with Australian Privacy Laws (as applicable), including by asking us to provide you with a summary of Your Information that we hold, subject to certain limitations under the Australian Privacy Laws.
For your protection, we may require you to confirm your identity before access to Your Information is granted.
In most cases, we can provide you with a summary of Your Information free of charge. However, in some circumstances, reasonable costs may be charged to you in accessing Your Information in accordance with and subject to the Australian Privacy Laws, including any costs limitations contained in applicable Australian Privacy Laws.
Queries and complaints
If you have a question or want to make a complaint about how we handle Your Information please contact us using the details below. We will review any question, complaint or concern you may have and will respond to you after we have carefully considered it. We will, where reasonably possible, take steps to investigate and resolve complaints within 30 days. Please note, we may require further information from you in order to resolve any complaints. If we need more time, we will notify you about the reasons for the delay and seek to agree a longer period with you (if you do not agree, we may not be able to resolve your complaint). If we cannot resolve a complaint related to your privacy information, you may contact the Office of the Australian Information Commissioner (“OAIC”) directly.
We can be contacted via:
Email: [email protected]
Phone: [insert phone]
Or for more information about privacy issues in Australia and protecting your privacy, please visit the OAIC website at www.oaic.gov.au.
Last date Updated: December 2020