This Privacy Policy is designed to tell you what will happen to the information you provide through our website, our mobile app, the CareTeam platform, or through any other form of communication with Steera IP Pty Ltd ABN 66 609 007 472 (Steera, us or we) or our employees, officers, agents or contractors (each a Related Party).  Please be sure to read this entire Privacy Policy before using our website, our mobile app, our CareTeam platform, or submitting personal information to us or our Related Parties.

Personal Information

In this Privacy Policy, “personal information” and “sensitive information” have the meanings set out in the Privacy Act 1988 (Cth) as amended (including the Australian Privacy Principles) (the Act). Essentially, personal information is any information about an identified individual or an individual who is reasonably identifiable, whether the information is true or not and whether the information is recorded in a material form or not.

Sensitive information is any personal information about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health, genetics, biometrics or biometric templates.  We will collect, use or disclose sensitive information about you only as allowed by law, for example where we have received your consent to do so or the collection is required by law.

Any references in this Privacy Policy to “personal information” are references to both “personal information” and “sensitive information”.

Consent

By using our website, our mobile app and the CareTeam platform or otherwise providing us directly, or through others, with personal information, you agree with the terms of this Privacy Policy and consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy, the Act and other applicable privacy laws.

Users under 13 years of age

Our website, our mobile app and the CareTeam platform are not intended for children under the age of 13; however, we will collect and store information that parents provide us about their children, in accordance with this Privacy Policy. 

How we collect your personal information

We collect personal information that is necessary to provide you with the services of the CareTeam platform.  We may do this in a number of ways, including:

• directly from you, or your kin, when you, or they, provide it to us or our Related Parties;

• from a doctor (including a general practitioner or a specialist) that has treated you; or

• by analysing our own records of your use of our services, websites and applications. 

We also may collect your personal information when legally required to do so.

What personal information do we collect?

The type of personal information we collect may include your name, date of birth, address, postcode, telephone numbers, email address and information about how you use our website, our mobile app and the Steera Platform.

If you are using the CareTeam platform as patient, we may also collect health information such as allergies, current conditions, previous medical history, medication history, test results, genetic information, vaccinations, medications, mental health, allied health, interactions with medical care providers, information on how you use our website and applications and your preferences for medical treatment.

If you are using the CareTeam platform as a doctor, we may also collect information about your interactions with other healthcare providers and your recommended medical treatment plans (including decision making or approval records).

If we are not provided with the information that we request, we may not be able to provide the CareTeam platform to you.

Passive information collection

As you navigate through our website and our mobile app and access and use the CareTeam platform, certain information can be passively collected (that is, gathered without you actively providing the information) through various technologies, such as cookies.

Our websites and applications may use and combine such passively collected anonymous information to provide better services to visitors and CareTeam platform users, customise the website, mobile app and CareTeam platform based on your preferences, compile and analyse statistics and trends and otherwise administer and improve the website and applications for your use.  Where we combine your personal information with non-personal information, the combined data will be used in accordance with this Privacy Policy, the Act and other applicable privacy laws.

Why do we collect your personal information?

The personal information you provide us may be used for a number of purposes connected with our business operations. In general, we collect, use and disclose your personal information to provide you with our CareTeam platform.  Some of the specific purposes for which we collect, use and disclose personal information are to:

• verify your identity;

• facilitate the communication between your general practitioners and specialists and the provision of health services to you, including a more efficient processing of your treatment plans;

• address or respond to any requests from you;

• inform you of existing and proposed products and services used for medical treatment provided by us or our carefully selected business partners;

• better understand your needs in relation to the products and services used for medical treatment;  

• compile and analyse statistics and trends in medical treatment;

• inform us about who uses our website, our mobile app and the CareTeam platform;

• compile and analyse statistics and trends and otherwise inform us of how our website, our mobile app and the CareTeam platform is being used; 

• support medical, social and population health research; and

• for targeted marketing on our website, our mobile app and on the CareTeam platform.

We may also use your personal information for purposes related to those described above which would reasonably be expected by you.

We will not use your information for purposes other than those described above unless we have your consent or as permitted by law (including for law enforcement or public health and safety reasons).

Sharing your personal information

 We may disclose your personal information in certain circumstances, such as where we are required or authorised by law or where you have consented to us doing so.

We also may disclose your personal information to:

• others in accordance with a request made by you;

• our Related Parties;

• your healthcare professionals and other third parties, but only to the extent that you have consented to us doing so; and

• persons engaged in providing us with professional, business, technology and corporate services, when reasonably required

We may also de-identify and anonymise your personal information, including health information, for the purpose of aggregating it with the de-identified and anonymised information of our other customers in order to provide such information to third parties so that those third parties can use that data for their own internal or commercial purposes.  

Unless you consent, we otherwise will not disclose your personal information to third parties other than as set out above.

When making any disclosure to a third party we will take reasonable steps to ensure that the third parties only use your personal information as reasonably required for the purpose we disclosed it to them and in a manner consistent with the Privacy Principles under the Act.

Does my personal information leave Australia? In the course of our ordinary business operations we may disclose personal  information to third parties who are located overseas, including those located in United Kingdom, Europe and United States of America. This is because some of our technology and operational service providers may be located outside of your country of residence. This means that when we use these provider’s services, it may involve disclosing your personal information overseas. We only disclose personal information to our overseas service providers when it is necessary for the services they provide to us. Except in some cases where we may rely on an exception under the 

Act, we will take reasonable steps to ensure that such overseas recipients do not breach the Privacy Principles in the Act when dealing with your personal information

Access and correction

You may request access to any of the personal information we hold about you by contacting us as specified below.  We reserve the right to charge a reasonable fee for the costs of retrieval and supply of any requested information.

We will take steps to ensure that the personal information we collect, use or disclose is accurate, complete and up to date.  To ensure your personal information is accurate, please notify us of any errors or changes to your personal information and we will take appropriate steps to update or correct such information in our possession.

To update or correct your account details on the CareTeam platform, please email us on support@steera.com.

Storage and security

We will take reasonable steps to safeguard your information from loss, misuse, interference, unauthorised access, modification or disclosure

You should keep in mind that no internet transmission is ever completely secure or error-free. In particular, e-mails sent to or from our website, our mobile app or the CareTeam platform may not be secure. Therefore, sending and receiving information over our website, our mobile app and the CareTeam platform is at your own risk.

We store personal information on computer databases and/or in hard copy and will take reasonable steps (including commercial physical and electronic security measures) to protect any records that we hold which contain your personal information. We destroy your personal information in a secure manner when we no longer need it.

However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuses of or loss or corruption of your personal information.  Nothing in this Privacy Policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth). 

Links to other websites

Our website, our mobile app and the CareTeam platform may contain links or references to other websites and applications to which this Privacy Policy may not apply. You should check their own privacy policies before providing your personal information

Complaints

If you have any questions or concerns about our collection, use or disclosure of personal information, or if you believe we have not complied with this Privacy Policy or the Act, please contact us as set out below.  One of our employees will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.  

Steera and our Related Parties will take any privacy complaint seriously and will aim to resolve any such complaint in a timely and efficient manner.

Steera and our Related Parties expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a formal complaint with the Officer of the Australian Information Commissioner (which is the regulator responsible for privacy in Australia): 

Office of the Australian Information Commissioner (OAIC)

Complaints must be made in writing 

PH: 1300 363 992

Email: Director of Compliance
Office of the Australian
Information Commissioner
GPO Box 5218
Sydney NSW 2001

Web: www.oaic.gov.au

How to contact us

If you wish to exercise your right to opt-out of receiving our marketing materials, or you have any questions or concerns about this Privacy Policy or our information practices (including whether and what type of health information we hold about you), please contact us on support@steera.com

Changes to this Privacy Policy

Our Privacy Policy may change from time to time as updated on our website.  Before providing us with personal information, please check this Privacy Policy on our website for any changes.

This Privacy Policy was last updated 7 March 2023.

Addendum: Information About Others

Where you provide us with personal information relating to other people, it is your responsibility to:

1. inform each individual of this Privacy Policy and provide them with a copy or method of accessing this Privacy Policy; 

2. inform each individual that you are proposing to disclose their personal information to us;

3. ensure that, prior to disclosure of an individual’s personal information to us the individual agrees to the terms of this Privacy Policy; and

4. procure their express consent to the disclosure of their personal information to us

If an individual does not agree to the terms of this Privacy Policy and provide their express consent to the disclosure of their personal information to us, you must not provide their personal information to us.

By providing us with other people’s personal information you warrant that you have complied with this Privacy Policy and all applicable laws regarding such disclosure (including the Act) and you indemnify us and our Related Parties against any and all loss arising directly or indirectly from you disclosing such information.