Privacy Policy In this Privacy Policy, 'We' or, 'Us' means GenEmbryomics Limited (ACN 631 082 418) and its related companies. We are committed to respecting your privacy and are bound by the Australian Privacy Principles set out in the Privacy Act 1988 (Cth), and applicable U.S. laws such as the Health Insurance Portability and Accountability Act (HIPAA), Genetic Information Nondiscrimination Act (GINA), Federal Trade Commission Act (FTC Act), and relevant state privacy laws, in relation to our handling of personal information in Australia and the United States, respectively. By providing us with your personal information, you allow us to collect, use and disclose your information in accordance with this Privacy Policy. Any changes to our Privacy Policy will be published on our website.
What personal information do we collect and how do we collect it? Personal information is any information which identifies you and includes sensitive information such as information about your health ("health information"). We will usually collect the following types of personal information about you: ● name; ● date of birth; ● information about any private health insurance that you have; ● contact details (e.g. telephone number, email address); ● genetic and genomic data; ● payment information; ● health information, including information about your medical history, any psychotherapy evaluations that may be conducted on you and information about the kinds of services that we provide to you; and ● any other personal information that we might require to provide our services to you. We may collect personal information either directly from you, or from third parties (if you have made an application for employment with us), including: ● by you engaging with us via our website, staff members or business associates (e.g. IVF clinics that engage us to provide services to you if you ask for our services to be provided to you); and ● when your personal information is otherwise obtained by us in the course of providing you with our services, or responding to an enquiry or request for information that you have made. When you apply for a job with us, we may collect information about you from third parties such as from recruitment consultants, former employers and other persons who might be able to provide information to assist us to decide whether or not to make you an offer of employment or engage with you under a contract.
Why and how do we collect, use and disclose your personal information? We may collect, hold, use and disclose your personal information for any of the following purposes: ● to enable us to provide you with our services (including counselling services), arranging payment of our fees, respond to enquiries, or other requests for information that you might make of us; ● to develop our services, for example, by performing analytics on your use of our website, and to conduct research; ● to request that you provide us with funding (although you may opt-out of receiving these kinds of communications by using the contact details set out below or by following the opt-out instructions that will be provided to you in our communications); ● to inform you about our services and any offerings from our business associates that we think might be of interest to you (although you may opt-out of receiving these kinds of communications as specified directly above); ● to comply with our legal obligations; and ● to consider any application for employment you make with us. We will never collect, use or disclose your personal information related to our IVF and genetic testing services without your prior express written consent, except where required by law. This includes: • Collecting and processing your genetic samples and data; • Analysing your genetic information and generating test results; • Sharing your genetic information or test results with third parties, including healthcare providers, unless you have provided explicit written authorization; • Using your genetic data for research purposes, unless you have opted-in to participate in such research and provided informed consent. We understand the sensitive nature of genetic information and are committed to protecting your privacy and respecting your autonomy in deciding how your data is used. Before undergoing any genetic testing, we will provide you with a detailed informed consent document outlining the specific purposes for which your data will be used, who will have access to it, and your rights regarding your genetic information. We will only share your genetic data and test results with the specific healthcare providers or third parties that you designate in writing. If we wish to use your de-identified genetic data for internal quality control, test validation, or research purposes, we will first obtain your explicit consent for such uses. Your genetic data will be stored securely and will only be accessible by authorized personnel who require access to perform their job duties. We will not sell or transfer your genetic data to any third parties for marketing, advertising, or other commercial purposes. We may disclose your personal information, for any of the above purposes, to: ● our employees, volunteers and contractors (e.g. laboratory providers) that might help us to provide you with our services, noting that these persons will be subject to confidentiality agreements to protect your personal information; ● any legal advisers that we may engage in relation to any actual or threatened legal action against us, or request for information from us by any person, noting that these persons will be subject to confidentiality agreements to protect your personal information; ● to a workers compensation insurer or private health insurer in relation to any claim made by you or in relation to you (although we will not share any information about you with your private health insurer if you pay for our services out of your own pocket); ● your treating healthcare professionals where we think it is necessary to provide you with test results and/or any other information relating to the services that we provide to you, or where we think this is otherwise necessary to promote your health or safety; and ● as otherwise required, authorised or permitted by law. Your health information will only be disclosed to third parties if you provide us with your consent to do so. We may also use de-identified information about you for other purposes such as to provide training to our staff and for research purposes. We will not sell any of your personal information to third parties.
Sending personal information overseas? We may disclose your personal information to our service providers such as laboratory providers and data storage providers located in, for example, in Australia and the United States. Clause 8.1 of the Australian Privacy Principles provide that if we disclose personal information about an individual to an overseas recipient, then we must take such steps as are reasonable in the circumstances to ensure the overseas recipient does not breach the Australian Privacy Principles in handling that information. An exception to this is if we obtain your consent to disclose that information to an overseas recipient without these protections. We intend to rely on this exception - so, unless you notify us in writing to the contrary, you will be taken to have consented to the disclosure by us of personal information to overseas recipients on the basis that: • clause 8.1 of the Australian Privacy Principles will not apply to such disclosure; • the overseas recipient may not be subject to obligations that provide a similar level of protection for your personal information as is the case under the Australian Privacy Principles; • you will not be able to seek redress under the Privacy Act 1988 (Cth) against the overseas recipient in relation to their handling of your personal information; and • the overseas recipient may be the subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.
Security Personal information will be stored by us securely in electronic databases/servers and in physical form. We strive to ensure the security of personal information that we handle and will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. Some measures that we use to ensure that personal information is kept secure includes the use of firewalls, encryption measures and strict access controls. We will regularly review and update our security measures in light of current technologies and industry practices.
Accessing or correcting your personal information You can access the personal information we hold about you by contacting us using the below contact details. Sometimes, we may not be able to provide you with access to all of your personal information and where this is the case, we will tell you why. You may be required to pay us a reasonable, cost-based fee if you choose to make any such request. If you think that any personal information that we hold about you is inaccurate, you can also contact us and request that this information be corrected using the below contact details.
Making a complaint If you think we have breached the Privacy Act 1988 (Cth), or you wish to make a complaint about the way we have handled your personal information, you can contact us at privacy@genembryomics.com. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to handle your complaint satisfactorily, we will provide you with information about the further steps you can take. More information about your rights and our obligations in relation to privacy, and information on making a privacy complaint are available from the Office of the Australian Information Commissioner, which can be contacted at www.oaic.gov.au, or by post to GPO Box 5218 Sydney NSW 2001, or by email to enquiries@oaic.gov.au.
Contact Us For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below: Privacy Officer privacy@genembryomics.com