Privacy Policy

Vitura Health Limited ABN 59 629 071 594 (Vitura), and its subsidiaries are located in Australia and subject to the Privacy Act 1988 (Privacy Act or the Act).

This Privacy Policy applies to all Vitura businesses unless that business has adopted a separate policy. A copy of this policy is available on the website located at https://www.vitura.com.au (the website).

This document sets out our policies for managing your personal information and is referred to as our Privacy Policy. We are committed to managing personal information in accordance with the Australian Privacy Principles (APPs). Where you access our services in Australia or via our websites, the privacy laws in Australia apply.

In this Privacy Policy, we and us refers to Vitura Health Limited and its subsidiaries (collectively referred to as Vitura) and you refers to any individual about whom we collect, use and store personal information in compliance with the law.

Personal information is defined by the Privacy Act as information or an opinion about an identified individual or an individual who is readily identifiable.

Vitura is an ASX listed company focussed on innovating the delivery of healthcare by building a centralised healthcare experience that connects and enhances each stage of the patient experience journey throughout their lifetime.

Vitura offers a range of services, including the sale and distribution of scheduled medicines, including medicinal cannabis, and the provision of medical services including telehealth.

The types of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:

• your full name, email, postal address, and other contact details;
• your age and/or date of birth;
• next of kin, or carer;
• where you are a patient of one of our clinics, medical history including notes, records, and past treatments;
• details of products and services we have provided to you and/or that you have enquired about, and our response to you;
• visitor IP addresses;
• hashed identifiers derived from email addresses for the purposes of cross-device tracking for targeted advertising;
• any additional personal information you provide to us, or authorise us to collect, as part of your interaction with Vitura.

We may also collect personal information from others who disclose your information in connection with the services that you request from us.

Vitura collects personal information reasonably necessary to carry out our business, to assess and manage our clients' needs, and provide services including telehealth consultations and health services.

We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you and/or others and managing client relationships.

The purposes for which Vitura usually collects and uses personal information depends on the nature of your interaction with us, but may include:

• enabling you to access and use our websites, associated applications and associated social media platforms;
• to contact and communicate with you;
• for internal record keeping and administrative purposes;
• for analytics, market research and business development, including to operate and improve our websites, associated applications and associated social media platforms;
• to run competitions, promotional activities and/or offer additional benefits to you;
• for advertising and marketing, including to send you promotional information about our products and services and information that we consider may be of interest to you;
• to comply with our legal obligations and resolve any disputes that we may have;
• to provide you with medical consultation services;
• responding to requests for information and other general inquiries; and
• responding to complaints.

Vitura generally collects personal information directly from you. We may also collect personal information about you from other sources, for example:

• Our advertising Partner, NextRoll Inc, performs a hash of your email address in order to serve targeted advertising to other devices connected to you (via cross-device tracking). Additionally, from visitors to our website using tracking technologies such as third-party cookies and non-cookie technologies. Your information is being used for our own marketing purposes. By checking the box for AdRoll , you consented to this. For more information, please see NextRoll’s Privacy Notice.

In addition to the above purposes, we may also process your personal information based on our legitimate interests in marketing, evaluating and developing our products and services as well as compiling statistics and analyses, and also for compliance with legal requirements or for determining or defending legal claims.

In limited circumstances, Vitura may collect information which is considered sensitive information. Sensitive information includes:

• an individual’s racial or ethnic origin;
• health information;
• genetic information; and
• biometric information that is to be used for certain purposes.

You can always decline to give Vitura any personal information we request, but that may mean we cannot provide you with some or all the services you have requested.

We will only use or disclose your personal information to the service provider who is providing services to you. Subject to the Act, we do not disclose your personal information to others without your permission.

Personal information may be shared between related and affiliated companies of Vitura, located in Australia.

Vitura may also use and disclose personal information for a range of administrative, management and operational purposes. This includes:

• administering billing and payments and debt recovery;
• planning, managing, monitoring and evaluating our services;
• quality improvement activities;
• statistical analysis and reporting;
• training staff, contractors and other workers;
• risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
• responding to enquiries and complaints regarding our services; and
• responding to subpoenas and other legal orders and obligations.

Vitura may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out of receiving marketing material from us at any time.

You can opt-out by using the unsubscribe function in the relevant message or contacting our Privacy Officer using the contact details set out at the end of this privacy policy.

If you opt-out of receiving marketing material from us, Vitura may still contact you in relation to its ongoing relationship with you.

You may also opt-out from receiving cross-device site advertising by selecting the blue opt-out icon used by AdRoll. You will no longer receive personalised ads served by NextRoll.

We may use and disclose your personal information for other purposes explained at the time of collection or otherwise as set out in this Privacy Policy.

We use cookies on our website. A cookie is a small text file that is stored in your internet browser and registers you as a user. We may collect personal data, such as your IP-address, browser history and information about your use of our website, including click behaviour. Cookies can be used for the following purposes:

• to improve the website's user-friendliness and personalise the website for you.
• to analyse the use of our website and collect visitor statistics.
• to manage the website and enable use of the features relating to e-commerce.
• to target advertising campaigns from us and others.

By using our website, you consent to our use of cookies.

You may visit our websites without identifying yourself where it is lawful and practicable (for example, when browsing). If we do not collect personal information about you, you may be unable to utilise our services. Any personal information you provide to us will be managed in accordance with this Privacy Policy.

Vitura stores all personal information using electronic record keeping methods in secure databases (including trusted third-party storage providers based in Australia and overseas). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.

We do not disclose your personal information to anyone overseas.

You are entitled to access your personal information held by Vitura on request. To request access to your personal information please contact our Privacy Officer using the contact details set out below.

You will not be charged for making a request to access your personal information.

We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.

However, if you consider any personal information, we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.

We may decline your request to access or correct your personal information in certain circumstances in accordance with the APPs. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

You may contact Vitura at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled. You may make a complaint about privacy to the Privacy Officer at the contact details set out below.

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.

If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.  

If you are not satisfied with our response to your complaint, or you consider that Vitura may have breached the APPs or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the OAIC website.

Vitura may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes.

The contact details for Vitura are:
Vitura’s Privacy Officer
Email address: privacyofficer@vitura.com.au
This Privacy Policy v2.0 was last updated July 2024