PRIVACY POLICY | Jess Grunberg

As at 30th November 2021

1. Commitment to privacy:

1.1. Jess Grunberg Clinical Psychology (the Practice) (also referred to as “us”, “we” or “our”) is committed to safeguarding the privacy of our clients, staff and visitors of the Practice, as well as those who visit our website.

1.2. The Practice is bound by the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles, and other laws governing how health service providers handle your Personal Information and Sensitive Information (including information about your health).

1.3. This Privacy Policy (Policy) sets out how we collect and treat your Personal Information and Sensitive Information. The Policy applies to our website [www.jessgrunberg.com], which is operated by us, and to the products and services provided by us.

2. Definitions In this Policy:

2.1. “Personal Information” is categorised as information held by the Practice, that may identify you, or by which your identity might be reasonably determined. The information you provide us may include, amongst other things, your name, address, email address and phone number.

2.2. “Sensitive Information” means any information about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliation, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preference or practices, criminal record or health information.

3. Collection of Your Data

3.1. To provide our services to you, the Practice may receive and store Personal Information and Sensitive Information (together, ‘your Data’) that you enter onto our website, provide to us directly or give to us in other forms including our general information and consent form, and client details form.

3.2. Your Data may include your:

3.2.1. Contact details including name, phone number, address and email address;

3.2.2. Payment and billing information, which we may use to bill you for our services and to process your payments (including credit

card details);

3.2.3. Health information (both physical and mental health) including information relating to injuries past or present, or whether you are

pregnant;

3.2.4. Personal history and family history; and

3.2.5. Other information voluntarily provided by you. Your Data is collected to ensure your safety and wellbeing, and that of other

participants and facilitators at the Practice, to send information, provide updates and process purchases of services and products

provided by the Practice.

3.3. Sensitive Information, which includes the definition of your Data relating to your health, will not be collected unless you consent to the collection of that information.

3.4. The Practice collects your Data from you in a variety of ways, including when you interact with us electronically or in person, when you access our website and when we provide our services to you.

3.5. We may collect additional personal Data at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your contact or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with us in any other way.

3.6. We may receive your Data from third parties. Those third parties may include your medical practitioners, hospitals, clinics, lawyers and/or family members. If we do, we will protect this information as set out in this Policy.

4. Use of Your Data

4.1. Personal Information (other than Sensitive Information) collected by us will only be used and disclosed for the purpose it was collected. This includes maintaining your account and contact details, providing you with our products and services, and processing payments. 4.2. The Practice may use Personal Information collected from you to provide you with information and updates on our services, additional products, or opportunities available to you.

4.3. We may use your Personal Information to improve our products and services and better understand your needs.

4.4. The Practice may contact you by a variety of measures including, but not limited to, telephone, email, text message or mail.

4.5. We may from time to time use your Personal Information for another purpose where it would be reasonably expected by you or if permitted by the Privacy Act. This includes to effectuate or enforce a transaction, or procure advice from legal and accounting firms, auditors and other consultants.

5. Disclosure of Your Data

5.1. The Practice may disclose your Personal Information (other than Sensitive Information) to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.

5.2. Personal Information is only supplied to a third party when it is required for the delivery of our services.

5.3. We may from time to time need to disclose your Data to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.

5.4. We may use your Data to protect the copyright, trademarks, legal rights, property or safety of the Practice [www.jessgrunberg.com], its clients or third parties.

5.5. We may also use and share aggregate or non-personally identifying information about clients for market analysis, research, marketing or other purposes.

5.6. We will not disclose, sell, share or trade your Data to any third parties unless we first receive your consent.

5.7. We may provide health information (Sensitive Information) to other medical service providers, such as your general practitioner or specialist medical practitioners. We will only supply this information with your consent, or in circumstances where it is required for the delivery of health services, such as referral to another health service provider, billing and liaising with government offices regarding Medicare entitlements and payments, where it is necessary to prevent or lessen a serious threat to a patient’s life, health or safety, or other reason as permitted by law.

5.8. Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia.

5.9. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer, to the extent permissible at law, our user databases together with any Personal Information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

5.10. By providing us with your Data, you consent to the terms of this privacy policy and the types of disclosure covered by this policy. Where we disclose your Personal Information to third parties, we will request that the third party follow this policy regarding handling your personal information.

6. Security of Your Data

6.1. The Practice is committed to ensuring that your Data is secure.

6.2. We will take reasonable steps to protect your Data from misuse, loss, unauthorised access and modification or disclosure.

6.3. We use commercially reasonable physical, technical and administrative measures to protect Information that we hold, including, where appropriate, password protection, encryption, and SSL to protect our website.

6.4. Despite taking appropriate measures to protect your Data used and collected by us, please be aware that no data security measures can guarantee 100% security all of the time. The transmission and exchange of information is carried out at your own risk.

6.5. We cannot guarantee the security of your Data that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of your Data, we cannot assure you that your Data we collect will not be disclosed in a manner that is inconsistent with this privacy policy.

6.6. You are solely responsible for maintaining the secrecy of any passwords and other account information pertaining to our Platform, apps or services.

7. Access to your Information

7.1. You may request details of your Data that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth).

7.2. A small administrative fee may be payable for the provision of your Data. If you would like a copy of your Data which we hold about you or believe that any of your Data we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at [hello@jessgrunberg.com]

7.3. We reserve the right to refuse to provide you with your Data that we hold about you, in certain circumstances set out in the Privacy Act.

8. Website

8.1. When you visit the website of the Practice [www.jessgrunberg.com], we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc.

8.2. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

8.3. When you interact with our website, we strive to make your experience easy and meaningful. We, or our third-party service providers, may use cookies, web beacons (clear GIFs, web bugs) and similar technologies to track site visitor activity and collect site data. We may combine this data with the Personal Information we have collected from you. Examples of information that we may collect include technical information such as your computer’s IP address and your browser type, and information about your visit such as the products you viewed or searched for, the country you are in, what you clicked on and what links you visited to get to or from our site. If we identify you with this information, any use or disclosure of that information will be in accordance with this Privacy Policy.

Third-party websites

8.4. At times, our website may contain links to other, third-party websites. Any access to and use of such linked websites is not governed by this Policy, but, instead, is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

9. Marketing Emails

9.1. We may send you direct marketing emails and information about products and services that we consider may be of interest to you. These communications will only be sent via email and in accordance with applicable marketing laws, such as the Spam Act 2004 (Cth).

9.2. If, at any time, you would like to stop receiving these promotional emails, you may follow the opt-out instructions contained in any such email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails or promotions from us, we still may send you emails about your account, any services you have requested or received from us, or for other customer service purposes. We do not provide your personal information to other organisations for the purposes of direct marketing.

9.3. If you receive communications from us that you believe have been sent to you other than in accordance with this Privacy Policy, or in breach of any law, please contact us using the details provided below.

10. Coronavirus (Covid-19) reporting requirements

10.1. In the event that staff or facilitators of the Practice, our client’s or any visitors contract or are suspected of contracting COVID-19, we may be required to disclose names and contact details of those people to relevant government agencies such as the Western Australia Department of Health or Western Australia Police Force.

11. Complaints about privacy

11.1. If you have any complaints about our privacy practices, please feel free to send in details of your complaints to: [hello@jessgrunberg.com]

11.2. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

12. Changes to privacy policy

12.1. Our Privacy Policy is subject to change.

12.2. The Practice may modify this policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website, or through distribution by email. Please check back from time to time to review our privacy policy.