Last Updated: 21 June 2023

1. About this Privacy Policy
   1. Medical Developments International Limited (ABN 14 106 340 667) (MDI) is committed to protecting the privacy of individuals’ Personal Information. MDI is bound by the Privacy Act 1988 (Cth) and the Privacy Principles set out in it (the Privacy Laws).
   2. This privacy policy outlines how MDI manages Personal Information, including the type of information, how it is collected and held, the purposes for which it is collected, held, used and disclosed, as well as how individuals can access their information and make enquiries or complaints about breaches of the Privacy Laws. MDI deals with Personal Information in accordance with the Privacy Laws and this policy. The Privacy Laws and this policy do not generally apply to employee records.
2. Types of Personal Information
   1. The Privacy Act 1988 (Cth) currently defines “Personal Information” as meaning information or an opinion about an identified individual or an individual who is reasonably identifiable:
      1. whether the information or opinion is true or not; and
      2. whether the information or opinion is recorded in a material form or not.
   2. If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “personal information” and will not be subject to this privacy policy.
   3. ‘Sensitive Information’ is a sub-set of Personal Information about an individual’s 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 information; genetic information that is not otherwise health information; biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or biometric templates.
3. What information do we collect?
   1. MDI collects Personal Information and, in some cases, Sensitive Information about individuals, eg. customers and prospective customers, employees of customers or prospective customers, investors, consultants, subcontractors, suppliers, industry participants, competition participants, candidates for employment, and employees.
   2. The Personal Information MDI collects may include things such as name; address; telephone number; email address; date of birth; age; gender; marital status; banking and superannuation details; credit card details; driver’s licence and other occupational licence details; passport number; tax file number; photographs; medical history; records and reports; racial or ethnic origin; information about financial status; credit history and insurances; proof of the right to work in Australia, or with children; resumes; qualifications; next of kin; employment history; criminal history and/or police checks; references; and use of MDI’s products.
   3. We aim to collect this information only as reasonably necessary to provide proposals; products and services to our customers; candidates and competition participants; to understand and forecast our business; and to respond to requests for information. Individuals are not required to provide us Personal Information, however withholding it might mean we are not able to satisfactorily fulfil those purposes. Where the Personal Information we collect includes Sensitive Information, we will collect and handle that Sensitive Information in accordance with our obligations under the Privacy Laws.
   4. We may also collect information about you from your access to our websites (for statistical purposes). This information is usually anonymous and we do not use it to identify you. However, due to the nature of internet protocols, such information might contain details that identify you, such as your IP address, internet service provider, the web page directing you and your activity on our website.
4. How we collect your personal information
   1. MDI may collect Personal Information through our marketing, business development, operational, human resources, finance, risk, research or other activities.
   2. We will generally collect Personal Information directly from you, unless it is unreasonable or impracticable to do so. For example, if you are seeking employment we may collect your Personal Information when you respond to an advertisement or apply for a position. We will generally only collect Sensitive Information about you with your consent or if authorised by law. By providing us or a third party authorised by us with Personal and Sensitive Information, you consent to our collection and use of it for the purposes set out in this policy.
   3. We may collect information from other sources such as: referees proposed by you; previous employers; police or Citrix (with your consent); agreements we enter; order forms; credit applications; surveys or other forms submitted to us (eg. website forms, online applications); online platforms or other technologies (for example if you place your details on a recruitment database or online platform, whether managed by us or another third party technology provider); telephone or in-person discussions about our services and business; correspondence; emails or other electronic means (eg. accessing our website and using the ‘contact us’ form or using social media sites); third parties (such as our agents and advisors, network contacts, credit providers, credit reporting bodies, regulatory bodies, government offices or your agents); and publicly available sources of information.
   4. We collect data from our website using various technologies, including ‘cookies’. A ‘cookie’ is a text file that our website sends to your browser which is stored on your computer as an anonymous tag identifying your computer (but not you) to us. You can set your browser to disable cookies. However, some parts of our website may not function properly (or at all) if cookies are disabled.
   5. MDI takes reasonable steps to hold Personal Information using appropriate physical and/or electronic security technology, settings and applications (eg. passwords and firewalls), and by training staff who deal with Personal Information on our policies and procedures. These measures are designed to protect Personal Information from unauthorised access; modification or disclosure; and from misuse, interference and loss. Notwithstanding this, you should be mindful that the internet is generally not a secure environment.
   6. In the event of a data breach that is likely to result in serious harm, the Notifiable Data Breaches Scheme in Part IIIC of the Privacy Act 1988 (Cth) sets out obligations for notifying affected individuals, and the Australian Information Commissioner (Commissioner), about an “eligible data breach”. Where a data breach occurs and serious harm to affected individuals is likely, we will notify those individuals and the Commissioner in accordance with our legal obligations.
   7. We will keep your Personal Information only for as long as required for our business purposes and otherwise as required by Australian law. Where we no longer need to keep your Personal Information in accordance with the purposes for which we collected it, we will take reasonable steps to destroy or de-identify your Personal Information. If you wish to have your Personal Information destroyed or de-identified, please let us know and we will take reasonable steps to do so (unless we need to keep it for legal, auditing or internal risk management reasons, or as otherwise required by law).
5. Purpose of collection
   1. The purpose for which we collect personal information is to provide you with the best service experience possible on the website.
   2. We customarily disclose personal information only to our service providers who assist us in operating the website. Your personal information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties.
   3. By using our website, you consent to the receipt of direct marketing material. We will only use your personal information for this purpose if we have collected such information direct from you, and if it is material of a type which you would reasonably expect to receive from us. We do not use sensitive personal information in direct marketing activity. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature.
6. Access and correction
   Australian Privacy Principle 12 permits you to obtain access to the personal information we hold about you in certain circumstances, and Australian Privacy Principle 13 allows you to correct inaccurate personal information subject to certain exceptions. If you would like to obtain such access, please contact us as set out below.
7. Complaint procedure
   If you have a complaint concerning the manner in which we maintain the privacy of your personal information, please contact us as set out below. All complaints will be considered by our Privacy Officer, and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.
8. Overseas transfer
   Your personal information may be transferred to recipients located in European Union. European Union has data protection laws which protect personal information in a way which is at least substantially similar to the Australian Privacy Principles, and there will be mechanisms available to you to enforce protection of your personal information under that overseas law. In the circumstances, we do not require the overseas recipients to comply with the Australian Privacy Principles and we will not be liable for a breach of the Australian Privacy Principles if your personal information is mishandled.
9. How to contact us about privacy
   If you have any queries, or if you seek access to your personal information, or if you have a complaint about our privacy practices, you can contact us through: infoau@medicaldev.com