Stella Privacy Policy
Stella complies with the Australian Privacy Principles (APPs) as contained in the Privacy Act 1988 (Cth) (Privacy Act) and all other applicable privacy legislation. The APPs regulate the ways and manner in which we collect, use, hold, disclose and destroy personal information, including health information and other sensitive information.
In the course of conducting our business, we collect personal information. This Privacy Policy outlines how we manage that personal information and how we comply with the APPs. If at any time you would like more information in relation to how we handle personal information, or if you would like to request access to your personal information, please contact us on the details below.
We may change this Privacy Policy from time to time by updating our Website.
1. Definitions
In this Privacy Policy:
health information is a subset of sensitive information and includes:
personal information means information or an opinion about an identified individual, or about an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not, and includes sensitive information and health information.
sensitive information is a subset of personal information, and includes information or an opinion about an individual’s racial origin, political opinions, religious and philosophical beliefs, sexual orientation and criminal record, and includes health information and genetic information.
Stella or we, us or our means Stella Centre Pty Ltd ACN 648 839 525.
Website means and includes our website, located at https://stellacentre.com.au/ and any other websites owned or controlled by Stella from time to time.
2. What personal information we collect
The personal information that we collect about you will depend on the nature of the dealings you have with Stella. The kinds of personal information that we regularly collect includes, but is not necessarily limited to your:
- first and last name, address, telephone number, date of birth, residential address, email address and other contact information;
- medical and health information, including medical history, medications used or prescribed, allergies, adverse events, immunisation history, social history, family history and risk factors;
- notes of your symptoms and diagnosis;
- specialist reports and test results;
- genetic information;
- Medicare number;
- health fund details;
- electronic data collected via cookies when you use our Website, including your IP address, browser type, geographical tags, and statistical data;
- appointment, billing details and financial information including credit card details and bank account details; and
- details on how you found Stella and/or its related entities.
You are entitled to remain anonymous or use a pseudonym when dealing with us, unless:
- we are required or authorised under Australian law, or a court/tribunal order, to deal only with individuals who have identified themselves; or
- it is impracticable for us to deal with you without using your real name.
However, please note that if we do not collect, hold, use or disclose your personal information, then it is likely that we will not be able to provide our services to you.
3. Why and when your consent is necessary
By completing our PTSD Quiz and Symptom Checker or otherwise engaging our services, you acknowledge that you have read and understand this Privacy Policy, as well as our Health Information and Collection Statement accessible here: Health Information Consent Form, and consent to Stella’s collection, use and disclosure of your personal information, including your health information, in accordance with this Privacy Policy and the APPs, and as set out in the Health Information and Collection Statement.
4. How we collect personal information
We collect personal information when you (among other things):
- make enquiries with us;
- engage our services;
- access and use our Website or engage with our social media channels;
- contact us via email, telephone or SMS;
- complete our PTSD Quiz and Symptom Checker; and/or
- provide personal information to our representatives or staff.
You are entitled to remain anonymous or use a pseudonym when dealing with us, unless:
- we are required or authorised under Australian law, or a court/tribunal order, to deal only with individuals who have identified themselves; or
- it is impracticable for us to deal with you without using your real name.
We will endeavour to collect personal information directly from you, including through our Website, unless it is unreasonable or impracticable to do so.
However, we may also collect personal information about you by indirect means including from our contractors, suppliers and other associates including health service providers, health practitioners, psychologists, allied health services providers, health practices and hospitals, your guardian(s) or responsible person(s), your healthcare providers, your health fund, Medicare, or through Oqea platform (https://oqea.com).
Where we have collected your personal information by indirect means, we will take reasonable steps to inform you that we have your personal information.
Before we collect your personal information, we will take reasonable steps to inform you as to why we are collecting the information, how it will be used and to whom it will be disclosed.
5. Purpose of collection and how we use personal information
We use personal information for the primary purpose for which it is collected. We may also use your personal information for related purposes that you would reasonably expect including financial claims and payments, marketing and promotions, feedback, statistical collection, clinical studies, clinical and other research and website and data analysis.
We use the personal information that we collect to enable us to conduct our business, to provide our services to you, to carry on our marketing activities and for other reasonably foreseeable purposes, including:
- to facilitate the provision of health care services to you by third party health service providers, health practitioners, psychologists, allied health services providers, health practices and hospitals;
- to communicate with you and provide you with information relating to our services, the related services of health service providers, health practitioners, psychologists, allied health services providers, health practices and hospitals, and other products and services that we consider may interest you;
- to “check in” with you post procedure, measure and discuss your progress;
- to communicate with and engage third parties related to our provision of services to you including but not limited to third party health service providers, health practitioners, psychologists, allied health services providers, health practices and hospitals, Medicare Australia, and private health insurers;
- to consider your answers to our PTSD Quiz and Symptom Checker;
- provide personal information to our representatives or staff.
- to comply with our legal, financial and reporting obligations;
- to enhance our services;
- for health and medical research, data analysis and related purposes; and
- to respond to enquiries.
6. Cookies
We may utilise "cookies" and pixels on our Website and on other social media channels to collect information about you. This information may include:
- your usage of our Website, pages visited, time spent, items and information searched;
- your IP address, to ascertain whether you have visited the website previously; and
- to determine preferences set while you were browsing our Website.
We generally use this information to report statistics, analyse trends, administer our services, diagnose problems and to help customise your website experience and to improve the quality of our services.
7. Disclosure of personal information
We treat all personal information collected by us as strictly private and confidential, and will not disclose any personal information unless:
- you consent to such disclosure;
- the disclosure is to our staff and related entities;
- the disclosure is required in the course of providing services to you (for example, where we refer you to a third-party health practitioner);
- the disclosure is to an external service provider on a confidential basis for financial or administrative purposes (for example to our legal and IT services providers);
- the disclosure is required by law in the discharge of our statutory obligations;
- the disclosure is in connection with the actual or proposed sale, merger or divestment of all or part of our business (whether or not any such transaction is completed); or
- we are required or permitted to do so by law.
Coroners, Funeral Directors, and Organ Donation: We may disclose protected health information to a coroner or medical examiner for identification purposes, determining cause of death or for the coroner or medical examiner to perform other duties authorized by law. We may also disclose protected health information to a funeral director, as authorized by law, in order to permit the funeral director to carry out their duties. We may disclose such information in reasonable anticipation of death. Protected health information may be used and disclosed for cadaveric organ, eye or tissue donation purposes.
Research: We may disclose your protected health information to researchers when their research has been approved by an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your protected health information.
The personal information we collect may be disclosed to third parties, including our related companies and third-party service providers which may be located outside Australia.
If we disclose personal information to third parties, we work with those third parties to ensure that all personal information we provide is kept secure, is only used to perform the task for which they have been provided and is handled in accordance with the APPs.
We do not sell or trade in personal information and will not disclose your personal information to third parties for the purposes of marketing of their products or services to you without your consent, where your consent is required by law.
We may request your consent to disclose your personal information for a particular purpose. In other circumstances, you will be deemed to have given your consent, including where you indicate to us that you wish to obtain information from any of our affiliated third parties about the services that they provide.
We will not disclose any health information or sensitive information about you unless we are authorised by law to do so, or otherwise have your express consent to such disclosure.
8. Overseas disclosure
We may need to disclose some of your personal information to an overseas recipient (including our related entities), in the course of providing services to you. However, we will only do so where:
- such disclosure is necessary for us to provide our services to you; and
- you have provided your consent; or
- we reasonably believe that the recipient is required to deal with the personal information in accordance with laws which are similar to the APPs and will keep the personal information secure and use it only for the purpose for which it was collected; or
- it is otherwise permitted or required by law or court order.
The territories in which we may disclose and/or store your personal information includes the United States.
9. Data security and data quality
We take our obligations under the Privacy Act and the privacy of all individuals very seriously. We take all reasonable steps to ensure that the personal information we collect, and hold is protected from misuse and loss, and from unauthorised access, alteration or disclosure.
We hold personal information in [electronic] form and endeavour to ensure that this personal information is protected by various security measures, including by:
- taking all reasonable steps to keep our premises secure;
- storing all data on secure online platforms;
- implementing password controls on our computers and other electronic devices, servers and emails; and
- using up to date software including antivirus and intrusion prevention.
10. Access and correction
The accuracy of the personal information we collect is imperative to us providing our services. We will take all reasonable steps to ensure that the personal information we hold is accurate, complete and up to date. If you become aware that any of the personal information, we hold about you is not accurate, complete or up-to-date, please contact us on the details below.
If we discover that the personal information, we hold about you is not accurate, or if you make a written request to us with respect to your personal information, wherever practicable and appropriate we will provide you with access to, or take steps to correct the personal information that we hold about you.
You have the right to request access to the personal information we hold about you at any time by contacting our Privacy Officer (contact details below). If access or correction is denied, we will inform you of the reasons why access has been denied.
To request access to or correction of your personal information, please contact our Privacy Officer managed via the following contact details:
We hold personal information in [electronic] form and endeavour to ensure that this personal information is protected by various security measures, including by:
- taking all reasonable steps to keep our premises secure;
- storing all data on secure online platforms;
- implementing password controls on our computers and other electronic devices, servers and emails; and
- using up to date software including antivirus and intrusion prevention.
11. Complaint procedure
If you believe that your privacy has been breached, please contact our Privacy Officer using the contact information above. We will treat your complaint as confidential, investigate it and aim to ensure that your complaint is resolved within a reasonable time.
We will handle all complaints in accordance with our obligations under the APPs.
If you are dissatisfied with any decision made by us in relation to your complaint, you have the right to refer your complaint to the Office of the Australian Information Commissioner on 1300 363 992 or at enquiries@oaic.gov.au.
12. Changes to our privacy policy
We review our policies regularly and may amend this policy from time to time. If we amend this policy, any updated version will be posted on our Website. We recommend that you revisit this page regularly and familiarise yourself with any updates.
This policy was last updated in October 2022.
