Privacy Policy
Last update: 5/10/2023
Introduction
Welcome to DocNow. When you use the website, applications, and services ("Services") provided by DocNow Pty Ltd. ("we", "us", "our", "DocNow"), we collect, use and are responsible for certain personal information about you.
When we do so we are subject to various laws in Australia, the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.
Key Terms
Below are some key terms used in this policy:
We, us, our, DocNow means DocNow Pty Ltd and our group companies.
Our data protection officer means our officer who can be contacted at [email protected].
Personal information means any information relating to an identified or identifiable individual.
Special category personal information means personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data, and data concerning health, sex life or sexual orientation.
Personal Information We Collect About You
We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
Categories of Personal Information
Specific Types of Personal Information Collected
Type | Information |
|---|---|
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) | Name Address IP Address Email Address |
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | Name Address Phone Number Insurance Policy Number Medical Information Health Insurance Information |
Characteristics of protected classifications under California or United States federal law. | Gender Age |
Audio, electronic, visual, thermal, olfactory, or similar information | Audio Input |
This personal information is required to provide products or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products or services to you.
How Your Personal Information is Collected
We collect most of this personal information directly from you—in person, by telephone, text, email, our apps and via our website. However, we may also collect information:
From publicly accessible sources;
Directly from a third party;
From a third party with your consent;
From cookies on our website; and
Via our IT systems, including:
Automated monitoring of our websites, apps and other technical systems
Other IT systems we may implement from time to time.
How and Why We Use Your Personal Information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:
To comply with our legal and regulatory obligations;
For the performance of our contract with you or to take steps at your request before entering into a contract;
For our legitimate interests or those of a third party; or
Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
What we use your personal information for | Our reasons |
To provide productsservicesproducts or services to you | For the performance of our contract with you or to take steps at your request before entering into a contract |
To prevent and detect fraud against you or DocNow Pty Ltd | For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you |
| To comply with our legal and regulatory obligations |
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
Ensuring business policies are adhered to, e.g. policies covering security and internet use | For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you |
Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price |
Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
Statistical analysis to help us manage our business, such as in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price |
Preventing unauthorised access and modifications to systems | For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations |
Updating and enhancing customer records | For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products |
Statutory returns | To comply with our legal and regulatory obligations |
Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
Marketing our services and those of selected third parties to:
| For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers |
Credit reference checks via external credit reference agencies | For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services |
External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts | For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
Promotional Communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our products, services, products or services, including exclusive offers, promotions or new products, services, products or services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell or share it with other organisations outside the group for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
Contacting us at [email protected]; or
Using the “unsubscribe” link in emails or “STOP” number in texts.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products, services, products or services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who We Share Your Personal Information With
We may share personal information with:
Service providers we use to help deliver our products, services, products or services to you, such as payment service providers;
Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
Credit reporting agencies;
Our insurers and brokers;
Our bank(s).
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO or Investors in People accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymise information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
How Your Personal Information is Handled
We implement appropriate technical and organisational measures to protect your data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption in-use, in-transit and at-rest, anonymisation, secure servers, and advanced security protocols.
Where Your Personal Information is Stored
Your personal information is securely stored within the Google Cloud Platform (GCP) and Amazon Web Services (AWS) Cloud Platforms. To ensure data sovereignty, we deploy and maintain separate infrastructures for each region. The data isolation ensures that your personal information along with all your user data remains within your geolocation's borders.
How Long Your Personal Information Will Be Kept
We will keep your personal information while you have an account with us or while we are providing products, services, products or services to you. Thereafter, we will keep your personal information for as long as is necessary:
To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Your Rights under the GDPR
Right to Access: the right to be provided with a copy of your personal information (the right of access).
Right to Rectification: the right to require us to correct any mistakes in your personal information.
Right to be Forgotten: the right to require us to delete your personal information—in certain situations.
Right to Restriction of Processing: the right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data.
Right to Data Portability: the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
Right to Object: the right to object:
at any time to your personal information being processed for direct marketing (including profiling);
in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making: the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.
Your Rights Under the CCPA
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:
Disclosure of Personal Information We Collect About You
You have the right to know:
The categories of personal information we have collected about you;
The categories of sources from which the personal information is collected;
Our business or commercial purpose for collecting or selling personal information;
The categories of third parties with whom we share personal information, if any; and
The specific pieces of personal information we have collected about you.
Please note that we are not required to:
Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
Provide the personal information to you more than twice in a 12-month period.
Right to Deletion
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
Delete your personal information from our records; and
Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with United States federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
Debug to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act;
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
Comply with an existing legal obligation; or
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
Deny goods or services to you;
Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Provide a different level or quality of goods or services to you; or
Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of products/services/products or services to you, if that difference is reasonably related to the value provided to our business by your personal information.
Keeping Your Personal Information Secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to Exercise Your Rights
If you would like to exercise any of your rights as described in this Privacy Policy, please email us at [email protected]. Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact directly by email, you will need to provide us with:
Enough information to identify you (e.g., your full name, address and customer or matter reference number);
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorised to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
Changes to This Privacy Notice
We may change the Privacy Policy from time to time to reflect changes in our Services, changes in the law, or for other reasons. If we make changes, we will notify you by revising the date at the top of these Terms and, in some cases, we may provide additional notice such as sending you an email or posting a notice on our website. Your continued use of our Services after the changes have been made will constitute your acceptance of the changes. If you do not agree to the changes, you should stop using our Services.
How to Contact Us
Please contact us if you have any questions about this privacy policy or the information we hold about you. We may be contacted at [email protected].
Alternatively, you can contact us by post.
DocNow Legal
Level 1, 457 Elizabeth Street
Surry Hills, NSW 2010
Australia