This Privacy Policy explains how Emeya Health, trading as Living With Diabetes (“Living With Diabetes”, “we”, “us” or “our”), collects, holds, uses and discloses personal information.

It applies to:

• the website at living-with-diabetes.org and any related websites, applications or online services operated by us;
• people who browse or use our directory;
• healthcare professionals, clinics, practices and other service providers whose details appear in the directory;
• people who create an account, submit or claim a listing, make an enquiry, subscribe to communications or otherwise interact with us; and
• our other business contacts and service providers.

We are committed to handling personal information in accordance with the Privacy Act 1988 (Cth), including the Australian Privacy Principles, where those laws apply to us. We may also be subject to state or territory privacy and health-records legislation.

The operator of Living With Diabetes is:

Legal entity: Emeya Health
Trading name: Living With Diabetes
ABN: 84 613 361 729
Registered address: Level 3, 15 Orion Rd, Lane Cove, 2066, NSW, Australia
Email: info@living-with-diabetes.org

The personal information we collect depends on how you interact with us.

3.1 Information about directory users

We may collect:

• your name;
• email address and telephone number;
• suburb, postcode or general location;
• account login and profile information;
• search preferences and directory activity;
• details included in an enquiry or message sent through the website;
• subscription and communication preferences;
• correspondence with us;
• feedback, reports or complaints; and
• technical and usage information described below.

3.2 Information about professionals and organisations

If you are a healthcare professional, clinic, practice or other listed service provider, we may collect:

• your name, title, photograph and biography;
• professional category, areas of practice and services offered;
• qualifications, registrations, accreditations and professional memberships;
• registration or provider numbers where relevant and lawful;
• business name, ABN and practice details;
• business address, service areas and consulting arrangements;
• telephone number, email address and website;
• languages spoken;
• accessibility information;
• appointment and referral information;
• pricing or billing information that you choose to publish;
• information about telehealth or online services;
• account credentials;
• evidence provided to verify a listing;
• payment and subscription records;
• communications with us; and
• information contained in feedback, complaints or reports about a listing.

Some professional information may already be publicly available from practice websites, professional registers, social media profiles, regulatory databases or other public sources.

3.3 Health and other sensitive information

Information about a person’s health, disability or medical treatment is sensitive information under Australian privacy law.

Living With Diabetes is a directory service and does not require users to provide detailed medical histories. However, a user may voluntarily include health information in an enquiry, support request, feedback form or other communication.

We ask users not to submit more health information than is reasonably necessary. Where we collect sensitive information, we will do so with consent or where otherwise permitted or required by law.

The website is not intended to store medical records or provide a channel for urgent or emergency medical information.

3.4 Payment information

Where paid listings or other paid services are available, payments may be processed by a third-party payment provider.

We may receive transaction details such as:

• payer name;
• billing address;
• amount paid;
• payment status;
• invoice information; and
• a partial or masked payment-card number.

We do not ordinarily receive or store complete payment-card details when payments are processed by an external payment provider.

3.5 Technical and usage information

When you use the website, we and our service providers may automatically collect:

• IP address;
• device type;
• browser and operating-system information;
• pages viewed;
• referring website;
• search terms and filters;
• links selected;
• dates and times of access;
• approximate location derived from an IP address;
• cookie and similar technology identifiers; and
• diagnostic, security and error information.

We may collect personal information:

• directly from you;
• when you create an account;
• when you submit, claim, verify or update a listing;
• when you search the directory or contact a listed professional;
• when you make a payment;
• when you contact us or submit feedback;
• when you subscribe to newsletters or marketing;
• through cookies, analytics and similar technologies;
• from clinics, practices, employers or authorised representatives;
• from publicly available sources;
• from professional registration bodies and public registers;
• from referral, technology, hosting, analytics or payment providers; and
• where authorised or required by law.

If you provide personal information about another person, you must be authorised to do so and, where reasonably required, make them aware of this Privacy Policy.

We may collect, hold and use personal information to:

• operate, maintain and improve the directory;
• allow users to search for relevant professionals and services;
• create, administer and authenticate accounts;
• publish, manage, verify and update listings;
• communicate enquiries where a user asks us to do so;
• respond to questions, feedback, disputes and complaints;
• process payments and administer subscriptions;
• prevent fraud, misuse, unauthorised access and security incidents;
• monitor performance and understand how the website is used;
• personalise website content and search results;
• maintain accurate and current directory information;
• moderate content and enforce our Terms and Conditions;
• comply with legal, regulatory, insurance and accounting obligations;
• protect our rights, users and the public;
• conduct business administration; and
• send marketing communications where you have consented or where otherwise permitted by law.

We will not use sensitive information for targeted advertising.

Information displayed in a directory listing is publicly accessible and may:

• appear in search-engine results;
• be copied, cached or indexed by third parties;
• be viewed outside Australia; and
• remain temporarily available in cached or archived versions after it has been changed or removed from our website.

Professionals and organisations should only provide information for publication that they are comfortable making public.

If we create a listing using publicly available professional or business information, the listed person or organisation may contact us to request correction, claim the listing or ask that it be removed, subject to applicable law and legitimate record-keeping requirements.

The website may allow you to contact a listed professional or organisation.

Where you submit an enquiry:

• the information you provide may be disclosed to the selected professional, clinic or organisation;
• that recipient will handle the information under its own privacy practices;
• the recipient may be an independent business that is not controlled by us; and
• we are not responsible for how an independent recipient handles information after receiving it.

Do not use a directory enquiry form for emergencies, urgent medical issues or highly sensitive medical records.

We may send you newsletters, service announcements, professional updates or promotional communications where you have consented or where permitted by law.

You may unsubscribe by:

• using the unsubscribe link in an email;
• changing your account preferences; or
• contacting us at info@living-with-diabetes.org.

We may still send non-marketing messages that are necessary to administer your account, listing, payment or use of the website.

We will comply with the Spam Act 2003 (Cth) when sending commercial electronic messages.

We may use cookies, pixels, local storage and similar technologies to:

• keep the website operating;
• remember preferences;
• authenticate accounts;
• protect against fraud and abuse;
• measure traffic and performance;
• understand how users interact with the directory; and
• improve content and functionality.

Some cookies are necessary for the website to function. Others may be provided by analytics, advertising, mapping, payment, embedded-content or other third-party services.

You can adjust browser settings to reject or delete cookies. Doing so may affect some website features.

Where required, we will provide appropriate cookie controls or obtain consent before placing non-essential cookies.

We may disclose personal information to:

• professionals, clinics or organisations selected by a user;
• contractors and staff who assist us in operating the service;
• website hosting, database, cloud-storage and IT providers;
• account authentication providers;
• email, customer-support and communications providers;
• payment processors and financial institutions;
• analytics, search, mapping and website-performance providers;
• professional advisers, accountants, insurers and auditors;
• prospective purchasers, investors or transaction advisers in connection with a proposed business sale, restructure or financing;
• regulators, law-enforcement bodies, courts and government agencies;
• parties involved in investigating fraud, misuse or security incidents; and
• other parties where you have consented or where disclosure is permitted or required by law.

We do not sell health information.

Some of our service providers may store or process information outside Australia.

Depending on the providers we use, information may be disclosed to recipients in the United States and other locations where our hosting, analytics, email, payment or support providers operate.

Overseas recipients may be subject to privacy laws that differ from Australian law.

Where the Australian Privacy Principles apply, we will take reasonable steps to ensure overseas recipients handle personal information consistently with those principles, unless an exception applies.

We take reasonable administrative, technical and physical steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure.

These measures may include:

• access controls and authentication;
• encryption in transit;
• restricted administrative access;
• system monitoring and backups;
• software and dependency updates;
• staff and contractor confidentiality obligations; and
• incident-response procedures.

No internet service or storage system is completely secure. Users are responsible for keeping account credentials confidential and notifying us promptly of suspected unauthorised access.

We retain personal information only for as long as reasonably required for the purposes described in this Privacy Policy, including to:

• operate accounts and listings;
• provide paid services;
• resolve disputes;
• prevent fraud and abuse;
• meet legal, tax and accounting obligations; and
• establish, exercise or defend legal claims.

When information is no longer required, we will take reasonable steps to destroy it or de-identify it, unless we are required or permitted by law to retain it.

Backups and technical logs may retain information for a limited period after deletion from active systems.

We maintain procedures for responding to suspected data breaches.

Where the Notifiable Data Breaches scheme applies and a breach is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner as required by law.

You may request access to personal information we hold about you or ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading.

To make a request, contact:
Email: info@living-with-diabetes.org

We may need to verify your identity before processing a request. We will respond within a reasonable period.

In some circumstances, the law permits us to refuse access or correction. If that occurs, we will generally provide written reasons and information about available complaint mechanisms.

Professionals may also be able to update some public listing information through their account.

A listed professional or organisation may contact us to:

• claim or verify a listing;
• correct inaccurate information;
• update professional or contact details;
• report an impersonation or unauthorised listing; or
• request removal of a listing.

Requests should be sent to info@living-with-diabetes.org and include enough information to identify the listing and verify the requester’s authority.

We may retain limited internal records after removing a public listing where reasonably necessary for security, dispute resolution, fraud prevention or legal compliance.

The directory may be used by parents, guardians and young people seeking diabetes-related services. However, accounts, listing submissions and commercial transactions are intended for people aged 18 years or older.

A person under 18 should use the website with the involvement of a parent or guardian and should not submit sensitive personal information without appropriate support.

If we learn that we have collected personal information from a child without appropriate authority, we will take reasonable steps to delete it where required.

Listings and website content may link to third-party websites, booking services, social-media pages, maps or other external services.

We do not control those services and are not responsible for their privacy practices. You should review the privacy policies of external services before providing them with personal information.

You may make a privacy complaint by contacting:

Privacy Officer
Jeremy Matchett
Email: jeremy@emeya-group.com
Address: Level 3, 15 Orion Rd, Lane Cove, 2066, NSW, Australia

Please provide enough information for us to understand and investigate your concern.

We will acknowledge and investigate complaints within a reasonable period. We may contact you for further information and will advise you of the outcome.

If you are not satisfied with our response, you may be entitled to complain to the Office of the Australian Information Commissioner or another applicable state or territory privacy regulator.

We may update this Privacy Policy from time to time to reflect changes to:

• the website and its functionality;
• our service providers;
• our information-handling practices; or
• applicable laws and regulatory guidance.

The current version will be published on the website with its effective date. Where a change is material, we may provide additional notice through the website or by email.

Questions about this Privacy Policy or our handling of personal information may be sent to:

Email: info@emeya-group.com
Postal address: Level 3, 15 Orion Rd, Lane Cove, 2066, NSW, Australia