Last Updated September 2014

This is SP Health Co Pty Ltd’s ABN 73 123 248 046 (“we” or “us”) Privacy Policy. It explains how we collect, use and handle any personal information we collect from you when you use this website and the services we provide through this website (together the “Services”). We understand that disclosure of personal information is a serious matter. So, the protection and appropriate use of your personal information is important to us.

In this Privacy Policy the term “personal information” has the same meaning as in the Australian Privacy Act 1988 and includes information that can be used to personally identify you.

Collecting your personal information

When you use the Services we will collect various information about you or relating to you:

  • if you sign-up to receive our newsletter or other email notification services;
  • if you communicate with us via telephone, SMS, email, face-to-face or via social media (including by submitting a query through our website via our Contact or Careers pages);
  • as you visit web pages associated with the Services; and
  • from your activities in connection with your use of the Services.

Unsolicited personal information

From time to time, we may receive information relating to you that we have not requested (“Unsolicited Information”).

If we receive Unsolicited Information, we will check whether it’s reasonably necessary for us to keep it.

If it is, we will treat the Unsolicited Information in the same way as other information that we request you to provide to us. If we determines that it not reasonably necessary for us to keep it, we will, as soon as practicable, destroy or de-identify the relevant Unsolicited Information.

How we use your personal information

We use your personal information to provide you with the Services.

Without limiting the generality of the foregoing, we may use your personal information to:

  • to provide you with any other information or services you request that we provide; and
  • to answer queries or resolve complaints.

Except as set out in this Privacy Policy or otherwise agreed by you, we will not share your personal information with third parties (such as marketing companies) or use your personal information other than for our internal purposes.


You may communicate with us in relation to the Services via phone, SMS, email or in person. We may retain records of those communications for the purposes of contacting you and for our internal purposes.


We may use ‘cookies’ to identify information about your web browser session and personalisation data each time you use the Services. A ‘cookie’ is a small data file that will be stored by your web browser when you access the Services. These cookies do not identify you personally.

Our intention is to use cookies to manage individual sessions relating to the use of the Services and for providing data relating to visitors visiting our website.

Cookies can be used to enhance your use of the Services, as we use them to help personalise our delivery of the Services to you, such as information that is most relevant to your location, activities and interests.

You can set up your browser so that it does not accept our cookies. You can also manually delete our cookies from your browser. However, these actions may stop you from accessing the full benefit of the Services.

How we may share your information

We may engage third parties to undertake some of the Services or related services such as hosting, archiving, data security and email communications. We may provide those third parties access to personal information for the sole purpose of them providing their services to us. We will use reasonable endeavours to ensure that those third parties only use your personal information for the specific purposes for which it is provided to them and consistently with this Privacy Policy.

We may also disclose your personal information:

  • to our related companies;
  • to our professional advisors;
  • to law enforcement authorities, if we suspect that an unlawful act is being committed or that such disclosure will prevent that unlawful act; or
  • as otherwise required or authorised by law. Other than the types of disclosures set out in this Privacy Policy or as otherwise agreed by you, we will not disclose your personal information to any third party.

Security of your personal information

We will use reasonable security measures to protect your personal information from loss or unauthorised access, use or disclosure.

Your access to your personal information

You are entitled to know what personal information we hold about you. You are also entitled to update or correct your personal information.

If you request to access your personal information, once our Privacy Officer has verified your identity, your request will be forwarded to the our information systems manager who will acknowledge receipt of your request within 14 days and arrange for access to be provided to you in an appropriate manner within a reasonable time, usually within 30 days of receipt of your request. We may charge a reasonable fee for providing access if a significant amount of time is required to locate your personal information or to collate or present it in an appropriate form. We will notify you in advance of any likely charges (or the basis for their calculation) for providing access to your information.

In rare circumstances, and only where it is permitted under the Privacy Act 1988, we may not be able to provide you with access to your personal information. If we are unable to provide you with the requested access, we will state why this is so and consider whether the use of an intermediary would be appropriate to provide you with an explanation of our position.

If you would like to contact us in relation to your personal information, please do so through our Contact webpage.


If you are not satisfied with how we handle your personal information, you are entitled to lodge a complaint with the Federal Privacy Commissioner. Information regarding how to lodge a complaint is available from the Commissioner's website at www.privacy.gov.au or by ringing the Commissioner's information line on 1300 363 992. However, before investigating a complaint, the Commissioner is legally required to be satisfied that you have first expressed your concern to us to afford us an opportunity to resolve the complaint directly, unless it is inappropriate for you to do so. You may lodge a complaint with our Privacy Officer using the contact details on our Contact webpage. We will inform you who will handle your complaint and you may contact our Privacy Officer to enquire about the progress of the complaint at any time.

Transfer overseas

We only transfer your personal information overseas if the transfer is to you, or to one of your authorised representatives, or it is with your express consent, or the transfer is necessary for the provision of the Services to you. For example, we may store your personal information in a cloud or other type of networked electronic storage. Countries to which we may transfer your personal information include the United States of America.

If we do send your personal information overseas, it will ensure reasonable steps are taken so that the overseas recipient does not breach the Australian Privacy Principles in relation to that information, or adheres to laws substantially similar to the Australian Privacy Principles. We will also take reasonable steps to prevent unauthorised access and reduce the risk of disclosure to unknown entities.

Third party websites

Please be aware that the Services may contain links to third party websites. If you visit such websites, before providing your personal information on or in connection with those websites, we suggest you review the privacy policy and terms and conditions of use of the third party website.