Active Hearing Pty Ltd ABN 91 087 971 051 trading as “Totalcare Hearing” and their related entities in Australia (totalcare, we, us, our) takes your privacy seriously and is committed to handling any personal information that we collect in the course of running our business in accordance with any requirements imposed by applicable privacy laws, including the Privacy Act 1988 (Cth) (Privacy Act).

We are very careful about how and when your personal information is collected, used and shared. This Policy outlines our commitment to you, how we handle and deal with your personal information, and how you may access and seek the correction of the personal information that we hold about you.

By using our services, and providing your information to us, you agree to the use, disclosure, and handling of your personal information in the manner described in this Policy.

In this Policy “personal information” has the meaning set out in the Privacy Act, and (in summary) means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or not.

1. Totalcare Hearings Specialists privacy commitment 2. Types of personal information we collect 3. Why we handle your personal information 4. How and when we collect your personal information 5. Who we disclose your personal information to 6. What if you don’t provide your personal information? 7. Security 8. Other sites 9. Cookies and log files 10. Direct marketing 11. Totalcare Hearing Specialists privacy practices 12. Legal disclaimer 13. Accessing and correcting your personal information 14. Retention and destruction of personal information 15. Questions, comments or complaints

We will handle your personal information securely and carefully, and will only use your personal information when it is necessary, including when we deliver our services to you, or perform other necessary business functions and activities.

We do not collect personal information unnecessarily. The personal information we collect and hold depends on the circumstances. The types of personal information we may typically collect include:

(a) your name, address, contact details (including phone number, facsimile number or email address), date of birth and gender; (b) details of your health service providers; (c) details of your health insurer; (d) your Centrelink Pension or DVA Number details; (e) billing information; (f) details of the services provided to you or which you have inquired about; (g) if you apply for a position with totalcare, your CV and details of your current and former employment details; (h) records of your communications with us.

Depending on the circumstance, sometimes we collect other information, such as details of the clinic you visit, so that we can improve our service offering to you.

Some of the personal information we collect about you will be sensitive because it will include information or an opinion about your hearing. We only collect sensitive information about you with your consent, or otherwise in accordance with the Privacy Act and applicable health records and related privacy laws. We will use sensitive information for the purpose for which it was provided or a directly related secondary purpose, for purposes that you consent to and as otherwise permitted by law. In this Policy, a reference to personal information is a reference to both personal information and sensitive information.

Where you do not wish to provide us with your personal information, we may not be able to provide you with requested goods or services.

As a general rule, if we are providing goods or services to you, we handle your personal information for the purpose of providing you with those goods and services and for purposes that would be considered relevant and reasonable in the circumstances.

We collect, hold, use and disclose your personal information to: (a) verify your identity; (b) communicate with you (including via mail, email, SMS or other forms of communication); (c) deliver the right hearing solution for you, including by ordering products from third-party suppliers; (d) better understand your requirements and preferences; (e) improve our service; (f) manage the goods and services we provide to you; and (g) comply with our legal and regulatory obligations, including: (i) to assess your eligibility for the Australian Government Hearing Services Program; and (ii) fulfil our obligations under the Hearing Services Administration Act 1997 (Cth); and (h) manage our business, including for complaint handling, planning, evaluation, audit, accreditation and quality assurance purposes.

Otherwise, with your consent or where permitted or required by law, we may handle your personal information for other purposes such as: (a) communicating with your family, carers and other representatives; (b) transferring your health records to our other clinics or health service providers; (c) conducting customer surveys and marketing research; and (d) undertaking direct marketing including providing you with offers that may be of interest or benefit to you (including via mail, email, SMS or other forms of communication).

We will always use fair and lawful means to collect your personal information.

In most circumstances, we will collect your personal information directly from you when you give us your details, or when you request information from us, or provide feedback to us.

We may also collect personal information from you when you: (a) attend a hearing assessment at one of our clinics; (b) have your hearing assessed using one of our devices or applications; (c) visit our website; (d) complete an application or consent form; (e) contact us by telephone, email, post or otherwise; (f) interact with us on social media; (g) visit us at a conference or hearing expo; (h) if you are a representative of one of our suppliers or we are a supplier to you, in the course of conducting such business activities; (i) apply for a job or other position at totalcare; or (j) purchase any of our products or services.

Otherwise, we may collect your personal information from third party sources, including: (a) health practitioners; (b) your health insurance company; (c) anyone you grant permission to act on your behalf, including under a power of attorney; (d) Government departments, including Centrelink and Veterans Affairs; (e) marketing service providers; and (f) publicly available sources.

We will not collect your personal information from third parties unless it is unreasonable or impractical for us to collect it directly from you, or if we are otherwise permitted to do so. In some circumstances, we will only collect personal information from third parties (such as health professionals) with your consent, unless we are required or permitted to collect such information by law.

We disclose your personal information in accordance with any consent you give, to Government and regulatory authorities if so required or authorised by law, or where disclosure is authorised, compelled or permitted by law. We may need to do this to communicate with your health practitioner, or to assess and process your hearing voucher application.

We may also disclose your personal information to our related entities (who may use and disclose the information in the same manner we can) and third parties who perform part of our service delivery. This includes organisations such as our suppliers, contractors, call centres, data hosting providers, IT service providers, mail houses and other service providers and third party fulfilment contractors.

In circumstances where your personal information is disclosed to a third party, other than where required to do so by law, we will use reasonable endeavours to ensure that those third parties undertake to protect your privacy to the same extent that we do.

If we are involved in a prospective merger, acquisition or sale of some or all of our assets, your personal information may be disclosed to our advisers and any prospective purchaser’s adviser and may be among the assets that are sold to the prospective purchaser.

We will not sell your personal information to other parties.

Some of our related entities, service providers and agents that we may disclose your information to are located overseas, including in Denmark, Singapore, South America and New Zealand. From time to time we may also engage an overseas recipient to provide services to us, such as cloud-based storage solutions. Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider.

By providing your personal information to us, you consent to us disclosing your personal information to any such overseas recipients for purposes necessary or useful in the course of operating our business, and notwithstanding anything else in this Policy, you agree that Australian Privacy Principle 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the Australian Privacy Principles, that entity will not be bound by, and you will not be able to seek redress under, the Privacy Act.

You may deal with us anonymously to request general information about our products or services.

However, if you choose not to provide personal information when requested, we may not be able to provide you with our full range of goods and services, you may not be able to obtain health concessions or other benefits you may be entitled to, or we may not be able to do business with you.

We will take all reasonable steps to store your personal information securely as we would like you to feel confident in dealing with us over the internet.

Whilst we will take all reasonable precautions to protect your information, please be aware that no data transmission over the internet can be guaranteed to be 100% secure and as a result we cannot provide an absolute guarantee of the security of all your information. We encourage you to take steps to secure your information when you use the internet.

We are not responsible for the privacy practices of sites that are linked to this site by hyperlinks, banner advertising or otherwise. Please take care at all times to check the sites you are visiting. Please note that if you disclose your personal information to third parties through such sites, this Policy will not apply and you will be subject to the privacy policy of that third party.

Like most websites we may use cookies and web log files to track website usage. A cookie is a tiny data file which resides on your computer which allows us to recognise you as a user when you return to the website using the same computer and web browser.

Cookies may collect and store your information when using our websites.

This Policy applies to any personal information collected via cookies.

If you do not wish to be contacted by us (about special offers, discounts or other promotional events), you may write to Totalcare Hearing, Shop 2, 3-5 Waters Road, Neutral Bay, NSW 2089 send an e-mail to info[atsymbol]totalcarehearing.com.au.

From time to time and in line with customer expectations and legislative changes, our Policy and privacy procedures will be reviewed and, if appropriate, updated. Such updates will be published on our website. If you continue to use our services after notice of changes has been published on our website, you hereby provide your consent to the changed practices.

It is possible that we may need to disclose personal information when required by law. We will disclose such information where we have a good-faith belief that such disclosure is necessary to comply with a court order, ongoing judicial proceeding, or other legal process served on us or to exercise our legal rights or defend against legal claims.

We also reserve the right to share personal information if we believe (in our sole discretion) it is required, necessary or permitted in order to investigate, prevent, or report illegal activities (including fraud) or situations involving actual or potential threats to the safety of any person or property.

You may contact us to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. To do so, please contact the Totalcare Hearing, Shop 2, 3-5 Waters Road, Neutral Bay, NSW 2089. Please remember to provide as much detail as you can as this will help us to find the information.

On the rare occasions when we refuse access, we will provide you with a written notice stating our reasons for refusing access.

We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.

We will respond to all requests for access to or correction of personal information within a reasonable time.

We may need to retain or archive your personal information for a significant period of time where we are required to do so by law. Subject to any such legal requirements, if we have no further need for your personal information, we will de-identify or destroy it.

Manual destruction of files, records and computer print-outs containing personal information are carried out in a secure way by either internal shredding or using a supplier who uses secure disposal methods.

All Totalcare Hearing employees are charged with the responsibility to provide reasonable information and assistance to ensure that complaints are lodged effectively using our Customer Relationship system.

Providing customers with easy access and a point of contact to lodge a question, concern or complaint is a fundamental element of our overall complaint policy. Complaints may be lodged by: • Customer Feedback web form • Phone on 02 9909 0020 • Email: info[insertatsymbol]totalcarehearing.com.au  (remove [ and ] brackets from email address) • Post: Shop 2, 3-5 Waters Road, Neutral Bay, NSW 2089 Complaints will be acknowledged, and customers will be advised of a reference number that can be used to identify progress of their complaint within 3 business days.

We take all complaints seriously and will respond to your complaint within a reasonable period. Please provide us with as much detail as possible so that we can fully consider your question, concern or complaint.

If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner: Office of the Australian Information Commissioner GPO Box 5218, Sydney NSW 2001 Telephone: 1300 363 992 Email: enquiries[insertatsymbol]oaic.gov.au  (remove [ and ] brackets from email address)

If you have any questions about this Policy, please contact us at Shop 2, 3-5 Waters Rd, Neutral Bay, NSW 2089, 02 8076 9128