“We”, “Us” and “Our” refer collectively to “Cortical Dynamics Limited.,”
We are committed to protecting your privacy in accordance with the Australian Privacy
Principles contained in the Privacy Act 1988 (Cth) (“Privacy Act”).
Our Privacy Policy provides you with information about how “personal information” may be
collected, accessed, used, stored, disclosed, or otherwise handled by Cortical Dynamics
Limited.
1. What is “personal information”?
“Personal information” is defined in the Privacy Act to mean any “information or an opinion
about an identified individual, or an individual who is reasonably identifiable”:
– whether the information is true or not, and
– whether the information or opinion is recorded in a material form or not.
What constitutes personal information will vary, depending on whether an individual can be
identified or is reasonably identifiable in the particular circumstances.
Information that includes a person’s first name, mailing address, telephone number, title or
e-mail address may be personal information, for example.
In this Privacy Policy, we also use the term “sensitive information”. Sensitive information
includes personal information relating to health, as well other kinds of personal information
to which higher standards apply under the Privacy Act.
2. Purposes for which we may collect and use personal information
We collect personal information when reasonably necessary for one or more of our
functions or activities. Purposes for which we collect, hold, disclose, and otherwise use
personal information include, but are not limited to, the following:
– to promote and market Cortical Dynamics Limited including their people and activities, to
you,
– to assess, receive, manage, or terminate the receipt of goods or services from you or the
organisation which employs you,
– to provide services to clients that engage us, as required by law.
In all cases where personal information is used, we will ensure we have consent from you to
do so.
Our practices in relation to electronic mailing lists
We do not send “commercial electronic messages” by email, SMS or other means unless the
relevant electronic account holder consents or we are otherwise permitted to send them
under the Spam Act 2003 (Cth). We include certain information about ourselves and an
unsubscribe facility in any commercial electronic messages that we send.
If you provide your email address to us via one of our websites (for instance, by sending an
electronic message or by completing a web form), we will only use your email address for
the purposes for which you provided it or agreed it may be used. Your email address will not
be subscribed to a mailing list without your consent. If you subscribe to one of our mailing
lists, you will be sent a confirmation message before your email address is added to that
mailing list. We will never provide your email address to a third party without your consent.
3. How we collect personal information
If we collect personal information about you, we will take reasonable steps to notify you or
to ensure your awareness of at least the following:
– our identity and contact details,
– the facts and circumstances of collection,
– whether collection is required or authorised by law,
– the purposes of collection,
– the consequences if personal information is not collected,
– our usual disclosures of personal information of the kind collected,
– information about this Privacy Policy, and
– whether we are likely to disclose personal information about you to overseas recipients,
and if practicable, the countries where they are located.
We may collect personal information about you in a number of ways, including:
– directly from you, such as when you provide information by phone or in a form, or when
you submit your personal details through our websites:
– from third parties, such as our clients, or your representatives; or
– from publicly available sources of information.
Sensitive information
We will collect sensitive information only with the consent of the individuals concerned,
subject to limited exceptions permitted by the Privacy Act.
You can interact with us anonymously or by using a pseudonym when it is lawful and
practicable to do so.
For example, you may be able to provide comments or make certain inquiries anonymously
or by using a pseudonym. However, if you choose to remain anonymous or use a
pseudonym, it may be impracticable for us to respond to some inquiries (e.g., investigate a
complaint) without knowing your identity.
Where you interact with us via one of our websites, we may automatically collect various
connection parameters, such as your IP address and details about your internet service
provider, in order to administer and improve the performance of the website. If the website
uses “cookies” you may choose to configure your web browser to access our websites
without accepting the cookies, but it may reduce your user experience and require you reenter certain information from time to time.
4. How we hold personal information
We will take reasonable steps to protect any personal information that we hold from
misuse, loss, unauthorised access, modification, or disclosure. We will also take reasonable
steps to destroy or permanently de-identify personal information that is no longer needed
for the purpose for which the information was collected.
Your personal information may be stored in hardcopy documents, as electronic data, in our
internal software or systems, or using a third party under an outsourced arrangement for
data storage or backup.
Our practices in relation to emails
Cortical Dynamics Limited logs and stores email messages by capturing each email log file on
a mail server. If an investigation is necessary, Cortical Dynamics Limited a law enforcement
agency or other government agency may inspect the above information for the purposes of
the investigation. We do not otherwise use or disclose the above information except in
accordance with applicable laws, including the Privacy Act.
5. Disclosure of personal information
Cortical Dynamics Limited may disclose your personal information (including to each other)
for the primary purpose for which it was collected, for a related purpose as you would
reasonably expect, with your consent, or otherwise as required or authorised by law.
For example, we may disclose your personal information to:
– our professional advisors including our accountants, auditors, and lawyers,
– your authorised representatives or legal advisors (e.g., when requested by you to do so),
– credit-reporting and fraud-checking agencies,
– third parties to whom we have outsourced various business functions,
– Government and regulatory authorities and other organisations, as required or authorised
by law,
– Cortical Dynamics Limited members,
our partners or other third parties who assist us in achieving the purpose for which the
information was collected.
6. How to access and correct your personal information
You have a right under the Privacy Act to request access to your personal information, and
to request its correction.
We will provide you with access to personal information that we hold about you, subject to
any exceptions allowed by law. We may charge you for providing access, but the charge (if
any) will not be excessive, and we will never charge you for making a request for access.
If you are aware that personal information which we hold about you is inaccurate,
incomplete, or out-of-date, please contact us and we will take reasonable steps to correct
the information or, if necessary, to associate a statement that the personal information is
inaccurate, out-of-date, incomplete, irrelevant, or misleading, in such a way that will make
the statement apparent to users of the personal information.
We will also respond to each request within a reasonable period after it is made. If we do
not provide access or make corrections as requested, then we will notify you of our reasons
except to the extent that it would be unreasonable to do so.
7. Updates to this Privacy Policy
We may change or modify this Privacy Policy from time to time. We encourage you to check
our websites regularly for updates.
8. Website analytics
To improve your experience on our site, we may use ‘cookies’. Cookies are an industry
standard and most major web sites use them. A cookie is a small text file that our site may
place on your computer as a tool to remember your preferences. You may refuse the use of
cookies by selecting the appropriate settings on your browser, however, please note that if
you do this you may not be able to use the full functionality of this website.
Our website uses Google Analytics, a service which transmits website traffic data to Google
servers outside of Australia. Google Analytics does not identify individual users or associate
your IP address with any other data held by Google. We use reports provided by Google
Analytics to help us understand website traffic and webpage usage.
By using this website, you consent to:
– The processing of data about you by Google in the manner described in Google’s Privacy
Policy:
– The use of data corresponding to your interactions with our websites to tailor marketing
messages to you that may be displayed on this or other web sites or, through third parties,
across the Internet.
– Information about how your visitors can opt out of Google’s use of cookies by visiting
Google’s http://www.google.com/settings/ads
-You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript,
or use the opt-out service provided by Google.
9. How to contact us
For any matter relating to this Privacy Policy or your personal information, including if you
wish to complain about a breach of the Australian Privacy Principles, please
contact:
Privacy Officer
Cortical Dynamics Limited,
Email: info@corticaldynamics.com
We will respond to you, and we will try to resolve any issues, as soon as possible