In this Privacy Policy, 'us' 'we' or 'our' means Medical Minds AI Pty Ltd (ACN 671 845 828), an Australian company doing business as Medow Health, and its related entities or body corporates. We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store and disclose your Personal Information.
This Privacy Policy applies to two distinct groups of people:
Except where this Privacy Policy specifies otherwise, it applies to both Healthcare providers and Patients. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.
Definitions
In this Privacy Policy, the following capitalised terms have the following meanings:
Australian Privacy Act means the Privacy Act 1988 (Australian Commonwealth).
Data Protection Laws mean the Australian Privacy Act, the New Zealand Privacy Act and the PDPA .
New Zealand Privacy Act means the Privacy Act 2020 (New Zealand).
Non-personal Information means information that does not relate to a person and/or cannot be used to identify a person.
PDPA means the Personal Data Protection Act 2012 (Singapore).
Personal Information means any information which can be used to identify an individual, and described in detail in clause 2.
Services mean the provision of the transcription and report writing services and any other goods or services offered by us on a payment or free-of-charge basis.
What Personal Information do we collect?
Patients
If you do not consent to the recording of your consultation, then please tell your Healthcare provider and they will not record the consultation.
Your Healthcare provider uses Medow Health to record and transcribe your consultation. Medow Health records the consultation and then provides accurate reports on the consultation for the Healthcare provider. Our service does not provide medical advice to you or the Healthcare provider, and your Healthcare provider will review and approve the reports before storing the reports in your medical file.
- Medow Health has adopted a privacy by design approach and the Service has been designed to limit the amount of personal information collected about Patients.
- When Healthcare providers use our services then the conversation between you and the Healthcare provider is recorded and our services automatically generate notes from that conversation. All recordings are deleted after 7 days unless the Healthcare provider explicitly requires otherwise.
- Our services also integrate with the Healthcare providers internal records systems to extract the appointment record so that we can match the recording and notes with the correct individual patient. Each Patient’s Personal Information is extracted and used for this matching purposes.
- We do not collect or use any contact information about you.
Healthcare Providers
- We may collect Personal Information about staff at Healthcare providers when they use the Services, register for an account with the Services or interact with us in any way.
- Information we automatically collect: We also automatically collect certain technical data that is sent to us from the computer, mobile device and/or browser through which Services are used (Automatic Data). Automatic Data, includes without limitation, a unique identifier associated with an access device and/or browser (including, for example, Internet Protocol (IP) address), characteristics about the access device and/or browser, statistics on activities on the Services, details of the Services we have supplied or that are enquired about, including any additional information necessary to deliver those Services and respond to enquiries, or information about the Services were discovered.
- Non-Personal Information: When Healthcare provider’s interact with the Services, we may collect Non-Personal Information. The limitations and requirements of this Privacy Policy on our collection, use, disclosure, transfer and storage/retention of Personal Information do not apply to Non-Personal Information. When a Healthcare provider registers to the Services or otherwise submit Personal Information to us, we may associate other Non-Personal Information (including Non-Personal Information we collect from third parties) with Personal Information. At such instance, we will treat any such combined data as the Personal Information of the staff at the Healthcare provider until such time as it can no longer be associated with them or used to identify them.
- We collect all information that Healthcare providers voluntarily provide to us while using the Services, signing up to our Services, or contacting our support services. This includes any information provided:
i. during registration;
ii.during correspondence, enquiries, support services or phone calls; or
iii.uploaded onto the Services in any way.
The Personal Information we may collect about staff at Healthcare providers includes without limitation:
i. basic information such as first and last name;
ii. contact information including email address and phone number;
iii. name of the Healthcare provider;
iv. demographic information such as postal code;
v. information related to use of the Services, including without limitation, goods or services bought or looked at;
vi. other relevant information in relation to the needs of our Services;
vii. geographic location; and
viii. other information obtained by Healthcare provider’s use of the Services.
Why do we collect, use and disclose Personal Information?
Patients
We may collect, hold, use and disclose your Personal Information to provide our Services to Healthcare providers.
We may collect, hold and use your anonymised and aggregated data to train and test our Services.
Healthcare providers
We may collect, hold, use and disclose your Personal Information for the
following purposes:
- We may collect, hold, use and disclose your Personal Information for the following purposes:
i. to enable you to access and use our Services;ii. to operate, protect, improve and optimise our Services, such as
to perform analytics and conduct research;
iii. to send service, support and administrative messages,
reminders, technical notices, updates, security alerts, and
information requested by the Healthcare provider;
iv. market services to the Healthcare provider; and
v. to comply with our legal obligations, resolve any disputes that
we may have with any of Healthcare providers, and enforce our
agreements with third parties.
- The information we collect is not distributed, sold or leased to third parties for commercial purposes, except to provide Services you have requested or for other purposes when we have Healthcare provider’s permission or when we are obliged to do so.
To whom do we disclose your Personal Information?
We may disclose Personal Information about Patients and staff at Healthcare providers for the purposes described in this Privacy Policy to:
- our employees and our related bodies corporate;
- where necessary to provide our Services, to third-party suppliers and service providers (including providers for the operation of our Services);
- (in relation to Healthcare providers only) payment systems operators (e.g.,
merchants receiving card payments); - anyone to whom our assets or businesses (or any part of them) are
transferred; - specific third parties authorised by Healthcare providers to receive information held by us; and/or
- other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law if we are compelled to comply with a lawful request for Personal Information.
Security
We take all reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your Personal Information. However, we cannot guarantee the security of your Personal Information.
Processing and transfer of your Personal Information
Patients and Healthcare providers
- Your information, including Personal Information, is hosted in the jurisdiction that the Healthcare provider has their premises, and is transferred as follows:
i. Australian and New Zealand located Healthcare provider –
hosted in Australia;
ii. Singapore located Healthcare provider – hosted in Singapore;
iii. UAE located Healthcare provider – hosted in the UAE; and
iv. in addition the following locations may be used:
1. support services provided by our support team in the Philippines;
2. Third-party suppliers of automated transcription services may be provided from the USA (these providers delete the audio file immediately once the automated
transcription has been completed); and
3. other third party suppliers of support services based in
Germany.
- Your personal information may be processed at our operating office in Australia and in any other places where our staff members are located or where subprocessing takes place. It means that this information may be transferred to Australia and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.
- We will take steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organisation or a country unless there are adequate controls in place including the security of your data and Personal Information.
Your rights
Where we process your personal information, we must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it.
- Your choice: Please read this Privacy Policy carefully. If you provide personal information to us or allow us to transcribe consultations, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information or allow us to transcribe the consultation, however, if you do not, we will not be able to provide the services to the Healthcare provider.
- Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.
- Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
- Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you may contact the privacy regulator in your country.
- We may ask you to verify your identity before acting on any of your requests.
Retention
Healthcare providers
- Ordinarily, we will retain your Personal Information as long as you are registered to the Services as a User, and aim to delete it as soon as practicable following the closure of your account. You may close your account by contacting us. On closing of your account we will delete all transcripts, audio files and reports of your patients. However, we may sometimes retain Personal Information for an additional period as is permitted or required under applicable laws; limited to billing details. Even if we delete your Personal Information it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.
- When the feature is released, we will enable you to determine how long we retain audio files and patient reports for.
Patients
- We retain audio files for up to a week from the recording. This is to allow troubleshooting support to the Healthcare providers in case there is an error in the transcription.
- Your Healthcare provider will decide how long we should retain the meeting notes on our systems for. Please check with them.
Exclusions
Links: Our Services may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.
Personal Information Provided to Others: This Privacy Policy does not apply to any Personal Information that you provide to another User or visitor through the Services or through any other means, or information posted by you to any public areas of the Services.
Accessing or correcting your Personal Information
- Patients: see clause 7 above.
- Healthcare provider: You can access the Personal Information we hold about you or your Patients by emailing us (address below). Sometimes, we may not be able to provide you with access to all of your Personal Information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your Personal Information. If you think that any Personal Information we hold about you is inaccurate, please email us and we will take reasonable steps to ensure that it is corrected. We will consider and respond to all requests in accordance with all applicable laws.
Making a complaint
If you think we have breached the Privacy Act or any other relevant privacy law, or you wish to make a complaint about the way we have handled your Personal Information, you can email us (address below). Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
Contact Us
For further information about our Privacy Policy or practices, or to access or correct your Personal Information, or make a complaint, please contact us on privacy@medowhealth.ai
