Effective Date: September 8, 2017
If you have questions about this policy, please feel free to contact us at:
10 Leilani Court,
Highton VIC 3216
Phone: 1800 726 090
In describing our collection, use, and sharing of information in this Policy, we refer to our collection and use of "Personal Information." "Personal Information," as used in this Policy, is personally identifiable information, which is information that directly identifies an individual, such as first and last name, mailing address, email address, IP addresses, demographics, or telephone number. We collect Personal Information, as well as non-personally identifiable information on the NetSmart site.
We collect Personal Information in two ways. First, we collect information you provide to us in optional, voluntary submissions, such as in registration forms or requests for customer service. Second, some Personal Information may be collected automatically. This is described below in "Passive Data Collection".
We may also obtain information, including Personal Information, from third party sources. If we directly combine information from third parties with Personal Information that we have collected, we will treat the combined information as Personal Information and handle it in accordance with this Policy. In addition, please note that we may solicit third parties to collect Personal Information on our behalf and in such cases we instruct those third parties to comply with this Policy and all applicable data protection laws.
Please be aware that we are prohibited from conditioning a child's participation in any activity on that child disclosing more personal information than is reasonably necessary to participate in that activity. You are under no obligation to provide, and can decline to provide, any requested information at any time. However, if you decline to provide personal information that is reasonably necessary to participate in certain activities, you may not be able to participate in those activities.
Passive Data Collection
We may receive passively-collected information through a variety of methods including but not limited to:
We may use a variety of methods, including "cookies" to collect information.
What is a cookie?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device. You can find more information about cookies at: http://www.allaboutcookies.org.
Cookies do lots of different jobs, like letting you navigate between pages efficiently and remembering your preferences, and generally improve the user experience. They can also help to ensure that advertisements you see online are more relevant to you and your interests.
The cookies used on our Site have been categorized based on the categories found in the ICC UK Cookie guide. A list of all the cookies used on our Site by category is set out below:
NetSmart collects cookies on our Site to capture information about page visits (e.g. “performance cookies.”) This information is anonymous and NetSmart uses this information only internally - to deliver the most effective content to our visitors. Information from the cookie is used to gauge page popularity, analyze traffic patterns on our Site and guide development of other improvements to our Site.
Targeting, Performance, and Functionality Cookies
In our email programs, NetSmart employs some tracking methods (e.g. “targeting, performance, and functionality cookies”). We may track "opens" via a tracking pixel in the email -meaning we track who opens our email messages and when our email messages are opened; and we track "clicks" via encoded URLs - meaning we track whether you click on the links contained in our email messages. This information is used internally only to help us deliver relevant messaging, and is not shared with any third parties.
Functionality and Necessary Cookies
Opting Out of Cookies
By using our Site you consent to the placement of the cookies referenced above. You can, however, set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it.
NetSmart never gives away information about our users. If you choose to provide Personal Information about yourself, NetSmart will use this information only to communicate directly with you. NetSmart will not sell, rent or otherwise disclose that information to third parties unless such disclosure is necessary for the purposes set forth in this Policy, or by law.
We may collect, use, and share (with NetSmart partners, service providers and licensees) precise location data, including the real-time location of your mobile or fixed location device.
We use analytics tools and other third party technologies, such as Google Analytics, to collect non-personal information in the form of various usage and user metrics when you use our Site. These tools and technologies collect and analyse certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behaviour and usage information, feature use metrics and statistics, usage history, and other similar information.
The third party analytics companies who collect information on our Site may combine the information collected with other information they have independently collected from other websites and/or other online or mobile products and services relating to your activities across their network of websites as well as online and/or mobile products and services. Many of these companies collect and use information under their own privacy policies.
In addition to our use of technologies as described herein, we may permit certain third party companies to help us tailor advertising that we think may be of interest to you based on your use of the NetSmart Site and to otherwise collect and use data about your use of the NetSmart Site.
Generally, we use Personal Information to establish and enhance our relationship with our users through four main categories: (1) Communication; (2) Optimization; (3) Advertising; and (4) Sharing Features. Below, we provide some specific examples of how we use the Personal Information and other information we collect.
Communication and Responding to Requests
We use your information, including Personal Information to provide you with customer support, respond to users' requests, send newsletters and updates, send special offers and advertisements, seek your opinions and feedback, and connect you to products and services of our partners and licensees.
We use your information, including Personal Information, behavioural metrics, and other non-personally identifiable information to operate, provide, improve, and maintain our Site, to prevent abuse and fraud, to personalize and display advertisements and other content for you, and for other administrative and internal business purposes.
We use your information, including Personal Information, behavioural metrics, geo-location data, demographic data and marketing preferences to personalize and display advertisements and other content for you.
We may provide Personal Information to third parties for their use in performing internal business functions (e.g., security, data analysis, email transmission, beta testing, or data hosting) on our behalf.
Whenever possible, we require such third-parties to only collect and use Personal Information in accordance with this Policy, to maintain the confidentiality, security, and integrity of such Personal Information, and for no purpose other than providing us with our requested services.
We may disclose Personal Information if we have a good-faith belief that doing so is required by a subpoena, warrant, or other judicial or administrative order or otherwise required by national security, law enforcement requirements, statute, government regulation, or law. Additionally, we may disclose Personal Information where we, in good faith, deem it appropriate or necessary to take precautions against liability, protect our rights, property, or safety, or those of a partner, any individual or the general public; maintain and protect the security and integrity of our Site, protect ourselves and our Site from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third party claims or allegations; or assist government regulatory agencies.
Change of Ownership
Information about our users, including Personal Information, may be disclosed as part of any bankruptcy, merger, sale, transfer of company assets, acquisition, or similar transaction. In the event of such a transaction in which your Personal Information would be transferred to a third party, we will make reasonable efforts to notify you. For example, we will post a notice of the transfer of Personal Information on our Site and, if we have your email address, we will send notice of the transfer of Personal Information to that email address.
In addition to using cookies and related technologies as described above, we also may permit certain third party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on our Site (e.g., to allow them to tailor ads on third party services). These companies may deliver ads that might also place cookies and otherwise track user behaviour. These companies may use information about user behaviour in order to provide customized advertisements across various services and products. In the course of providing these services, products or placing advertisements, these third party companies may place or recognize a unique cookie on your computer, and may record information to these cookies based upon your activities on our Site and on third party websites. Each of these companies uses this cookie information according to their own privacy and security policies. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out as indicated in this Policy. Please note this does not opt you out of being delivered advertising. You will continue to receive generic ads.
Submitting Personal Information
If you do not want to submit Personal Information that is necessary to provide to use our Site or to fulfil your request, you will not be able to access and/or participate in certain NetSmart Site services. In addition, your refusal to submit Personal Information may limit our ability to respond to your customer support inquiry in a timely fashion.
If you want to remove yourself from individual communications, including marketing promotions, advertisements, updates and email newsletters, simply click the unsubscribe link in the communication. You also acknowledge and agree that there may be instances where we may elect to notify you about administrative notices such as to inform you about changes to our terms, conditions, and policies, or to provide you with other relevant administrative information. Because this information is important to your interaction with us, you may not opt out of receiving these communications.
We take reasonable measures, including the implementation and maintenance of physical, electronic, and managerial procedures, in an effort to assure the security, integrity, and accuracy of all Personal Information that we collect. Our efforts include procedures designed to avoid unauthorized access, alteration, loss, misuse, disclosure, or destruction of Personal Information taking into account the risks involved in the processing and the nature of the Personal Information.
If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the NetSmart Site covered by this Policy and providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your account information and usage.
We collect and use Personal Information in accordance with this Policy and only for the limited relevant purposes stated in this Policy and/or at the time we request such Personal Information from our users, or for such purposes to which a user may otherwise consent. We do not use or share our users' Personal Information in a way that is incompatible with the purposes for which such Personal Information was requested and authorized for use by us. We retain Personal Information for no longer than is commercially useful to carry out our business purposes, or as we believe may be legally required. NetSmart takes reasonable steps to ensure that the Personal Information is reliable for its intended use, accurate, complete and current.
We may update this Policy from time to time. If we do, we will update the "effective date" at the top of the Policy. If we make material changes to how we use Personal Information, we will attempt to notify you of the change and to give you the opportunity to exercise choice as to how your Personal Information is used. We will post the updated Policy on the Site and if we have your email address, we will send notice of the update to that email address.
We encourage you to review this Policy periodically to stay informed about our collection, use and disclosure of Personal Information. Your continued use of our Site or any other content, products or other services covered by this Policy constitutes your agreement to this Policy and any updates.