The SFI Health Group ("SFI Health", "we" or "us") works hard to foster and maintain confidence, goodwill and stronger relationships with you. We are committed to protecting your privacy and the security of your Personal Information. For that reason, please read this Privacy Policy carefully and contact us if you have any questions.
This Privacy Policy describes how we collect, hold, use, disclose and otherwise handle the personal and sensitive information we receive when you access or visit our website www.sfihealth.com or our mobile applications.
Although anyone can view our websites, our mobile applications and services, they are not directed to individuals under the age of 16 years. Therefore, if you are under 16 years of age, please do not provide Personal Information through our mobile applications or services.
If you are a parent or guardian and your child has provided us with their Personal Information, please contact us so that we can delete it from our records.
"Personal Information" is information or an opinion from which your identity is either clear or can reasonably be determined. Personal Information may include your name, email address, birth date, phone number, gender, location and any other Sensitive Information.
"Sensitive information" includes personal information about your physical or mental health or disability (at any time); any information you provide about future health services you may require or about a health service provided or to be provided to you; any genetic information you provide; personal information (such as date of birth, gender, race, sexuality or religion); or other healthcare identifiers.
SFI Health is a global business, so the Personal Information you provide to us will be controlled by any of our related entities listed below:
| Countries | Data Controller |
|---|---|
| SFI Corporate | Soho Flordis International Pty Ltd |
| Australia | Soho Flordis International Australia Pty Ltd |
| Asia | Soho Flordis International Asia-Pacific Pty Ltd |
| Korea | SFI Korea Inc |
| SFI Corporate | SFI Research Pty Ltd |
| India | SFI India Private Limited |
| EU | Ginsana SA |
| South Africa | Soho Flordis International South Africa (Pty) Ltd |
| USA | ProThera Inc., dba SFI USA |
| Mexico | Soho Flordis International de Mexico S.A. de C.V. |
| UK | Soho Flordis UK Limited |
You can learn more about SFI Health here.
We collect Personal Information when you voluntarily provide it to us, such as where you:
We may use the Personal Information we collect for the following purposes:
If you are an EU resident, you also have other personal data rights such as the right to:
You can use any of our sites and mobile applications without disclosing any of your Personal Information. However, unless you provide us with the requested Personal Information, you may not be able access some of our services (such as if you want to purchase products or services online, use our mobile applications, enter competitions or be involved in clinical research trials).
Please read more about how we collect, hold, use and disclose your Personal Information by clicking on the heading below, or you can print out a full PDF version here.
You agree that we may collect, hold, use and disclose your Personal Information for any of the purposes listed in Point 5 of the Summary above.
Healthcare Professionals: We may collect Personal Information about healthcare professionals and their employees (such as doctors and pharmacists) who dispense and prescribe SFI Health’s products and services. If you are a healthcare professional, you will also need to provide your Personal Information so that you can use our mobile applications or services for your practice or with your patients. If you are a healthcare professional, or will be giving information to your healthcare professional via one of our sites or mobile applications, you can read more under "Sensitive Information - Collection, use and disclosure".
When you interact with us through our sites and mobile applications, we may collect information from you as described below.
Some elements of our sites or mobile applications may ask you to submit Personal Information in order for you to benefit from the specified features or participate in a certain activity, such as newsletter subscriptions, processing of online purchases, completion of surveys, or account registration. For example:
We may combine information you submit through our sites and mobile applications with other information we have collected from you, whether on-line or off-line. We treat the combined information in accordance with this Privacy Statement.
We only use the Personal Information for the purposes for which you have agreed to and/or expressly consented.
We use Personal Information submitted by you or collected through our sites, mobile applications and through other sources, for the purposes described in this Privacy Policy. Generally, we use the information you provide to use for the reason for which it was provided and as described to you at the point of collection. For example, if you sign up to receive email notifications, we will contact you by email. If you provide us with information to purchase a product, we will use the information to process your transaction. Specifically, we may use Personal Information from or about you:
We may use any information that does not personally identify you, your computer, or your device, for any purpose.
Your Personal Information may be disclosed for the following purposes:
There are also other circumstances in which we may collect your Personal Information indirectly. For example, we may occasionally collect Personal Information from third party companies, healthcare professionals and information service providers with whom we have a relationship (referred to collectively in this Privacy Policy as "our partners"). In such circumstances, we take all reasonable steps to ensure that our partners have obtained your consent to disclose your Personal Information to us.
SFI Health may also, in some circumstances, collect and use Sensitive Information that you voluntarily provide to us which requires greater restrictions, such as if you agree to participate in clinical trials, questionnaires or research, or are using SFI Health’s mobile applications or services.
Our use of your Sensitive Information is to enhance your ability to make informed decisions about your health care. If you agree to provide us with Sensitive Information, it will be used for SFI Health’s internal statistical or business purposes only, unless you expressly consent otherwise.
We do not disclose your Personal or Sensitive Information to our partners unless you have expressly consented to such disclosure; it has been de-identified; or if it is directly related to the primary purpose for which it was collected.
Some of the SFI Health mobile applications and services may be offered to you by your healthcare provider. Your healthcare professional may ask you to expressly consent to them collecting, using and sharing your Personal Information. You should therefore also review your healthcare provider’s privacy policy.
If you do not give your healthcare provider consent to use your Personal Information you can still view or use the SFI Health mobile applications or services, but many of the features and functionalities will not be available to you.
SFI Health will not have any access to any Personal Information you share with your healthcare provider via the SFI Health mobile applications or services unless you have also expressly given us consent.
If you are a healthcare professional and you are using an SFI Health mobile application or service in the provision of medical or professional healthcare services, it is your sole responsibility to:
We may collect information about your web behaviour such as your IP address, browser type, URLs of the websites you access from our website and details of the webpages you visit (see Interest-based Advertising below), as well as other software and hardware information that may be available. This information is automatically provided to us by your web browser without revealing to us your identity or any other Personal Information. This is done in the following ways:
An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet. When you visit our sites, we may view the IP address of the device you use to connect to the Internet. We use this information to determine the general physical location of the device and understand from what geographic regions our website visitors come. We also may use this information to enhance our sites or mobile applications.
Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and Internet browser type and version.
Our sites may include social media tools, including social media widgets or plug-ins, to connect you to our social media pages. These features may set a cookie or use other automatic collection and tracking technologies to collect information about you and your use of the social media features through and in connection with our sites. These social media tools may be hosted by a third party. Your interactions with these tools and the corresponding social media platforms are governed by the privacy policies of the companies that provide such platforms.
We also use cookies to collect useful information about how you interact with SFI Health sites and mobile applications. You can read more about how we use cookies below. The information we collect in this way is, by itself, anonymous ("Non-Personal Information") and it cannot be used to identify or contact you.
We may provide Non-Personal Information to our partners, who may use it to understand how often and in what ways you use our websites and services so that they too can provide you with an optimal experience. We never disclose Non-Personal Information to a partner in a manner that would identify you personally.
When you visit our websites, non-personally identifiable information in the form of a "cookie" may be stored on your computer enabling automatic user recognition for when you next visit our sites or mobile applications. Cookies allow us, for example, to adapt a website to your interests or to store your location, to save you from having to re-enter the information each time you visit.
Some cookies are essential whilst others help us improve your experience. Essential cookies help make our sites and mobile applications usable by enabling basic functions like page navigation and access to secure areas. Our sites and mobile applications may not function properly without these cookies. Some other cookies may help us to comply with legal requirements like the EU’s GDPR (privacy) such as managing your consents, requests and company data.
We also cookies to understand your browsing and buying activities to measure the success of online advertising campaigns we run on our sites and mobile applications. We also use:
The cookies and web beacons we use collect non-personally identifiable information about you including: IP address, browser used to access the site, date and time, the URL of the page being loaded, users who have visited a particular website(s), any previously assigned cookie identification (a unique identifier assigned to a user to identify repeat visitors), browser window size, your geographic location, device and operating system used to access our sites or mobile applications. The information we collect from these cookies and web beacons is used to:
If you do not wish your computer to be recognised, please select browser settings to delete cookies from your hard drive; or block all cookies; or prompt you before a cookie is stored. Each Internet browser has a different procedure for disabling the use of cookies. The Help function within your browser should tell you how. Alternatively, visit http://www.aboutcookies.org where you can find information on how to control cookies on a variety of browsers.
You will also find details of how to delete cookies from your computer and other general information about cookies. You should note, however, that turning off cookies may prevent some of our websites or mobile application features from working properly.
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The SFI Health website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). This tool helps us understand how visitors engage with our website. SFI Health as a Google Analytics customer can view various reports on how visitors interact with our website. This allows us to make improvements based on the information generated by the tool.
You can prevent transmission of the data generated by the cookie and relating to your use of the website to Google (including your IP address) as well as processing of the data by Google by downloading and installing the browser plug-in available: http://tools.google.com/dlpage/gaoptout?hl=en
When you are using SFI Health websites or mobile applications, your location information may be used to tailor our products or service offerings to your current location. Your mobile device’s ‘background location’ may be used to provide the services, including to send you notifications. If you have ‘background location’ turned on, we may gather information about your device’s location even if you are not directly interacting with the application. This information is not shared with others.
If you do not wish for your location to be accessed, please ensure you turn the ‘background location’ off on your mobile device.
We work with third-party advertising companies and networks to display ads online or on mobile applications. These ads are tailored to your individual interests based on how you use our sites, and the other websites and online services that you use. Note that these advertisements may be delivered to you on our sites, on third party websites and applications, and on a computer or device other than the device from which the information was collected.
This is called "Interest-Based Advertising" or "Online Behavioral Advertising."
To learn more about Interest-Based Advertising, you can visit any of these sites:
www.networkadvertising.org/choices
www.datalogix.com/privacy
www.aboutads.com
Click here to read more about SFI Health’s use of interest based advertising, and your participation choices
In accordance with industry self-regulatory principles, we will notify you about:
You can find this information by clicking a specialised icon, logo, or text in or around the relevant advertisement.
Some of our third-party service providers may participate in self-regulatory programs for interest-based advertising through the Network Advertising Initiative (NAI) and/or the Digital Advertising Alliance (DAA).
Each of these programs provides an opt-out feature where you can choose not to receive targeted advertising from any NAI member or DAA participant. To opt-out of tracking by companies who are NAI members, please click HERE. To opt-out of tracking by companies who are DAA participants, please click HERE.
Some of our third-party service providers do not participate in the NAI or DAA. This means that you will not be opted-out of tracking by these providers by following the instructions in the paragraph above. Instead, click on the name of each provider below to get more information about how to opt-out of that providers’ tracking technologies.
| Advertising Partner | Opt Out Features |
|---|---|
| [name] | [Opt out link] |
For mobile advertising, you may also use your phone operating system’s opt-out setting (For instructions on how to "Limit Ad Tracking" on iOS, please visit this Apple Support Document; For instructions on how to opt out of interest-based ads on Android, please visit these instructions); and
If you would like, you can discontinue using our sites and delete our applications from your devices. To uninstall our applications from your devices, such as smartphone applications, tablet applications, connected TV applications, and desktop, you can use the standard uninstall processes available as part of your device or via the application marketplace or network.
If you use more than one device, you should renew your opt-out choices on each such device.
We may disclose your Personal Information and Non-Personal Information to our partners for the purposes identified in our Summary (Point 7) above. Except as set out in this Privacy Policy, or as expressly consented to by you as required by law, we will not disclose any of your Personal Information to our partners.
We may disclose your Personal Information or Non-Personal Information if we are required to do so by law, including in connection with any legal proceedings or anticipated legal proceedings, or to comply with any legal obligation, or to establish, exercise or defend our legal rights.
We may also sell, transfer, or disclose our database of Personal Information, Non-Personal and Health Information to an actual or potential successor entity, purchaser, or investor in connection with significant structural transactions involving SFI Health a corporate merger, consolidation, sale of our assets or substantially all our assets, share sale, investment transaction or other corporate rearrangement.
We use up to date server, database, backup and firewall technologies for the protection of all information we hold. We have also implemented various processes and systems to ensure the security of your Personal Information, including encryption of all data when it is transferred to our service providers and limitations on access to Personal Information within our organisation.
In the event of a data breach, SFI Health will notify the relevant regulators within 72 hours and, in serious cases such as where there is a high risk to your rights and freedom (such as of security, confidentiality or identity theft), we will also notify you as soon as is reasonably possible.
SFI Health owns and manages websites that may contain links to other websites. Please note that SFI Health are not responsible for the compliance with data protection regulations by third-party providers or the contents of such websites, and we are not in any way liable for how these third parties collect, hold, use or disclose your Personal Information.
We recommend that you read the Privacy Policy (and other material such as data protection declarations and privacy statements) of any third party websites you visit.
SFI Health does not disclose Personal Information to any overseas recipients. We do however disclose your personal information to our affiliated companies and partners to the extent permitted in this privacy policy.
We will take all reasonable steps to ensure that information we hold about you is accurate, complete, relevant, up-to-date and not misleading on a regular and ongoing basis.
If you would like to obtain access to, correct the or request deletion of information we hold about you, please contact our Privacy Officer by completing an online enquiry form or:
BY MAIL: To the Privacy Officer, Soho Flordis International Pty Ltd at PO Box 1027, Crows Nest NSW 1585
BY TELEPHONE: 1300 334 224
BY EMAIL: to privacy@sfihealth.com
If you reside in the EU, you may request to:
Subject to certain limitations under California Civil Code § 1798.83, California residents may ask us to provide them with (i) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties. To make this request, California residents may contact us as specified in the "Contacting us" section above.
Please provide the statement "Your California Privacy Rights" in the subject field of your e-mail or on the envelope or post card and in the actual request. For all requests, please include your name, street address, city, state, and zip code.
These requests must made to SFI Health in writing to the Data Protection Officer at privacy@sfihealth.com , together with proof of identification so that we can verify your request. Please allow us 2-4 weeks to process your request. SFI Health reserves the right to refuse your request if it is manifestly unfounded or excessive, and we will notify you in writing if this is the case.
If you wish to make a complaint about how we handle your Personal Information or Non-Personal Information, you can email our Privacy Officer (or Data Protection Officer if you are an EU resident) at privacy@sfihealth.com .
Please provide as much detail about the facts surrounding your complaint so we can resolve it accordingly. Allow us at least 7 days to respond to your complaint.
If we fail to resolve your complaint, you may refer the matter to the Australian Information Commissioner (see www.oaic.gov.au), or the supervisory authority in the Member State of your habitual residence, place or work or place of the alleged infringement.
We only retain your data for as long as is necessary for us to provide the goods or services you have requested or to which you have given consent, unless otherwise provided by law.
We may change this Privacy Policy from time to time to ensure they are current. Updated versions of this Privacy Policy will be posted on our websites and/or notified via our mobile applications. We will also provide you with 30 days’ notice of the modification by email where you have provided it to us. Updates are effective 30 days’ after posting or notification.
You can cancel or unsubscribe from SFI Health sites and services if you do not agree with the revised Privacy Policy. Otherwise, your continued access or use of the SFI Health websites and/or mobile applications will signify your confirmation and acceptance of the revised Privacy Policy.
This Privacy Policy is governed under Australian law and you agree to submit to the exclusive jurisdiction of the courts of Australia and any courts that may hear appeals in respect of any proceedings in connection with this contract.
This Privacy Policy was last updated in June 2018.
