Genea Fertility Australia

Privacy Policy

When you are starting or growing your family, trust and confidence are central to your relationship with us. This includes how we handle your personal information.

Genea Pty Ltd provides a range of services including IVF treatments, fertility testing, genetic testing and fertility preservation options, all with the goal of helping individuals and couples build their families. References to ‘we’, ‘us’ or ‘our’ in this policy are to Genea Pty Ltd.

This Privacy Policy (Policy) sets out how Genea Pty Ltd (ABN 82 002 844 448) collects, holds, uses and discloses personal information across our business, consistent with the Privacy Act 1988 (Cth).

The kinds of personal information we collect and hold

Our staff and fertility specialists collect information about you to provide you with fertility treatment, services and advice. The table below summarises the broad categories of personal information we may collect. Further information is set out in our Privacy Collection Notice, available on our website.

Types of personal information	Examples
Sensitive information	Medical, genetic and family medical history, fertility assessments and test results, mental health records, and other health related information
Personal information	Contact details, date of birth, relationship status, emergency contacts, Medicare and health fund details, and billing information
Donor information	Donor health, physical and personal information, and donor-recipient matching information
Third party information	Partner and surrogate medical information
Audio/visual recordings	Consultation recordings (with consent), phone call recordings, and CCTV footage
Digital information	Location information (if enabled), website and app usage information, IP address and device information, website tracking pixel and cookie data (see 'Website tracking, cookies and pixels' below) and behavioural signals (such as mouse movement and timing)

We will only collect sensitive information (such as health, genetic, sexual orientation or religious belief information) with your consent, or where otherwise permitted by law, for example where necessary to provide you with appropriate care or to comply with our legal obligations.

We may also collect information from other sources, such as your referring doctor, other treating healthcare providers, health funds, or someone acting on your behalf (for example, a next of kin), where it is not practicable to collect it directly from you.

Where it is lawful and practicable, we will allow you to interact with us anonymously or under a pseudonym. However, in most cases this will not be practicable given the nature of fertility treatment and our legal obligations.

Why and how we use your personal information

We may collect, hold, use and disclose your personal information for the following purposes:

Purpose	What this involves
Providing your treatment and care	Verifying your identity, managing your treatment and coordinating care with your fertility care team and referring healthcare professionals Sending appointment reminders, treatment updates and follow-up communications and obtaining and managing your treatment consents
Improving our business	We use your information to improve the level of care, service and support we provide through activities such as: Monitoring and reviewing call recordings, online chats and other business activity for quality assurance, training and compliance purposes and create AI-generated summaries of calls Allowing staff to refer to recorded consultations or transcriptions to ensure accuracy and continuity in your care
Managing our operations	We use your information to manage our operations through activities such as: Referring your treatment for review by an advisory or clinical ethics committee where appropriate Processing billing, Medicare claims and health insurance reimbursements, and managing outstanding accounts Handling complaints, incidents and insurance related matters Sharing necessary information with service providers who support our operations or assist in delivering your care Maintaining accurate records for licensing, accreditation, risk management and quality assurance purposes Using your information for administrative, marketing, planning, product or service development, quality control and research purposes of Genea and its related bodies corporate Recording and managing the storage, retrieval, transport and disposition of your gametes and embryos in accordance with your consent forms and applicable regulatory requirements
Meeting our legal, regulatory and accreditation obligations	Where required, we use your personal information to comply with the law, including our regulatory obligations, including to: Complying with legal obligations, including disclosures required by courts, government agencies or statutory bodies (e.g. public health reporting, donor information, notifiable diseases) Providing information to regulatory and accreditation bodies such as the Reproductive Technology Accreditation Committee (RTAC) for confidential review Submitting de-identified patient and treatment information to be recorded in the Australia and New Zealand Assisted Reproductive Technology Database (ANZARD). This ANZARD information may be used for population analysis, research projects and the publication of our success rates. This information may be further supplied to other government and statutory bodies, all in compliance with regulatory requirements. In all these cases we remove any information that personally identifies you
Performing analytics activities	Sometimes we combine de-identified information we have about you and other patients, for example patient treatment results, to use this information: To understand trends in patient treatment and analyse data to help clinicians and embryologists make predictions and improve data quality To improve our business and develop services that better meet our patients' needs To understand and manage our risks better and support clinical decision-making and improve our service
Website functionality, security, analytics and online advertising	We use information collected through website tracking pixels and cookies to: Protect our website and forms from bots, malicious scripts and spam Host and operate our website, forms, and embedded video and podcast content Manage your cookie consent preferences Understand how visitors use our website, to improve content and performance Show you targeted advertising about our services and measure the effectiveness of our advertising campaigns, including retargeting. See 'Website tracking, cookies and pixels' below for the specific tools we use and how to opt out
De-identifying information	De-identified information may be used for data analysis, research purposes, reporting or marketing purposes, which may involve sending it overseas

If we are unable to collect your personal and health information, we may not be able to deliver appropriate fertility care, guidance or treatment. Additionally, insufficient information may affect your eligibility to access Medicare or private health insurance rebates.

Who we share your information with

We understand how important it is to keep your information private and we only disclose your personal information to third parties in circumstances including but not limited to:

To fertility specialists, care partners and general practitioners to treat you
To third-party service providers engaged by us (such as Microsoft Teams, Easysend, Cercle and Embryo Options) so that they may perform services for us or on our behalf, including debt collection agencies
Sharing de-identified, aggregated advertising performance data with third-party advertising partners, to help us measure how our advertising is performing
Sharing information collected through website cookies and third-party tracking pixels (such as your IP address, device and browser information, browsing activity) with third party providers such as Meta, Google, HubSpot and others named in our Privacy Collection Notice, to show you relevant advertising, unless you opt out
Regulatory and accreditation bodies, such as the Reproductive Technology Accreditation Committee (RTAC), and research database such as ANZARD and research institutions such as Universities
To government agencies and regulatory bodies to comply with laws and requirements
To parties you have instructed us to

We take steps to limit the personal information we disclose and in practice your personal information is unlikely to be disclosed to all of the parties described above.

Disclosure of personal information overseas

Your clinical and health information is stored in Australia. We only disclose this information overseas in specific circumstances, such as where you have requested and consented to it.

Separately, our website uses tracking pixels and analytics tools provided by companies based overseas (see ‘Website tracking, cookies and pixels’ below); this involves an ongoing, automatic transfer of website de-identified visitor information on an opt-out basis, rather than case-by-case consent.

Before we disclose personal information to an overseas recipient, we take reasonable steps to ensure that the recipient does not breach the Australian Privacy Principles in relation to that information, unless an exception under the Privacy Act applies. If something goes wrong with how an overseas recipient handles your personal information, we may remain responsible for that under Australian law.

Direct marketing

From time to time, we may send you direct marketing communications, such as newsletters, service updates or information about events or webinars, by email, SMS or other electronic messaging.

Where required by law, we will only use your sensitive information (including health information) for direct marketing purposes with your consent. You can opt out of receiving direct marketing communications from us at any time by using the unsubscribed link included in the communication, updating your preferences, or contacting our Privacy Officer using the details in this policy. We will not charge you for opting out.

Website tracking, cookies and pixels

We also use cookies for website statistics and third-party tracking pixels for paid advertising. These run automatically, but you can opt out at any time. Tools such as Meta and Google Ads can match your visit to our website with your social media or advertising profile, even when you are not logged in (including via Meta's Advanced Matching). However, this pixel and Advanced Matching activity is limited to our home page and does not occur on pages relating to specific fertility services. We take all reasonable steps to minimise the data collected by these tools and will only use this information for the purposes identified in this notice.

For a full list of the specific tools we use, why we use them and how to opt out of each one, see our Privacy Collection Notice, available on our website.

How we protect your personal information

We take reasonable steps to ensure the personal information we collect, hold, use and disclose is accurate, complete, relevant and up to date, having regard to the purpose for which we hold it. You can help us do this by letting us know if your contact details or other personal information change.

We take reasonable steps to protect the personal information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include restricting access to personal information on a need-to-know basis, staff training, technical and physical security controls and ongoing review of our security practices and those of our service providers.

We retain personal information for as long as we need it for the purposes described in this policy, or as required by law. As a provider of assisted reproductive treatment, we are subject to specific state and territory laws that require us to retain certain patient and donor records for extended periods.

Accessing and correcting your personal information

You can ask us for access to the personal information we hold about you or ask us to correct it if you believe it is inaccurate, out of date, incomplete, irrelevant or misleading.

To make a request, please contact our Privacy Officer using the details in this policy. We may need to verify your identity before we can act on your request. We will generally respond within a reasonable period.

In some circumstances, we may refuse to give you access to, or correct, your personal information - for example, where we reasonably believe giving access would pose a serious threat to the life, health or safety of any person, or would have an unreasonable impact on the privacy of others. If we refuse your request, we will explain our reasons where it is reasonable to do so and let you know how you can make a complaint about our decision.

If we refuse to correct your personal information, you may ask us to associate a statement with it, noting that you believe it is incorrect, and we will take reasonable steps to do so.

How to make a privacy complaint

If you have any concerns about how we have handled your personal information, we encourage you to raise them with us first. You can contact our Privacy Officer using the details in this policy.

We will acknowledge your complaint within a reasonable time and aim to investigate and respond within 30 days. If we need more time, we will let you know and explain why.

If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC):

Website: www.oaic.gov.au

Phone: 1300 363 992

Mail: GPO Box 5288, Sydney NSW 2001

Changes to this Privacy Policy

Sometimes we update our Privacy Policy. We may make changes to reflect changes in our practices, our services, or the law. The most current version will always be available on our website, and we will take reasonable steps to notify you of significant changes.

Our Privacy Policy and how to contact us

You can locate our Privacy Policy through https://www.genea.com.au/pages/genea-privacy-policy-MCFKLVTHWY3VBGLJG3THJSA4LSF4 or ask for a copy at your clinic.

You can contact us to talk about our privacy policy and practices by:

Email: privacy@genea.com.au

Phone: 02 9229 6441

Mail: Level 3, 321 Kent Street, Sydney NSW 2000

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Genea privacy policy