Lantern is committed to protecting your data and providing you with a safe online experience. This Privacy Policy explains how we may collect, use and disclose your Personal Information when you visit our Sites or use our Services.

Where there are capitalised terms used in this policy, you can find their meaning in the definitions section below.

1       GENERAL TERMS ABOUT THIS POLICY

1.1     This Privacy Policy applies when you visit our Sites and/or use our Services, and governs our data collection, use and disclosure.

1.2     1.2 This Privacy Policy, and any terms and definitions in it, should be read in conjunction with any relevant Agreements you have with us, or have found on our Sites. If any part of this Privacy Policy is inconsistent with any term set out in the relevant Agreement, the terms of this Privacy Policy will prevail to the extent of the inconsistency. Our Agreements and this Privacy Policy are available in hardcopy on request.

1.3     Please contact us (through the method set out in clause 10 below and/or on our website) if you have questions about these terms or our privacy practices that are not addressed in this Privacy Policy.

2       COLLECTION OF YOUR PERSONAL INFORMATION

2.1      Lantern collects Personal Information in connection with the management, operation and promotion of our business. The types of Personal Information that we collect includes:

• e-mail address;
• name;
• age;
• home or work address;
• organisation name and address;
• telephone number;
• password;
• records of your use of the Services (such as details of the goods and/or services acquired and additional information necessary to provides those goods and/or services), which may include information about a health service provided by or to you; and
• business information that might be reasonably capable of identifying you as an individual (for example if you are a sole trader);
• information through customer surveys or any additional information relating to you that you provide us directly through our Sites, or indirectly through your use of our Sites.

2.2     There is also information about your use of computer hardware (including hand-held devices) and software that is collected by or on behalf of Lantern. This information can include your IP address, browser type, device type and location, domain names, access times, which pages you viewed, and how you navigated through our Sites (including fields you access or complete in forms and applications). This information is used by us for the operation of the service, to maintain quality of the service, and/or to understand general statistics regarding use of the Services.

2.3     The information that we seek to collect about you may vary and may depend on services that we provide. If you elect not to provide the required personal information, we may not be able to deliver some or all of those services effectively or at all.

2.4     Lantern's collection of data as set out in this clause and Privacy Policy generally may occur directly by us through electronic means (for example when you visit our Sites), or through third party service providers acting on our behalf.

2.5     Your information, including Personal Information, may be collected when you:

• register on our website;
• download our app;
• elect to use our Services in connection with managing your health care / support requirements and use of government entitlements;
• communicate with us through correspondence, chats, email or when you share information with us from other social applications, services or websites; or
• interact with our Sites, services, content and/or advertising.

2.6     Where links to other websites are provided through the Services, we encourage you to review the privacy policies of any such websites you choose to link to so that you can understand how those websites collect, use and share your information. Lantern is not responsible for the use, access, storage or treatment of your data (including Personal Information) and the privacy policies or other content on websites or applications outside of our Sites.

3       USE OF YOUR PERSONAL INFORMATION

3.1   Lantern collects, holds, uses and discloses your Personal Information to allow us to deliver and improve our Services and otherwise operate our business.
In some instances, we engage third-party service providers to deliver Services on our behalf or to otherwise assist us to operate, maintain and develop our business operations and our systems, procedures and technology infrastructure. Where such third party service providers will have access to your information, we will ensure that they are subject to appropriate privacy, confidentiality and security obligations.
Lantern may also disclose or otherwise make your Personal Information available to Australian government agencies or authorities, including in connection with an applicable Scheme, or to other organisations who provide funding for any goods or services you have requested or received.

3.2     Lantern may also, either directly or through one of our third-party service providers:

• use your Personal Information to send you direct marketing communications and/or inform you of other products or services available from Lantern or its affiliates; and/or
• contact you (including via surveys) to conduct research about your opinion of current Services or of potential new services that may be offered.

These communications from us may take the form of emails, SMS, mail or other forms of communication, in will be sent only in accordance with all applicable laws. You may opt-out of receiving marketing materials from us by contacting us at help@lanternpay.com.au, or by using the opt-out facilities provided in all such communications (e.g. an unsubscribe link).

4       DISCLOSURE OF YOUR PERSONAL INFORMATION AND OTHER DATA

4.1     Lantern may disclose Personal Information or other information provided by you for the following reasons:

• if such disclosure is required, authorised or permitted by law or a regulator, including in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Lantern or the relevant site; (b) protect and defend the rights or property of Lantern; and/or (c) act under exigent circumstances to protect the personal safety of users of Lantern, or the public;
• to related companies of Lantern, to assist with – amongst other things - the provision of the Services to you, to identify and manage risks, to help detect, prevent and respond to suspected fraud and other illegal acts, and to help Lantern operate its business including the provision of Services and communications to you;
• to the third party suppliers and service providers described above (including those located outside of Australia);
• to relevant Australian government agencies and authorities in connection with applicable Schemes, or to other organisations who provide funding for any applicable goods and/or services you request or receive, including to, among other things, provide the Services and related services to you, identify and manage risks, to help detect, prevent and respond to suspected fraud or other illegal acts;
• to third parties for our internal business purposes or as permitted or required by law, including to support our audit, compliance and corporate governance functions;
• to third parties who may collect certain use statistics from your devices or from our Sites in accordance with clause 2.2 above;
• to anyone to whom our assets or businesses (or any part of them) are transferred;
• to third parties where you have expressly consented to the disclosure or your consent may be reasonably inferred from the circumstances; and
• where we are otherwise permitted to disclose the information under the Privacy Act.

4.2     Lantern may collect, use and disclose information associated with your use of the Service provided that the information is de-identified, aggregated or otherwise made anonymous, and use and disclose that de-identified, aggregated or otherwise anonymous information for any purpose provided that such data does not contain Personal Information or any means of identifying you.

5       ACCURACY OF YOUR PERSONAL INFORMATION 

5.1     Lantern seeks to ensure that the information it holds about you is accurate, up to date, complete and relevant. If you learn that Personal Information Lantern holds about you is inaccurate, not up to date, incomplete, irrelevant or misleading, you should contact Lantern so that your information can be promptly corrected. Our contact details are listed below and on our website.

5.2     If you wish to see what information Lantern holds about you, you can check your account on or through our Sites. This will contain almost all the information that Lantern maintains about you. If you think we may have additional Personal Information, you can request access to that information. 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 will also need to verify your identity when you request your Personal Information.

6       USE OF COOKIES

6.1     Lantern uses "cookies" as part of the normal operation of our Sites, and the Sites may not work appropriately if your browser has cookies disabled. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. Where a cookie collects any Personal Information, for example where the cookie is linked to your account, we will handle this in the same way that we handle all other Personal Information as described in this Privacy Policy.

6.2     You have the ability to accept or decline cookies on our Sites. If you choose to decline use of cookies, you may not be able use some or all of the Services.

7       SECURITY OF YOUR PERSONAL INFORMATION

7.1     Lantern has implemented and maintains security measures designed to protect for your Personal Information against loss, unauthorised access, misuse or disclosure. These security measures include appropriate information security, access controls and data encryption.

7.2     While there is no guarantee that Personal Information transmitted to other websites is fully secure, Lantern does encrypt Personal Information in transit through the use of industry standard encryption methods.

8        MANDATORY DATA BREACH NOTIFICATION REQUIREMENTS

8.1     Lantern will comply with the notifiable data breaches scheme under the Privacy Act (NDB Scheme). The NDB Scheme requires organisations with obligations under the Privacy Act to notify the Office of the Australian Information Commissioner and impacted individuals about 'eligible data breaches'. A data breach is 'eligible' if it is likely to result in serious harm to any of the individuals to whom the breached information relates.

8.2     If Lantern believes there has been an eligible data breach that impacts Personal Information provided by you, Lantern will notify you (or the applicable individual(s) if relevant) as soon as reasonably possible and will keep in contact with you about the nature of the breach, the steps we are taking and what can be done to reduce the impacts to the applicable individuals’ privacy.

9       CHANGES TO THIS POLICY

Lantern will periodically review and update this Privacy Policy. Lantern encourages you to check our Sites and review this Privacy Policy regularly to make sure you are informed of any changes to how Lantern is processing and protecting your information. An up-to-date version of this Privacy Policy can always be found through our Sites.

10      CONTACT INFORMATION 

Lantern welcomes your comments regarding this Privacy Policy. You may contact us at help@lanternpay.com.au, including for the following reasons: if you believe that Lantern has not adhered to this Privacy Policy or you have a privacy-related complaint; if you seek further information about our privacy practices; or if you seek to access or correct your Personal Information held with us. We will use commercially reasonable efforts to respond to you promptly. We will also let you know if we need any further information.

Where you have a complaint and have contacted us as set out above, we will use commercially reasonable efforts to promptly determine and remedy the applicable issue. Where you believe we have failed to resolve a complaint satisfactorily in accordance with this Privacy Policy, we will provide you with information about further steps you can take.

11      DEFINITIONS

Agreements means any agreement(s) you have with us, including, as relevant, our LanternPay User Agreement, LanternPay Provider Agreement, LanternPay NDIS Participant Service Agreement, and LanternPay Direct Debit Agreement;

Lantern means Lantern Claims Pty Ltd (ABN 28 606 978 796);

Personal Information includes any information or opinion, about an identified individual or an individual who can be reasonably identified from their information. The information or opinion will still be Personal Information whether it is true or not and regardless of whether we have kept a record of it; Privacy Act means the Australian Privacy Act 1988 (Cth);

Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by Lantern; and

Scheme means a scheme funded by any Australian Government or Authority or any other care or entitlement scheme, or a private health insurer in relation to which Invoices may be submitted through LanternPay;

Sites means the websites, mobile apps, official social media platforms or other online properties through which Lantern offers the Services and which has posted or linked to this Privacy Policy;

We, us or our means Lantern.

Last updated 8 March 2022