Privacy Policy

Effective date: March 1, 2024

Yellow Cake Media Pty Ltd (“us”, “we”, or “our”) operates the PrimaryCareInsider.com website (hereinafter referred to as the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://yellowcakemedia.com

At any time you can exercise your rights by emailing us at DataProtectionOfficer@yellowcakemedia.com. For further details about our processing and your rights, please see below.

Definitions

• Service
  Service is the https://primarycareinsider.com/ website operated by Yellow Cake Media Pty Ltd
• Personal Data
  Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
• Usage Data
  Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Cookies
  Cookies are small files stored on your device (computer or mobile device).
• Data Controller
  Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
• Data Processors (or Service Providers)
  Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
• Data Subject (or User)
  Data Subject is any living individual who is using our Service and is the subject of Personal Data.
• About Us
  Yellow Cake Media Pty Ltd is a company registered in Australia (ABN 65627609198), with our registered office at L24, Tower 2, 101 Grafton St, Bondi Junction, NSW, 2022, Australia.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Cookies and Usage Data

Yellow Cake Media or our partner organizations may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email you receive or by contacting us.

Usage Data

We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier.

Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and ana lyse our Service. 

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. 

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

Use of Data

Yellow Cake Media Pty Ltd uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

Our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Yellow Cake Media Pty Ltd may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it is not overridden by your rights
• For payment processing purposes
• To comply with the law

Retention of Data

Yellow Cake Media Pty Ltd will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. 

Yellow Cake Media Pty Ltd will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Australia and choose to provide information to us, please note that we transfer the data, including Personal Data, to our servers located in the USA and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Yellow cake Media Pty Ltd will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Business Transaction

If Yellow Cake Media Pty Ltd is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Yellow Cake Media Pty Ltd may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Yellow Cake Media Pty Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Yellow Cake Media Pty Ltd
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Information for California Rights

This California Privacy Notice supplements the information contained in our general Privacy Policy and applies solely to those visitors and users that are residents of the State of California (“consumer” or “you”). Yellow Cake Media Pty Ltd (“we”, “us”, “our”) adopts this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended, and other California Privacy laws. Any terms defined by the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include publicly available information, deidentified information, aggregate information, or any information protected by other privacy laws and otherwise excluded from the scope of the CCPA.

This table identifies the categories of personal information we have collected about consumers within the last 12 months:

	Category	Examples	Collected
A.	Identifiers	Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers	YES
B.	Personal information described in the California Customer Records statute (Cal. Civil Code §1798.80(e))	A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Note: Personal information included in this category (1) does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records, and (2) may overlap with other categories.	YES
C.	Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)	YES
D.	Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E.	Biometric Information	Physiological, biological, or behavioral characteristics, including deoxyribonucleic acid (DNA), which can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	NO
F.	Internet or other electronic network activity information	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement	YES
G.	Geolocation data	Physical location or movements	YES
H.	Audio, electronic, visual, thermal, olfactory, or similar information	Electronic recording of customer or prospective customer calls.	YES
I.	Professional or employment-related information	Current and prior job and salary history or performance evaluations.	NO
J.	Education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K.	Inferences drawn from any other category of personal information	Deriving information, data, assumptions, or conclusions from facts, evidence, or another source of information or data to create a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

Personal information does not include:

• Publicly available information, which for purposes of the CCPA:
  • means information that is lawfully made available from federal, state or local government records.
  • does not mean biometric information collected by a business about a consumer without the consumer’s knowledge.
  • does not include data used for a purpose that is not compatible with the purpose for which the data is maintained and made available in the government records or for which it is publicly maintained.
  • does not include consumer information that is de-identified or aggregate consumer information.
• Information excluded from the CCPA’s scope, like:
  • Medical information governed by the California Confidentiality of Medical Information Act (CMIA); protected health information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health Act (HITECH); and information collected as part of a clinical trial subject to the Federal Policy for the Protection of Human Subjects.
  • Personal information covered by certain sector-specific privacy laws, including the federal Fair Credit Reporting Act (FCRA), the federal Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994 (DPPA).

Your California Privacy Rights and Choices

If you are a California resident, the CCPA provides you with additional rights regarding our use of your personal information. This section describes your CCPA rights and explains how to exercise those rights.

(1) Right to Access Your Information

You have the right to request that we disclose certain information to you about our collection and use of your personal information during the 12-month period preceding your request. Once we receive and verify your request, we will disclose to you the information that you request and we are obligated to provide under the CCPA, which may include:

• The categories of personal information we have collected about you;
• The categories of sources from which we collected your personal information;
• Our business or commercial purpose for collecting or selling your personal information;
• The categories of personal information we have disclosed for a business purpose or sold about you;
• The categories of third parties with whom we share or sell your personal information; and
• The specific pieces of personal information we have collected about you.

(2) Right to Request Deletion

You have the right to request that we delete some or all of the personal information that we have collected from you, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers to whom we have furnished that information to also delete) your personal information from our (and their) records. With respect to the exceptions, we may deny your deletion request in whole or in part if retaining your personal information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
5. Comply with the California Electronic Communications Privacy Act;
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
7. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
8. Comply with a legal obligation; or
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

(3) Right to Opt-Out

You have the right to direct us not to sell your personal information to third parties. Any personal information about you that we sell to a third party cannot be sold by that third party unless you have received explicit notice and are provided with an opportunity to opt-out of the sale of your personal information.

You (or your authorized representative) may submit your request to opt-out by using the form available on this page.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, deletion and opt-out rights described above, please submit a verifiable consumer request to us by either:

• Using the form available on this page
• Emailing us compliance[at]yellowcakemedia.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. This includes your or the consumer’s:
  • Name
  • Address
  • Email
  • Current Mailing Address
  • Alternate Phone
  • Alternate Mailing Address
  • Other personal information about you maintained by us.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Generally, we will not request additional information from you for purposes of verification. If, however, we cannot verify you identity from the information already maintained by us, we may request additional information from you, which shall only be used for the purposes of verifying you identity and seeking to exercise you rights under the CCPA, and for security or fraud-prevention purposes. We will delete any new personal information collected for the purposes of verification as soon as practical after processing your request, except as required to comply with the CCPA. 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We may require authentication that is reasonable in light of the nature of the personal information requested and will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. 

Please note that we may continue to share your personal information with our affiliates and service providers for essential purposes described above and other such circumstances allowed under the CCPA. Opting out of the sale of personal information through the “Do Not Sell My Personal information” link does not mean that you will stop seeing ads, including some interest-based ads. To learn more about interest-based advertising across sites and additional opt-out choices, please see our general Privacy Policy.

Use of an Authorized Agent

If you use an authorized agent to submit a request to know or a request to delete, we may require that you provide the authorized agent written permission and require the authorized agent to verify its own identity with us.

A power of attorney to your authorized agent is an acceptable form of authorization. 

We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

How we Verify your Request

When you submit a request to delete, or a request to know, we verify your request by taking the following steps:  

• We may match the information you provided in your request with the personal information of the consumer already maintained by us; or
• We may use a third-party identity verification service that complies with the CCPA;

When verifying a request, we consider the following factors:

• The type, sensitivity, and value of the personal information collected and maintained about you;
• The risk of harm to you posed by any unauthorized access or deletion;
• The likelihood that fraudulent or malicious actors would seek the personal information;
• Whether the personal information to be provided by you to verify your identity is sufficiently robust to protect against fraudulent requests or being spoofed or fabricated;
• The manner in which we interact with you; and
• The technology available for verification.

When you request to know categories of personal information, we verify your identity to a reasonable degree of certainty.

When you request to delete, we verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the personal information and the risk of harm to you posed by unauthorized deletion.

In all cases, we verify by matching the identifying information provided with the request to the personal information of the consumer already maintained by us.

Response Timing and Format

Upon receiving a request to know or a request to delete, we will confirm receipt of the request within 15 days and provide information about how we will process the request.

We strive to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For these requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

(4) Right to Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CCPA. For example, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through the use of discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please know that we may charge you a different price or rate or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to you by your personal information.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice (which will be updated at least once every 12 months), we will notify you through a notice on this page: Privacy Policy.

Contact Information

If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: compliance[at]yellowcakemedia.com 

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Yellow Cake Media Pty Ltd aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Yellow Cake Media Pty Ltd relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

• Google Analytics
  Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Behavioral Remarketing

Yellow Cake Media Pty Ltd uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

• Google Ads (AdWords)
  Google Ads (AdWords) remarketing service is provided by Google Inc.You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: https://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
• Facebook
  Facebook remarketing service is provided by Facebook Inc.You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950 To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217 Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA https://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada https://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe https://www.youronlinechoices.eu/, or opt-out using your mobile device settings.For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors). 

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

• Apple Store In-App Payments Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/
• Google Play In-App Payments Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/
• Stripe Their Privacy Policy can be viewed at https://stripe.com/us/privacy
• PayPal/Braintree Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”). 

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

• By email: DataProtectionOfficer@yellowcakemedia.com
• By phone number: +61291586001