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1.1 When you use Software, you are trusting us with your information. We recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information. We take your privacy seriously.
1.1 We respect your rights to privacy and have a legal obligation to abide by the provisions of the Privacy Act 1988 (Cth) (Privacy Act). The rules that an organisation must follow under the Privacy Act are known as the Australian Privacy Principles (APPs) and cover areas including the collection, use, disclosure, quality and security of personal information. We are also bound by any relevant health privacy principles under State legislation.
1.2 This policy outlines the types of information we collect, why we collect it and how you can manage, update and delete the information we hold.
1.3 Skin Software Pty Ltd (ACN: 641 119 646) (Software, we, us, our) is an online health platform dedicated to dermatology.
1.4 At Software we:
1.5 We collect a range of information, including personal information about you. Personal information includes information or an opinion about you (whether true or not), which identifies you or from which you are reasonably identifiable.
How we collect your personal information
2.1 We will collect and hold your personal information in a lawful and fair manner, and not in an intrusive way.
2.2 Where it is reasonably practical to do so, we will collect your personal information directly from you.
2.3 We collect your personal information directly from you when you:
2.4 We may also collect your personal information:
2.5 If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding your information, how we will use and disclose it, and that you may contact us to gain access to and correct or update the information.
Types of personal information we collect
3.1 The types of personal information we collect include (but are not limited to): your name, postal address, email address, contact phone numbers, date of birth, driver’s licence details, Medicare information, billing and shipping information, device ID, IP address, statistics on page views, traffic, standard web log-in information, details of the services and Partners you make enquiries about, written consents related to the goods and services we facilitate and, if applicable, employment information.
3.2 We only collect health information about you with your consent, or otherwise in accordance with the Privacy Act. The types of health information we collect include (but are not limited to): your medical history, Medicare number, Individual Healthcare Identifier (IHI) number, height, weight, symptoms, future health goals, medical records, medical prescriptions, and other health information or sensitive information that you provide or that we (or our Partners) consider necessary to provide our (or their) services to you.
3.3 Where you do not wish to provide us with your personal information, we may not be able to provide you with the requested goods or services.
Our purposes for handling your personal information
4.1 We collect, hold, use and disclose personal information to:
Disclosure of personal information
5.1 We disclose personal information in accordance with the Privacy Act.
5.3 We will not use or disclose your personal information for any other purpose unless you have consented to that use or disclosure or where we are required or authorised by law.
Protection of personal information
6.1 We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, as records on third party servers, which may be located overseas.
6.2 We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of personal information. This also applies to disposal of the personal information.
6.3 We further protect personal information by restricting access to your personal information to only those who need access to the personal information to do their job. Physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your personal information.
6.4 We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.
7.1 Like most businesses, marketing is important to our ongoing success. We believe we have a unique range of products and services that we provide to customers at a high standard. Therefore we like to stay in touch with our customers and let them know about new opportunities.
7.2 From time to time, we may use or disclose to our third-party service providers your personal information to provide you with marketing materials that may be of interest to you, including marketing materials in relation to offers, specials, other products and services that we, our group companies, or affiliated business partners provide.
7.3 Except to the extent that our collection, use or disclosure is subject to clause 4.1(a), we will not collect, use or disclose your sensitive information for the purpose of direct marketing without your consent. You may opt out of receiving marketing communications from us at any time by following the opt out instructions provided in such marketing communications or by contacting our Privacy Officer. Where you receive marketing communications from us through multiple channels (eg, SMS and email), you will need to opt out from each of those channels by following the instructions provided in such marketing communications or by contacting our Privacy Officer.
7.4 Receiving marketing communications is not a condition of any purchase or service with us. However, you are solely responsible for all charges related to SMS/text/email messages you send, including charges from your wireless or internet provider. If your contact details change, you may need to subscribe with your new contact details to ensure you can still receive marketing communications.
Accessing and correcting your personal information
9.1 You may contact our Privacy Officer to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. We may require you to verify your identity and specify what information you require. On the rare occasion when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to any of the personal information about you held by us.
9.2 We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusal.
9.3 We will respond to all requests for access to, or correction of, your personal information within a reasonable time.
Overseas transfers of personal information
10.1 From time to time we may engage an overseas service provider to provide services to us, such as cloud-based storage solutions. By providing us with your personal information, you consent to your personal information being handled and stored overseas, including being stored on servers located in USA, Asia or Europe.
10.2 You acknowledge that Australian Privacy Principle 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas service provider breaches the APPs, that entity will not be bound by, and you will not be able seek redress under, the Privacy Act.
Resolving personal information concerns
The Privacy Officer
Skin Software Pty Ltd
155 Clarence Street
Sydney NSW 2000
11.2 Your experience with Software is important to us. We endeavour to respond to any complaint within a reasonable period.
11.3 If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:
Office of the Australian Information Commissioner
GPO Box 5218 Sydney NSW 2001
Telephone: 1300 363 992 Email:firstname.lastname@example.org
12.2 The last update to this document was August 2022.