In this Policy, the term “ASC Group” refers to Australian Skin Clinics Pty Ltd ACN 123 038 264, ASC Master Franchise Pty Ltd ACN 153 138 268 and each of our individual clinics.
What information do we collect?
Personally identifiable information is collected when users voluntarily provide information to:
- australianskinclinics.com.au, for example in registering for e-mail communications or other services;
- one of the clinics in the ASC Group, such as completing our consent forms; and
- when making enquiries about franchising opportunities.
Personal information may also be collected when other health practitioners provide personal information to us. During these activities, we may request information such as your name, e-mail address, residence address, phone number, date of birth, Medicare number, healthcare provider details, subscriber status, and credit card number (when purchasing products or services). We may also ask you for other information at other times.
What additional information is collected about our customer?
In addition to the above information, we may take before and after photographs of you, write file notes about your skin, your treatment, medical conditions and your leisure activities. For example, a customer who is frequently exposed to the sun may require extra care when managing their skin.
What additional information is collected about our franchisees or potential franchisees?
We may also collect information about your current employment including your position, period of employment, experience and the amount you are looking to invest.
Why do we collect personal information?
Personal information is information or an opinion about an identified individual or an individual who is reasonably identifiable. We collect personal information so that we can:
- Understand your requirements and provide you with the appropriate product or service which includes assessing, diagnosing and treating a patient’s presenting issue or concern;
- Monitor the progress of our services to you and tailor the services to suit your needs;
- Set up, administer and manage our products and services;
- Gather and aggregate information for statistical, reporting and research purposes;
- Perform tasks in connection with purchasing products provided to customers;
- Manage, train and develop our employees and representatives;
- Assessing a person’s application for employment with us;
- Delivering service and company updates and newsletters to you, to inform you about new services or information about us;
- For administrative, marketing (including direct marketing), promotional, planning and quality control purposes;
- Compiling and maintaining mailing lists derived from our website, from our clinics or from other entities within the Group and communicating with persons on those lists;
- Manage complaints and disputes and report to dispute resolution bodes;
- Responding to inquiries;
- As required or permitted by any law, including the Privacy Act 1988 (Cth);
- Get a better understanding or you, your needs, your behaviours and how you interact with us, so we can engage in product and service research, development and manage the delivery of our services and products via the way we communicate with you; and
- For potential franchisees, to determine whether there is a suitable investment opportunity available.
You can choose not to provide certain information, but then you may not be able to take advantage of some or all of the features of our products and services. It may also not enable us to personalise your products and services to suit your individual needs. For potential franchisees, if you decide not to provide all information, you may not be able to take part in available investment opportunities.
How we handle your personal information?
We collect your personal information directly from you and, in some cases, from other people or organisations.
We also provide your personal information to other entities in the Group and they may disclose or use your personal information for the purposes described in “Why do we collect personal information?” in relation to products and services that they may provide to you.
We will use and disclose your personal information for the purposes we collected it as well as for related purposes, where you would reasonably expect us to. We may disclose your personal information to and/or collect your personal information from:
- Other entities;
- Any of our group joint ventures where authorised or required;
- Any entity where disclosure to, or collection from, such entity is required or authorised by law;
- Customer, product, business or strategic research and development organisations;
- Data warehouse, strategic learning organisations and data partners;
- Social media and other virtual communities and networks where people create, share or exchange information;
- Publicly available sources of information;
- Member loyalty or rewards programs and other industry relevant organisations;
- A third party that we’ve contracted to provide business, administration or consultancy services – for example: information technology providers, consultancy firms, auditors and business management consultants, sales agents, marketing agencies and other marketing service providers and print/mail/digital service/imaging/document management providers;
- Your and our advisers, agents, representatives or consultants;
- Government, statutory or regulatory bodies and enforcement bodies;
- Any external dispute resolution body;
- Investors, advisers, trustees or any other organisation that performs tasks in connection with the franchising of this business;
- Any organisation that assists us to gather or aggregate information for statistical, reporting or research purposes;
- Any organisation or person in connection with the sale of a clinic, its assets or any part or whole of the Group;
- Any other organisation or person, where you’ve asked them to provide your personal information to us or asked us to obtain personal information from them; or
- As required or permitted by any law (including the Privacy Act 1988 (Cth)).
We may disclose personal information where we reasonably believe that a failure to disclose such information places a patient or another person at risk to health or safety. We’ll use a variety of methods to collect your personal information from and disclose your personal information to, these persons or oganisations, including written forms, telephone calls and via electronic delivery. We may collect and disclose your personal information to these persons and organisations regularly or on an ad hoc basis, depending on the purpose of collection. We may disclose:
- user information in connection with law enforcement, governmental investigations or inquiries;
- to enforce compliance with the policies governing medical practices and applicable laws; and
- to protect and enforce the intellectual property and other legal rights of the Group.
What choices do I have about Australian Skin Clinics collecting, using and sharing my information?
It is possible for you to use much of this website without providing any personally identifiable information. When you do register with our website, or provide personally identifiable information, you will have an opportunity, at the time we collect your information, to limit e-mail communications. You can request at any time that we not send future e-mails to you either by unsubscribing from the communication or by contacting us.
Your personal information and our marketing practices
Every now and then, any entities in the Group and any entities that use the Australian Skin Clinics brand might let you know – including via mail, SMS, email, telephone or online – about news, special offers, products or services that you might be interested in. When you provide your personal information to us, you consent to any entities in the Group using your personal information to direct market. We will engage in marketing unless you tell us otherwise. You can contact us to update your marketing preferences at any time. Where we use or disclose your personal information for the purpose of direct marketing, we will allow you to request not to receive direct marketing communications from us, and will comply with such a request within a reasonable time frame. You may request to be removed from our marketing lists at any time by directly contacting us. If you do not wish to receive new information and marketing material from us, please email us directly at firstname.lastname@example.org.
In order to carry out our direct marketing we collect your personal information from and disclosure it to others that provide us with specialised data matching, trending or analytical services as well as general marketing services. We may use online targeted marketing, data and audience matching and market segmentation to improve our advertising relevance to you.
We may also collect your personal information for marketing through competitions.
We, and other people who provide us with services, may combine the personal information collected from you or others, with the information we, or entities in the Group, or our services providers already hold about you.
Where is my personal information stored?
The ASC Group takes all reasonable steps to keep secure personal information recorded and to keep this information accurate and up-to-date. The personal information is stored on secure servers if in digital format, or if in hardcopy format, under the strict control of the staff member treating the customer so as to not reveal the identity of the customer to anyone else. In some cases secure servers are located in Australia and the United States of America. Our employees and data processors are obliged to respect the confidentiality of any personal and/or sensitive information held by us. We destroy or de-identify personal information we no longer need, wherever possible.
How to access your personal information
You have the right to access and seek correction of your personal information held by us. Please send full details of your request to email@example.com or the customer service manager at your local clinic.
How to make a complaint
All such enquiries or complaints will be taken seriously and handled with impartiality and discretion. If you wish to submit a complaint, please provide us with all relevant details such as the date and time of the incident or communication, the circumstances surrounding the event and your concerns about what was said or done. Once you have submitted your complaint, we will assess it to determine whether or not you have complained about a privacy issue which is covered by the Privacy Laws. If your complaint is covered by the Privacy Laws, we will thoroughly investigate all aspects of your complaint including ascertaining the relevant facts and what your expectations are for any resolution. During our investigation we may need to seek further information from you as to the nature of or factual circumstances surrounding your complaint.
We will endeavor to respond to you at all times promptly and to offer a practical solution which is consistent with our legal obligations.
We take reasonable measures to protect the security of the information transmitted between browsers and our web server, including using firewalls, SSL encryption technology and other security technologies where deemed appropriate by the Group. To protect your privacy, however, please do not use e-mail to communicate information you wish to be kept strictly confidential. You acknowledge that any transmission of data may be illegally intercepted and used by third parties. The Group shall not be responsible for any interception of data transmitted to or from our web server.
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website.
Australian Skin Clinics © 2014