Privacy Policy – Australian Skin Clinics

Effective date: 12th February 2024

This Privacy Policy outlines how we collect, hold, use and disclose your personal information. In adopting this Privacy Policy, our intent is to balance our legitimate business interests in collecting and using information obtained through our websites with your reasonable expectations of privacy.

We take your privacy rights seriously. This Privacy Policy is your assurance that we never take your privacy for granted and always take the utmost care in protecting your personal information. We comply with and are subject to obligations under the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).

Definitions

In this Privacy Policy:

the term “SILK Laser Group” (or “we”, “our” or “us”) refers to SILK Laser Australia Limited ACN 645 400 399 (SILK Laser Australia) and its related entities, and includes:
- SILK Laser Clinics; and
- Australian Skin Clinics; and
- Eden Laser Clinics Pty Ltd ACN 151 004 474;
- Clear Skincare (which refers to CSC Holdings Australia Pty Ltd ACN 625 519 075 and its related entities); and

the term “related entity” means any:
- subsidiary of SILK Laser Australia;
- franchisee of SILK Laser Australia;
- a subsidiary of Clear Skincare;
- franchisee of Clear Skincare; and
- contractual joint ventures to the extent that a subsidiary of SILK Laser Australia is a party.

Our Websites

Copies of this policy can be located at the following links:

(our Websites).

What information do we collect?

We collect personal information when you provide information:

via any of our Websites, for example purchasing any our products and/or services or making an online booking for any of our services, in registering for e-mail communications or creating a customer account;
to one of the clinics in the SILK Laser Group, such as completing our consent forms and during treatment consultations;
when giving feedback about your experience with us; and
when making enquiries about franchising opportunities.

We may also collect personal information when other health practitioners provide personal information about you to us.

The types of personal information that we collect may include but is not limited to your:

name;
e-mail address;
residence address;
phone number;
date of birth;
emergency contact details; and
subscriber status.

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 collect the following sensitive information (which includes health information):

photographs of you before and after your treatment;
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);
details of your medical history, including but not limited to imaging history, test results, medical conditions, treatments, allergies, medications and use of health services;
where relevant, family history and lifestyle information, which may include information about your occupation and genetic information; and
your health service preferences.

We will only use sensitive information to provide our products and/or services to you, and to market our products and/or services to you. This information will not be used or disclosed for any other purpose without your consent, except where disclosure may be required by law or is necessary to protect the rights or property of SILK Laser Group, any member of the public, or to lessen a serious threat to a person’s health or safety. For the purpose of this Privacy Policy, sensitive information is a subset of personal information.

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;
your qualifications and skills;

relevant financial information and screening checks (including but not limited to financial probity, identity and criminal record checks); 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/or 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;
assess a person’s application for employment with us;
deliver service and company updates and newsletters to you, to inform you about new products, services or information about us;
fulfil administrative, marketing (including direct marketing), promotional, planning and quality control purposes;
compile and maintain mailing lists derived from our Websites, from our clinics or from other entities within the SILK Laser Group and communicating with persons on those lists;
manage complaints and disputes and report to dispute resolution bodies;
respond to inquiries;
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/or products via the way we communicate with you; and
for potential franchisees, determine whether there is a suitable investment opportunity available,
or for purposes as required or permitted by any law, including the Privacy Act.

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/or services. It may also inhibit us from personalising your products and/or 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 from you and, in some cases, from other people or organisations.

We also provide your personal information to other entities in the SILK Laser 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/or 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:

related entities in the SILK Laser Group to provide you with a seamless customer experience;
any entity where disclosure to, or collection from, such entity is required, permitted or authorised by any law (including the Privacy Act);
customer, product, business or strategic research and development organisations;
data warehouse, strategic learning organisations and data partners;
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;
franchise partners, 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 SILK Laser 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
social media and other virtual communities and networks where people create, share or exchange information, where we may collect your personal information but will not disclose your personal information to such communities and networks without your permission.

We may disclose your personal information to recipients (overseas service providers) who are located outside Australia. We will only disclose personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient will not breach the APPs in relation to your personal information.

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 will use a variety of methods to collect your personal information from and disclose your personal information to, these persons or organisations, including written forms, telephone calls and via electronic delivery. We may collect and disclose your personal information to these persons and organizations regularly or on an ad hoc basis, depending on the purpose of collection. We may disclose:

customer 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 SILK Laser Group.

Your personal information and our marketing practices

Every now and then, any entities in the SILK Laser Group and any entities that use the SILK Laser Clinics, Australian Skin Clinics or Eden Laser Clinics brands might let you know – including via mail, SMS, email, telephone or online – about news, special offers, products and/or services that you might be interested in. When you provide your personal information to us, you consent to any entity in the SILK Laser Group using your personal information to directly market our products and/or services to you. You are able to opt out of receiving direct marketing at any time.

When you register with our Website, or provide personal information, you will have an opportunity, at the time we collect your information, to limit e-mail and other communications. You can request at any time that we not send future e-mails or other communications to you either by unsubscribing from the communication or by contacting us.

You can contact us to update your direct 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 unsubscribing from the email or SMS directly or by contacting us at customerservice@silklaser.com.au.

In order to carry out our direct marketing we collect your personal information from and disclose 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 that you participate in.

We, and other people who provide us with product and/or services, may combine the personal information collected from you or others, with the information we, or entities in the SILK Laser Group, or our service providers already hold about you.

Using our Websites

We may collect information about how you access, use and interact with our Websites. We do this by using a range of tools such as Google Analytics and cookies. This information may include:

the location from which you have come to the site and the pages you have visited; and
technical data, which may include IP address, the types of devices you are using to access our Websites, device attributes, browser type, language and operating system.

We use cookies on our Websites. A cookie is a small text file that our Websites may place on your device to store information. We may use persistent cookies (which remain on your device even after you close your browser) to store information that may speed up your use of our Websites for any of your future visits to our Websites. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on our Websites. You may refuse to use cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of our Websites.

Where is my personal information stored?

The SILK Laser Group takes all reasonable steps to keep secure personal information and to keep this information accurate and up-to-date.

The personal information is stored on secure servers which may be operated by us and/or by third-party storage providers if in digital format, or if in hardcopy format, under the strict control of the clinic team. In some cases, secure servers are located in Australia and/or may be overseas.

Our employees and data processors are obliged to respect the confidentiality of any personal and/or sensitive information held by us.

We implement and maintain processes and security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure.

These processes and systems include:

the use of identity and access management technologies to control access to systems on which information is processed and stored;
requiring all employees to comply with internal information security policies and keep information secure;
requiring all employees to complete training about information security; and
monitoring and regularly reviewing our practices against our own policies and against industry best practice.

We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.

How to access and correct your personal information

You may access and request correction of your personal information that we hold about you by contacting us. Please send full details of your request to privacy.officer@silklaser.com.au.

We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate and up to date.

Please note that there are some circumstances in which we are not required to give you access to your personal information.

How to make a complaint

If you believe that we have breached your privacy rights in any way, or would like to discuss any issues about our privacy policy, please contact our head office at privacy.officer@silklaser.com.au.

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 Act. If your complaint is covered by the Privacy Act, 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 endeavour to respond to you at all times promptly and to offer a practical solution which is consistent with our legal obligations.

If you remain unsatisfied with the way in which we have handled a complaint or a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) for guidance on alternative courses of action which may be available.

Security

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 SILK Laser 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 SILK Laser Group shall not be responsible for any interception of data transmitted to or from our web server.

Links

Our Websites 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.

Contact

If you have any questions, comments, requests or concerns, please contact us at: privacy.officer@silklaser.com.au

Changes

We reserve the right to review, amend, update and change this Privacy Policy from time to time and for any reason, including to reflect our practices on how we handle personal information or the types of personal information which we hold and our statutory obligations. Any changes to this Privacy Policy will be published on our Websites.

Last updated 12th February 2024.

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