Privacy Policy

Fresh Trading Pty Limited ACN 624 936 081 trading as Fresh Cosmetic Clinics (we, us, our) is committed to protecting your privacy. We are bound by the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs) and have set out in this Privacy Policy how we collect, hold, use, and disclose your personal information. This Privacy Policy also explains how you can access and correct your personal information, and make a complaint about your privacy.

We value all of the personal information that is entrusted to us.  We have developed this Privacy Policy to help you understand how we manage your personal information.

This Privacy Policy applies whenever we collect, use and disclose your personal information, including:
‍
• when you use our website, which can be accessed at https://freshclinics.com.au; or
• when consulting doctors (Doctors) or operators of cosmetic clinics (Clinics) register for an account through the Fresh Clinics Consultation Application (FCC App);
• when Doctors, Clinics or the patients of Clinics (Patients) use the FCC App for consultations; and
• when you apply for a job with us.

“Personal information” is information or an opinion (in a recorded form or otherwise) about an identified, or reasonably identifiable, individual.  This includes an individual’s name, date of birth and contact details.

For Patients, ‘personal information’ can also include information or opinions about the Patient’s health, medical history, consents to medical treatments, information about your medical treatments, video records of consultations with Doctors, complications in the course of a medical treatment, and other information collected or created in the course of a consultation or receiving a medical treatment.  This health information is also called ‘sensitive information’.

Personal information we collect

The personal information we collect includes your:

• contact details (such as name, address, phone number and email address);
• current location (if the location tracking is enabled in the FCC App); and
• information that is uploaded to the FCC App, our website or otherwise disclosed to us.

The personal information we collect also includes:

for Clinics:
the above types of personal information in respect of personnel engaged by the Clinic; records and evidence of compliance with regulatory requirements; andyour payment information; for

for Doctors:
video records of consultations with Patients; andrecords and evidence of compliance with regulatory requirements;

• for Patients, your health information; and

• for job applicants, all personal information you provide in job applications such as your job history.

If you decide not to disclose your personal information to us, we may not be able to provide you with the services you would like.  

In the case of Patients, if you do not agree to the disclosure of your personal information to us, your Clinic may not be able to provide you with the services you are requesting.  Please contact your Clinic for information about how they collect, use and disclose your personal information.

Collection of personal information

Where possible, we only collect personal information directly from you.  However, in respect of: personnel of Clinics, we may collect your personal information from the operator of the Clinic’s account; andPatients, we may collect personal information from your Clinic and/or Doctor. We collect your personal information when:you interact with us, whether through the FCC App, in writing, electronically or by phone; we provide you with our services; you consult with a Doctor or Patient; orin the case of Doctors and Clinics, when you register for an account through the FCC App and use the FCC App.

Our purposes for handling personal information

We collect, hold, use and disclose personal information: to provide, maintain, protect and improve the FCC App, including troubleshooting, technical support and handling complaints and to run our business; for Doctors and Clinics: to verify your identity and administer your account through the FCC App; to allow Doctors and Clinics to contact each other and share information; to allow Doctors to consult with Patients; to ensure your compliance with any agreement you have with usfor Patients, to help ensure you receive safe and effective treatments; for job applicants, to assess and evaluate your application; to respond to any accident, complaint or claim; to generate data for internal analysis; to communicate with you; for any purpose required or authorised by law, including to manage our legal and regulatory obligations; for any other reason you consent to, or which you would reasonably expect; andotherwise to run our business.

Disclosures of personal information

As a general policy, we only disclose the personal information we collect: to our service providers, our consultants and advisors, regulatory bodies and government authorities as required or authorised by law. If we disclose your personal information to our service providers, we only disclose what is necessary for them to provide their service to us, and we ensure that they have satisfactory privacy safeguards; in respect of Clinics, to Doctors to permit the Doctor to use the FCC App, to consult with and otherwise care for Patients; in respect of Doctors, to Clinics to use the FCC App, to consult with and otherwise care for Patients, and to; in respect of Patients: to Doctors and Clinics to permit you to consult with Doctors and to receive medical treatment; to any other health professional involved in your care; to Medicare, private health insurers, medical defence organisations and complaints handling bodies where required; andin the case of medical emergencies, to third parties where we consider it appropriate or necessary to provide you with the care we believe you need; andas required by law. We never sell your personal information.We will not disclose personal information to third parties without your consent except as explained in this Privacy Policy.

Security of personal information

We are committed to protecting the security of your personal information.  We employ security measures designed to protect your personal information from misuse, interference and loss and unauthorised access, modification and disclosure.

The FCC App is hosted using cloud infrastructure provided by Amazon Web Services. Personal information we hold is encrypted at rest (on the server) and encrypted in transport by Secure Socket Layer (SSL) encryption.Personal information is only accessible by our employees and contractors with an account login and password on a need-to-know basis.

We maintain other electronic (e-security) measures for the purposes of securing personal information, such as passwords, firewalls and antivirus software. We also maintain physical security measures in our buildings and offices. The personal information we hold is treated as confidential and only accessed when necessary.  When we disclose personal information to others, we seek to ensure that they are bound by obligations of privacy.  Where we no longer need your personal information and are not required to keep a record of it, we will de-identify or destroy your personal information.

Accessing and correcting your personal information

In most cases, the personal information that we hold about Doctors and Clinics will be accessible to you through the FCC App and can be corrected by you.
For Patients, or if you think we may have other personal information that you would like to access or correct, you can contact us at info@freshclinics.com
‍If we do not agree to provide you with access to your personal information, we will provide you with written notice stating our reasons.  We may seek to recover our reasonable costs (if any) for providing you with access to any of the personal information we hold about you.

Marketing

For Doctors, Clinics and others who request it, we may use and disclose your contact information to provide you with information about products and services we think may be of interest to you.  You can opt out of receiving marketing communications from us at any time by contacting us at info@freshclinics.com or through the opt out function in any applicable message sent to you.For Patients, we will not use your personal information that we receive from Clinics or Doctors to contact you for marketing purposes.

Cookies

We automatically collect usage information that allows us to collect information regarding how users access and use the FCC App and our website. For example, when you access the website, or (for Doctors and Clinics) when you download and use the FCC App, we automatically collect information on the type of device you use and its device identifier (or “UDID”). Additionally, each time you use the FCC App or use our website, we automatically collect information regarding the type of web browser you use, your operating system, your internet service provider, your IP address, pages you view on our website, the time and duration of your visits to the website, log and contact data, crash logs and other related information relating to your use of the FCC App.  We also use cookies to gather information as users navigate through our website.

Questions and complaints

If you have any questions or you believe that we have not complied with our obligations under the Privacy Act, or you believe that the information we hold about you is incorrect or has been compromised, please contact us in writing at info@freshclinics.com. We will respond to any question or complaint as soon as possible.  If you do not agree with or are dissatisfied with our response, you can contact the Office of the Australian Information Commissioner at enquiries@oaic.gov.au or on 1300 363 992 to lodge a complaint.

Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time without notice to you.  Updated policies will be available through the FCC App and posted on our website on freshclinics.com/privacy. This Privacy Policy is current as of 6 August 2020