Privacy Policy
OVERVIEW
Shade Skin Cancer Medicine Pty Ltd (ABN 64 678 763 972) (Shade) values your privacy and the security of your personal data. Our goal is to outline to you, as simply as possible, how and why we gather, store, share and use your personal data. We also want to explain the controls and choices you have around when and how you chose to share your personal data. This Privacy Policy (Policy) will go into detail and explain this further.
This Policy applies to all Shade services, content and materials (collectively, “Shade Services”). We may, from time to time, update this Policy, the most recent version will always be available on our website.
AUSTRALIAN PRIVACY PRINCIPLES
As an Australian business, Shade is bound by the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (Act). The purpose of the APPs is to govern standards, rights and obligations surrounding personal information.
The Act defines personal information as meaning information or an opinion about an identified individual, or an individual who is reasonably identifiable:
a) whether the information or opinion is true or not; and
b) whether the information or opinion is recorded in a material form or not.
A copy of the APPs may be obtained from the website of the Office of the Australian Information Commissioner at https://www.oaic.gov.au/privacy/australian-privacy-principles/.
WHAT DATA WE COLLECT
Shade collects data from you in order to provide the best possible service to you, catered to your particular needs. We have set out below the categories of personal data that will be collected below.
The following describes the personal data collected when you register/sign up for Shade Services:
User Data: this is the personal data that is provided by you or collected by us to enable you to accept and receive Shade Services. This may include your full name, email address, phone number, birth date, gender, street address, medicare number, health insurance details and country.
The following describes personal data collected through your use of the Shade Services:
Usage Data: this is the personal data that is collected about you when you’re accessing and/or using the Shade Service. This may include your full name, email address, phone number, birth date, gender, street address, medicare number, health insurance details and country.
The following describes personal data that you choose to give us that enables us to provide you with additional features/functionality:
Payment & Purchase Data
We may collect certain personal data if you sign up/make a purchase from Shade. The exact personal data collected will vary depending on product or service as well as the payment method but will include information such as:
name, address, postal code, email address and phone number;
credit or debit card type, expiration date, and certain digits of your card number;
personal medical information, medicare card details and health insurance detals;
details of your purchase and payment history; and
mobile phone number
The following describes personal data collected from third party sources:
Authentication partners: if you register for or log into our services using third party credentials, we will import your information from such third party to help create your account with us.
Payment partners: if you choose to pay for a service via a payment partner, we may receive data from our payment partners to enable us to send you invoices and/or process your payment and provide you with what you’ve purchased.
Payment partners: we may obtain certain data about you, such as cookie id, mobile device id, or email address, and inferences about your interests and preferences from certain advertisers and advertising partners that allow us to deliver more relevant ads and measure their effectiveness.
HOW WE SOURCE YOUR DATA
The main way Shade sources your data and personal information is through the use of “cookies”. A cookie is a small data file stored on your device’s browser. Its purpose is to help the Shade website keep track of your visits and activity. The cookies we use include, but are not limited to, the Google AdWords tracking cookie; meaning Shade will continuously display ads across the internet and on the Google Display Network.
You can find information on the specific type of cookies used in your browser settings. You also have the option to block our cookies, however this will impact your experience on the Shade website.
HOW WE USE YOUR DATA
We have set below out the circumstances where Shade would use your data, the legal basis for the purpose and the categories of data which would be used in each circumstance:
Shade processes your personal data to provide and personalise the Shade Service:
The legal bases for the processing purpose are Performance of a Contract, Legitimate Interest, and Consent.
The categories of personal data used by Shade for the processing purpose are User Data, Usage Data and Payment and Purchase Data.
Shade processes your personal data to understand, troubleshoot, and address issues with the Shade Service:
The legal bases for the processing purpose are Performance of a Contract and Legitimate Interest.
The categories of personal data used by Shade for the processing purpose are User Data, and Usage Data.
Shade processes your personal data to make improvements to the service:
The legal bases for the processing purpose are Performance of Legitimate Interest, and Consent.
The categories of personal data used by Shade for the processing purpose are User Data, and Usage Data.
Shade processes your personal data for marketing, promotion, and advertising purposes:
The legal bases for the processing purpose are Performance of Legitimate Interest, and Consent.
The categories of personal data used by Shade for the processing purpose are User Data, and Usage Data.
Shade processes your personal data to comply with legal obligations and law enforcement requests:
The legal bases for the processing purpose are Performance of Compliance with legal obligations, and Legitimate Interest.
The categories of personal data used by Shade for the processing purpose are User Data, Usage Data and Payment and Purchase Data.
Shade processes your personal data to fulfill contractual obligations with third parties:
The legal basis for the processing purpose is Legitimate Interest.
The categories of personal data used by Shade for the processing purpose are User Data, Usage Data and Payment and Purchase Data.
Shade processes your personal data to establish, exercise, or defend legal claims:
The legal basis for the processing purpose is Legitimate Interest.
The categories of personal data used by Shade for the processing purpose are User Data, Usage Data and Payment and Purchase Data.
Shade processes your personal data to conduct business planning, reporting, and forecasting:
The legal basis for the processing purpose is Legitimate Interest.
The categories of personal data used by Shade for the processing purpose are User Data, Usage Data and Payment and Purchase Data.
Shade processes your personal data to process your payment:
The legal bases for the processing purpose are Performance of a Contract, and Compliance with legal obligations.
The categories of personal data used by Shade for the processing purpose are User Data, and Payment and Purchase Data.
Shade processes your personal data to detect fraud, including fraudulent payments and fraudulent use of the service:
The legal bases for the processing purpose are Performance of a Contract, Legitimate Interest, and Compliance with legal obligations.
The categories of personal data used by Shade for the processing purpose are User Data, Usage Data, and Payment and Purchase Data.
SHARING YOUR PERSONAL DATA
We have set out below the categories of recipients to who we may share information, and the reason for sharing:
Service providers: Shade has service providers who do work on our behalf and who may need to ascertain personal data so that they that they may provide their services to us.
Payment processors: We will share your personal data with our payment processors as and when necessary to enable them to process your payments, and for anti-fraud purposes.
Advertising partners: Shade and its advertising partners may, from time to time, process certain personal data to help Shade understand your preferences so that we may deliver more relevant advertising to you.
Law enforcement and data protection authorities: Personal data will be shared when we believe, in good faith, it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also share your personal data where we believe, in good faith, that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
Purchasers of our business: We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In this situation, Shade will, to the extent required by law, continue to ensure the confidentiality of your personal data and give you notice before your personal data is transferred to the buyer or becomes subject to a different privacy policy.
DATA RETENTION & DELETION
Shade will only keep your personal data only as long as necessary to provide you with the Shade Service and for legitimate and essential business purposes, such as maintaining the performance of the Shade Service, making data-driven business decisions, complying with our legal obligations, and resolving disputes. Shade keeps some of your personal data for as long as you are a customer of the Shade Service.
At your request, we will delete your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:
if there is an unresolved issue relating to your account;
where we need to retain the personal data for our regulatory, legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
where necessary for our legitimate business interests such as fraud prevention.
TRANSFER TO OTHER COUNTRIES
Shade shares your personal data globally to carry out the activities specified in this Policy. Shade may also subcontract processing to, or share your personal data with, third parties located in countries other than Australia. Shade uses a third-party company, which is located in the United States of America, to store your data. Your personal data, therefore, may be subject to privacy laws that are different from those in Australia. The APPs require us to ensure any foreign country is compliant with the APPs, unless you consent otherwise. Any submission of your personal information will constitute consent for such information to be stored, transferred, disclosed or processed outside of Australia.
LINKS
From time to time, we may display advertisements from third parties and other content that links to third party websites. Shade cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the Shade Service and any personal data you provide will not be covered by this Policy.
KEEPING YOUR PERSONAL DATA SAFE
At Shade, we take all reasonable steps to protect our customers’ personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies, procedures and IT systems to guard against unauthorised access and unnecessary retention of personal data in our systems.
Your password protects your user account, so we encourage you to use a strong password that is unique to your Shade account, never share your password with anyone, use a private network only (not public or free Wi-Fi, limit access to your computer and browser, and log out after having used the Shade Service.
ACCESS TO PERSONAL DATA
The APPs permit you to obtain access to the personal information we hold about you in certain circumstances, and correct inaccurate personal information subject to certain exceptions. If you would like to obtain such access, please contact us as set out below.
COMPLAINTS PROCEDURE
If you have a complaint concerning the manner in which we maintain the privacy of your personal information, please contact us as set out below. All complaints will be considered by us, and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.
CHANGES TO THIS POLICY
We may occasionally make changes to this Policy. When we make material changes to this Policy, you will be provided notice of the same, as appropriate under the circumstances, such as by sending you an email. Please, therefore, make sure you read any such notice carefully.
HOW TO CONTACT US
Thank you for reading our Policy. If you have any questions about this Policy, please contact us by using the ‘Contact Us’ form located on the Shade website here https://www.shadeskin.com.au/contact/, by emailing us at admin@shadeskin.com.au, or by writing to us at the following address:
The Directors
97 Outram Street
WEST PERTH WA 6005