Dr Glitter Pty Ltd is committed to protecting your privacy. The Privacy Policy explains the types of personal information we collect, how we use this information, who we share it with, and how we protect that information. Please read the following carefully to understand our views and practices regarding your personal information.

1. Introduction and who we are

Dr Glitter Pty Ltd (ABN 55 637 747 945) and its Related Bodies Corporate (as defined in s50 Corporations Act 2001 (Cth)) (Company, “we”, “us”, “our”) are committed to protecting and respecting your privacy, and ensuring all personal information we collect, or hold is handled respectfully, responsibly and securely in accordance with the relevant privacy laws including the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APPs) and the Health Records Act 2001 (Vic) (Health Act) when handling your personal information and information that is health information. 

When you use our services or access our website you provide your personal information voluntarily to us, and you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between you and us.

This Privacy Policy explains what personal information we collect, why and how we collect, use, hold, store and disclose your personal information, and your rights to access and correct that information or make a complaint about our handling of your personal information if you believe we fail to manage your personal information appropriately. We strongly encourage you to read this document carefully.

This Privacy Policy applies to all personal information collected by the Company when you access our website or contact us through other communication channels, purchase any of our products or services, or apply for an advertised position in the Company. 

This Privacy Policy does not apply to third party websites which may be accessible through links to our website (please refer to Clause 4 in this document).

From time to time, we may change our Privacy Policy by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of the most up-to-date version of our Privacy Policy.

By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. 

1. What is personal information?

Personal information is any information or opinion about an identified individual or an individual who can reasonably be identified from that information or opinion. For example, this may include your name, age, gender, address, contact details, your credit card information, information about you from social media such as your profile pictures, likes, location and social network, and information about your business if applicable. 

1. What personal information do we collect and hold?

The personal information we collect and hold about you will vary depending on the nature of your interaction with us. We may collect the following types of personal information: 

• name, gender, residential, delivery and billing addresses, email and other electronic addresses, telephone number and other contact details, age or date of birth, payment information, and health information if required;

• your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, advertising data, IP address and standard web log information;

• details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and our responses to your queries;

• if you apply for a position in the Company you may need to provide additional personal information such as employment history.

1. Why do we collect, hold and use your personal information?

We collect, hold, use and may disclose your personal information for the following purposes:

• to confirm your identity;

• to process your payments and protect you against fraudulent transactions;

• to manage delivery of your orders;

• to design the suitable products and services to you;

• to enable you to access and use our website, services and apps in an efficient manner;

• for record-keeping and administrative purposes;

• to send you our marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;

• to send you service, support and administrative messages, reminders, technical notices, updates, security alerts and to provide you with any refunds or exchanges or information requested by you;

• to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;

• to contact you, for example, to respond to your queries or complaints, or to send you an important message;

• to operate, protect, improve and optimise our products, services, website, social media pages and business such as to perform analytics, conduct research and for advertising and marketing;

• if you are a contractor, service provider, or an employee of one of our contractors or service providers, to engage with you under the relevant agreement;

• if you apply to join our team, to assess and consider your employment application;

• to comply with our legal and regulatory obligations, assist government and law enforcement agencies or regulators, resolve any disputes that we may have with any of our users, and enforce our rights and agreements with third parties; and

• to otherwise manage our business. 

We may disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive. Certain third-party service providers may have their own privacy policies with respect to the personal information we provide to them, please refer to these privacy policies to understand how your personal information will be handled by these third-party service providers. Once you leave our website or application or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy. We are not responsible for the privacy policies or practices of any other third-party website, services or application.

Where appropriate, we will confirm your express consent before collecting such information.

If you do not provide us with your personal information, we may not be able to provide you with the product or services you require, communicate with you or respond to your enquiries.

1. Do we use your personal information for direct marketing purposes?

We will use your personal information to offer you products and services we believe may interest you, but we will not do so if you tell us not to.

We and/or our carefully selected business partners may send you direct marketing communications and information about our products and services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act 2003 (Cth) and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us or by using the opt-out facilities provided (e.g. an unsubscribe link).

1. How do we collect personal information?

You may provide personal information to us via the following channels: 

• directly through your use of our website or apps; or 

• indirectly through your online presence or through other websites or accounts from which you permit us to collect information; or

• during our marketing campaigns; or

• through our customer surveys; or

• from your subscription profile; or

• records of communications with us, including your history of purchases, use of our products or services, and details of enquiries or complaints about our products and services you make; or

• your online views and insights about our business, products and services that you may provide through reviews or complaints; or 

• you intend to invest in our business; or

• when you apply for a job or position with us. 

We use a range of tools such as Google Analytics, other third-party services, cookies, and tracking technologies to analyse user behaviour and improve our site functionality. 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 the website, device attributes, browser type, language and operating system; and

• usage patterns and preferences, such as the time spent on the site, interactions with specific content, and the frequency of visits.

A cookie is a small text file that the website may place on your device to store information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our website for any of your future visits to the website. 

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 the website. 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 the website.

1. How do we store and hold personal information?

We may hold your personal information in electronic form. Your personal information will either be stored on the Company’s IT systems or the IT systems of our contractors or service providers. If your personal information is initially collected in paper form, we will destroy that paper when and transfer your information to electronic form. 

We take reasonable steps as well as implement and maintain processes and security measures to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. However, we cannot guarantee the security of your personal information, but are taking steps to restrict access to databases, maintainning firewalls, encrypting data, useing secure servers in controlled facilities and only allowing access by those entrusted with authority and computer network passwords.

Our authorised personnel will be provided with access to your personal information. These personnel are required to treat this personal information as confidential and deal with it in accordance with this privacy policy. The obligations are also imposed on contractors and service providers.

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, unless there is a legal reason why we need to continue to hold that personal information.

Although all care is taken to preserve the integrity of your personal information there remains a risk that the provided information  may be compromised during transmission, or while stored on our system, or in under certain circumstances outside of our operational control.   

1. How long do we keep personal information?

We will only keep your personal information for as long as permitted by the applicable laws and regulations. We will remove it from our systems and records when we no longer need to use it, and will anonymise it so that you can no longer be identified from it.

1. What happens to non-personal information?

We may collect non-personal information on the website and via our products and services including but not limited to, which sections of the website are most frequently visited, how often the website sections are visited, how often our products and services are utilised and for how long the website, products and services are used. This data is always used as aggregated non-personal information and may be shared with our agents and employees to provide them with information relating to how our visitors access and use our products, services and the website. This is done for the purpose of providing you with the best and most efficient services.

1. Sensitive Information

The Privacy Act protects your sensitive information, such as information about your religion, ethnicity, health or biometrics (for example, your fingerprints). If we need this type of information, we will ask for your permission, except where otherwise allowed by law.

1. Who do we disclose your personal information to, and why?

We do not sell your personal information to anyone else.

We may however transfer or disclose your personal information:

• to our related companies;

• to third party suppliers, our contractors and external service providers (including IT service providers, legal advisors etc) on a confidential basis so that they may perform services for us or on our behalf. This information may only be used to help us manage our business;

• as required or authorised by law to do so;

• as permitted to disclose under the Privacy Act;

• where you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances;

• to any person that is a party to an agreement with the Company for the sale of all or part of our business; and

• to any person or organisation that we tell you about and you consent to.

If the ownership or control of all or part of our assets or business changes, we reserve the right to the extent permissible at law to transfer your personal information to the prospective or new owner. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.

1. Do we disclose personal information to overseas recipients?

We may disclose your personal information to other organisations/people located outside of Australia. We may disclose personal information outside of Australia to third party suppliers, contractors or cloud providers located in various countries including New Zealand, China, Hong Kong, Singapore, Malaysia, Cambodia, Indonesia, the European Union, United Kingdom, Canada, the United States and other countries as applicable. 

1. Links to other sites from our website

Our sites may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

This privacy policy applies only to the information we collect on our sites.

1. Access to and correction of your personal information

From time to time, you may need to update personal information you have provided previously. If you have registered an account with us, and if it is active and valid you can update your personal information by accessing your registered account.  However, if you do not have an active account or if your account is locked, and you need access or request correction of the personal information that we hold about you please contact us. Our contact details are set out below. We may need to verify your identity before giving you access to your personal information (e.g. copies of government-issued identification, such as valid Driver’s Licence, Passport or Identity Card). There are some circumstances in which we are not required to give you access to your personal information (for example, where a legal exemption applies).

There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).

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.

1. Your rights under the EU GDPR

We welcomed the General Data Protection Regulation (GDPR) of the European Union (EU) as an important step forward in streamlining data protection globally. Although we do not operate an establishment within the EU and do not target any offering of services towards clients in the EU specifically, we intend to comply with the data handling regime laid out in the GDPR in respect of any personal information of data subjects in the EU that we may obtain.

Under the GDPR, as a data subject you have the right to:

• access your data;

• have your data deleted or corrected where it is inaccurate;

• object to your data being processed and to restrict processing;

• withdraw consent to having your data processed;

• have your data provided in a standard format so that it can be transferred elsewhere; and

• not be subject to a decision based solely on automated processing,

(together, Data Subject Rights).

We have processes in place to deal with Data Subject Rights requests. Our actions and responsibilities will depend on whether we are the controller or processor of the personal data at issue. Depending on our role as either a controller or processor, the process for enabling Data Subject Rights may differ, and is always subject to the applicable law. Please refer to the Contact Details section of this policy if you would like to make a Data Subject Rights request or have a specific need for assistance with a Data Subject Rights request.

1. Complaints

If you have a question about our Privacy Policy or think we have breached the Privacy Act or wish to make a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us in writing. Our contact details are set out below:

wow@drglitter.com

We will get back to you as soon as we can. We may not always be able to provide you with details about what we hold. In these circumstances we will explain this to you. 

We take reasonable steps to ensure that the personal information that we collect, use and disclose is accurate, up to date and complete. Where an individual requests to have personal information corrected, we will take reasonable steps to correct the Information as quickly as is reasonably possible, having regard to the purpose(s) for which it is held. If there is some reason why we don’t think the information should be changed, we will contact you and let you know.

We will also consider your complaint promptly and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.

It is our intention to use our best endeavours to resolve any complaints to your satisfaction. However, if you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC) for guidance on alternative courses of action which may be available.

Office of the Australian Information Commissioner

Phone: 1300 363 992

Mail: GPO Box 5218
SYDNEY NSW  2001

Website: www.oaic.gov.au

1. Contact details

If you have any questions, comments, requests or concerns, please contact us at:

wow@drglitter.com

1. Changes to this policy

From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website.

You may obtain a copy of our current policy from our website www.drglitter.com or by contacting us at the contact details above.

Effective Date: 22 August 2024