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Privacy Policy

Thank you for visiting Gro and for taking the time to read our Privacy Policy.

Gro Clinics (Online) Pty Ltd (“Gro Online”, “us”, “we”, or “our”) is a health care platform that provides access to hair care and hair loss treatments. The Gro offering includes but is not limited to; ‘Everyday Products’ (over the counter) through the online store, the ‘Online Clinic’ service, which facilitates confidential consultations via an online telehealth platform with registered Australian medical practitioners (Affiliated Doctors) and health practitioners such as pharmacists (Affiliated Practitioners) who are independent from Gro® and ‘InClinic’ procedures provided by registered medical practitioners at our physical Gro Clinics locations in Australia. 

Gro Online is part of a larger group of companies owned by Gro®. Gro Online operates the Website, including the Online Store and Online Clinic. Other entities within the Gro® group of companies are responsible for operating our physical locations. The Privacy Policy only applies to your engagement with Gro Online.

Affiliated Doctors and Practitioners involved with the Online Clinic are not employees or agents of Gro Online. They are independent from Gro® and exercise their independent medical judgement in determining which course of treatment is appropriate for your condition.  Furthermore, Gro Online is not a pharmacy and does not supply prescription products. Gro Online engages pharmacies to fill customer prescriptions and provides facilitation services such as management of orders and payments and related communications.  Gro Online is therefore a facilitation service and we are not in the business of providing medical treatment or advice, nor are we in the pharmacy business.

Hence, Gro Online must disclose customer information to third parties and entities within the Gro® group of companies in order to facilitate the supply of goods and services to its customers.  See our Website Terms and Conditions for more information on our operations and the Gro® group of companies.  Gro Online will also share your information with third parties as required to provide services to you.

We are committed to respecting your privacy. This Privacy Policy sets outs out how we collect, use, store and disclose your personal information. We are bound by the Australian Privacy Principles contained in the Privacy Act and applicable state-based health records legislation to the extent we collect, use or disclose health information.

This Privacy Policy explains how we manage your personal information (that is, information or an opinion about you, whether true or not, which identifies you or from which your identity is reasonably ascertainable), including our obligations and your rights in respect of our dealings with your personal information.

Please take a moment to read this Privacy Policy as it describes what happens to your personal information that is collected via our website at groclinics.com.au (Website). By accessing the Website (including when purchasing goods or accessing services via the Website) you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy.

This Privacy Policy forms part of our Website Terms and Conditions.  Please review our Website Terms and Conditions for the terms and conditions which apply to your use of the Website.

 

How Do we Collect Your Personal Information?

We will only collect your personal information in a way that is fair and lawful, and not intrusive. Where it is reasonably practical to do so, we will collect your personal information directly from you.

We may collect the personal information you provide to us directly as follows:

  1. when you make an inquiry or order in relation to goods or services through the Website;
  2. when you attend an online consultation with an Affiliated Doctor or Practitioner through the Website, your treating practitioner will make, hold and maintain your medical records using our online medical records system. Gro Online may also be provided with notes made by Affiliated Doctors and/or Practitioners for the purposes of managing your subscription. Any health information held by Gro Online will be managed in accordance with Privacy Act;
  3. when we receive prescription information from pharmacies in relation to your prescriptions, including details of any communications you have had with the pharmacy that are relevant to your subscription;
  4. in administering and performing any contracts with partners or service providers we engage to deliver the services or to assist us with internal business functions;
  5. when you contact us via telephone or facsimile;
  6. from correspondence (whether in writing or electronically), including when you complete our online forms, contact us through the Website chat feature or write to us by email;
  7. through any Gro Online mobile applications;
  8. when conducting customer satisfaction and market research surveys;
  9. when administering any of our services; and
  10. as otherwise required to manage our business.

We may also collect personal information from publicly available sources and third parties, such as suppliers, contractors, our clients and business partners but only where it is unreasonable or impracticable for us to obtain the information from you directly.

If we collect personal information about you from a third party we will, where appropriate, request that the third party informs you of the disclosure, how we will use and disclose it, and that you may contact us to gain access to and correct or update the information.

 

What Types of Information Do we Collect?

We only collect personal information that is reasonably necessary for our business functions or activities. The type of information we may collect can include (but is not limited to), your name, postal address, email address, phone numbers, date of birth, billing and shipping information, your device ID, IP address, statistics on page views, traffic, standard web log-in information, and details of the services, products and treatments you make enquiries about. Some of this information does not identify you and will not be linked to you.

We will collect health information about you, such as your height, weight and medical history and any information you provide to Doctors or Practitioners. We only collect health information about you with your consent, or otherwise in accordance with the Privacy Act or state-based health records legislation if it applies. Gro Online provides an online medical records system. Affiliated Doctors will enter and store health information provided by you to the Doctor during telehealth consultations in the online medical records system. Access to the records is restricted to those persons who require access in order to provide services to you or to perform essential business functions, including but not limited to maintenance and security of the records.

Where you do not consent to our collection of your personal information, we may not be able to provide you with requested goods or services. If you withhold relevant personal information in relation to a consultation, the Affiliated Doctor may not have access to your complete medical history and this will limit the efficacy of any treatments or advice provided and may potentially be dangerous to your health.

 

Why do we Collect, Use and Disclose your Personal Information?

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

  1. to enable you to access and use the Website and services;
  2. to offer and provide you with our goods and services, such as to arrange online consultations with Affiliated Practitioners or to comply with your request for a pharmacy to fill your prescription;
  3. to provide facilities to Affiliated Doctors and Practitioners using our Online Clinic so that they can arrange consultations with you and store medical records;
  4. to communicate with you about topics, including (but not limited to), the goods or services you have enquired about or purchased;
  5. to follow-up on your treatment;
  6. to email you tax invoices;
  7. to dispatch and track information, returns and exchange authorisations;
  8. to perform analytics and conduct research in order to protect, improve and optimise the Website and services, business and our user experience;
  9. advertising and marketing;
  10. to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
  11. to send you marketing messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that may be of interest to you;
  12. to comply with our legal and regulatory obligations; and
  13. to otherwise manage our business, including by sharing information within the Gro group in relation to products and services which may be relevant to you.

Your information will be de-identified wherever possible for uses such as production of statistics, research and marketing.

 

To Whom do we Disclose your Personal Information?

Gro Online operates within a group of companies, which cooperate to provide you with our full range of services.  We may disclose personal information to organisations within the Gro® group of companies or to third parties such as pharmacies, Affiliated Doctors and Practitioners, organisations that provide us with technical and support services, or our professional advisors, but only where permitted by the Privacy Act.

If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do.

Specifically, we may disclose personal information for the purposes outlined in the Terms and Conditions including this Privacy Policy to:

  1. Affiliated Doctors;
  2. Affiliated Practitioners;
  3. pharmacies;
  4. cloud service providers; and
  5. payment system operators.

 

How do we Hold Your Personal Information?

We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and, in some cases, on third party servers, which may be located in Australia or overseas.

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of personal information. This also applies to disposal of personal information.

We further protect personal information by restricting access to only those who need access to the personal information to do their job. We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.

From time to time we may engage an overseas recipient to provide services to us, such as cloud-based storage solutions. Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider. However, by providing us with your personal information, you consent to the storage of such information on overseas servers (such as servers located in the United States of America) and acknowledge that Australian Privacy Principle 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the APPs, that entity will not be bound by, and you will not be able seek redress under, the Privacy Act.  In any case, Gro Online will only engage cloud service providers with robust security measures in place and who are subject to privacy laws substantially similar to the APPs.

 

Cookies

A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre-defined period of time. We use cookies to identify specific machines in order to collect aggregate information on how visitors experience the Website. This information will help to better adapt the Website to suit personal requirements.

We may use third-party vendors to show our ads on sites on the internet and serve these ads based on a user’s prior visits to our Website. We may also use analytics data supplied by these vendors to inform and optimise our ad campaigns based on your prior visits to our Website.

While cookies allow a computer to be identified, they do not contain personal information about a specific individual. For information on cookie settings of your internet browser, please refer to your browser’s manual.

 

Accessing and Correcting your Personal Information

You can contact us using the information below to access the personal information we hold about you. On rare occasion, we may not be able to provide you with access to all of your personal information and, where this is the case, we will provide you with written notice stating our reasons. We will need to verify your identity when you request your personal information.

If you think that any personal information we hold about you is inaccurate, incomplete or misleading, please contact us and we will take reasonable steps to ensure that it is corrected.

 

Changes

We reserve the right to modify or replace this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by email or by a notice on our homepage.  The new or modified Privacy Policy will apply to our collection, use and disclosure of your personal information if you continue to engage with us after we publish the new or modified Privacy Policy.

 

Making a Complaint

If you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We take all complaints seriously, and will respond to your complaint within a reasonable period.

 

Contact Us

For further information about our Privacy Policy or practices, to access or correct your personal information or to make a complaint, please contact us at [email protected].

 

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