Collection Notice

Advanced Hair Studio

For the purpose of this Collection Notice, the Advanced Hair Studio group of associated companies is comprised of the following companies:

• Advanced Hair Studio Pty Ltd ACN 005 245 143
• Advanced Hair Studio (Franchising) Pty Ltd ACN 006 236 166
• Advanced Hair Studio of Australia Pty Ltd ACN 005 784 298 (AHSA)

(together and separately (as applicable), AHS, we, us, our).

AHSA conducts a business known as Advanced Hair Direct (AHD) from a website at https://www.advancedhairdirect.online (AHD Website) which is a health platform that facilitates confidential consultations with Australian registered doctors (Doctors) and health professionals (Practitioners) and which sells personal care products and facilitates the supply by mail of medications by independent pharmacies (Pharmacies) which use the platform.

This Collection Notice sets out the matters described in Australian Privacy Principle (APP) 5.2 (as part of the Privacy Act 1988 (Cth)) as they relate to AHS, when we collect personal information about you.

1. Purpose of Collection

We collect personal information primarily to:

• provide you with the goods, services and information that you request from us;
• provide you with information about AHS’ products and services;
• suggest AHS products and services to you;
• manage our relationship with you;
• enable you to use and access the AHD Website;
• to provide facilities to Doctors, Practitioners and Pharmacies who work with or use AHD so that they can arrange consultations with you and provide services and goods to you;
• to communicate with you in the event that any services requested are unavailable or if there is a query or problem with a scheduled consultation or an order for goods, or with your subscription;
• to operate, protect, improve and optimise our website and services, business and our users’ experience, such as to perform analytics, conduct research and quality assurance activities, and for advertising and marketing;
• to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
• to maintain and update our records including medical records. We aim to provide users with continuity of care which requires that records from one consultation or order are available to Doctors, Practitioners and Pharmacies who subsequently provide you with services or goods;
• subject to our legal obligations and your rights to unsubscribe, 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 we think you may find interesting; and
• to comply with our legal obligations, exercise and defend our legal rights, resolve disputes, and perform and enforce our agreements. Some of the laws under which our obligations and rights in respect of collection of Personal Information arise include the Human Services (Medicare) Act, Healthcare Identifiers Act and National Health Act.

If it is reasonable to expect that we would use or disclose your personal information for purposes which are related to the above primary purposes, we may also use or disclose your personal information to:

• assist you with enquiries or complaints;
• develop and improve our client service and relationships;
• promote, advertise and market any of our products and services, including to invite you to seminars or events hosted by AHS;
• to comply with our legal obligations (including to comply with any law or any lawful request of a law enforcement agency or government authority), resolve any disputes that we may have with any of our clients and enforce our agreements with third parties such as your employer; and
• inform you of developments at AHS and other products or services that we can provide.

We may use information collected through our Website or the AHD Website for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are at our Website or the AHD Website.

We may otherwise use your personal information to comply with any law, and to comply with any lawful request of a law enforcement agency or government authority.

Where possible, we will provide you with a choice to opt-out of any of the above and any of our marketing activities. We will respect your request to decide whether or not to receive these marketing communications.

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

2. Type of personal information collected and consequences if personal information is not collected

In general, you can assume that we may collect the following personal information about you:

• name;
• address;
• email address;
• telephone number and other contact details;
• details about you to assist in managing our relationship with you;
• details of the products or services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
• billing and shipping information; and
• your device ID, IP address and web log in information.

If you are a customer participating in, or enquiring about participating in an AHS program or procedure, or obtaining goods or services from the AHD Website, we may also collect your date of birth, height, weight, medical history (which may include information about sexual activity / orientation, religious and other beliefs, ethnicity and genetics where relevant), medicare number, individual healthcare identifier, health care and concession care details, health insurance details, take a photograph of your head and scalp and collect health information about you, including in relation to medication, previous medical conditions or problems, and the ongoing condition of your scalp and hair.

If you receive goods or services from us under a finance arrangement, we may also collect proof of identity documents from you (such as a copy of a bank statement, payslip or power bill), which we collect on behalf of the finance provider, which includes Certegy Ezi-Pay Pty Ltd.

If you do not provide the necessary personal information, we may not be able to provide you with the goods, services or information that you have requested from us, and the effectiveness of our programs may be effected.

3. How we collect personal information

In the course of providing you with products and services, AHS collects personal information in a variety of ways. Unless it is unreasonable or impracticable to do so, we collect your personal information from you directly, including by using cookies on our websites.

In some cases however, we will collect information about you from a third party, including from our franchisees that operate Advanced Hair Studio retail outlets.

AHS may collect personal information about you:

• are a recipient of our products or services, including through face to face or phone meetings with you, when our third party;
• consultants provide us with information about their assessment of your hair loss, when you complete a Minoxidil request;
• complete a form online, or when you complete any other information sheet or form;
• visit our website, www.advancedhair.com.au (Website) or the AHD Website;
• make an enquiry about our products and/or services, whether in person, by phone, mail, fax, email or mobile app, either directly to us, or through a franchisee;
• become a customer or debtor of AHS;
• ask to be placed on one of our mailing lists;
• acquire goods or services through our Website or the AHD Website or otherwise;
• supply goods or services to us; and
• apply and/or enter into an agreement to become a franchisee of AHS.

When you attend an online consultation with a Doctor or Practitioner through the AHD Website, your treating practitioner will make, hold and maintain your medical records within AHD’s system. Doctors, Practitioners and Pharmacies may also create and hold medical records in their own systems. Any health information held by us will be managed in accordance with the The Health Records Act Victoria (2001) or other relevant State legislation.

We will take reasonable steps to let you know when we have collected your personal information, unless it is obvious from the circumstances that you would know or would expect us to have the information.

4. Sharing of your personal information

As well as our franchisees, we may also disclose your personal information to:

• external providers of services that we may use to operate our business and manage our business systems (for example, this may include file storage service providers, database providers; couriers and/or freight service providers, providers of payment processing and identity verification services and IT technicians who may need access when providing on-site support (although it is our practice for them to work under supervision));
• third party consultants who assist us in assessing hair loss;
• our professional advisors and agents;
• payment systems operators (e.g. merchants receiving card payments);
• Doctors, Practitioners and Pharmacies (including pharmacists and pharmacy staff);
• specific third parties authorised by you to receive information held by us;
• should a Doctor form the professional opinion that a user is at imminent risk of harm, including self-harm, and where it is consistent with his or her professional and ethical obligations to do so, to contact emergency services (such as an Ambulance Service) to request a welfare check or similar intervention; and/or
• other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

If you receive goods or services from us under a finance arrangement, we may also disclose personal information about you to the finance provider, which includes Certegy Ezi-Pay Pty Ltd.

We may disclose your personal information to these third parties so that they can assist us with providing the best possible service to you.

Each company in the AHS group of associated companies may also disclose your personal information to the other companies within the AHS group of associated companies (which are listed above).

Those companies will be permitted to access only the personal information they need to deliver the service to AHS or to you. AHS takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.

Our Website and the ADH Website are primarily hosted in Australia. 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 provision of such information to overseas recipients (such as servers located in the United States of America) and acknowledge that overseas recipients may not be bound by the Privacy Act, and you may not be able seek redress under that Act from them or us.

We will only disclose your personal information overseas (for example, to a third-party service provider or to cloud servers which are based outside of Australia), in accordance with the Australian Privacy Principles (APPs), particularly APP 8. Where we do transfer your personal information to another country, we will ensure that:

• the receiving person or organisation is subject to a binding agreement to protect that information in accordance with Australian standards; or
• the receiving person or organisation is subject to a law or a scheme substantially similar to the APPs, including mechanisms for enforcement; or
• you have provided your prior consent to the disclosure.

Where we do this, we will take reasonable steps to ensure these parties take appropriate measures not to breach the APPs.

The privacy and collection practices of entities to which we disclose personal information are governed by their own privacy policies and collection notices.

Where our Website or the AHD Website contains links to third parties, the collection, use and care of your personal information is governed by that third party’s privacy policy and collection notice.

We will not otherwise disclose information about you unless the disclosure:

• is required or authorised by law; or
• you have consented to our disclosing the information about you.

Privacy Policy

AHS understands that you value your privacy and wish to have your personal information kept secure. For these reasons, we place a high priority on the security of the personal information that we hold. AHS has developed a Privacy Policy to inform you of how we manage your personal information and maintain its integrity and security.

AHS’s Privacy Policy is available for you to access on our Websites and can be accessed at https://www.advancedhair.com.au/privacy-policy .

Our Privacy Policy contains information about how you may access the personal information that we hold about you and seek the correction of such information, if you believe it to be incorrect.

The Privacy Policy also contains information about how you may complain about a breach of the APPs and how we will deal with such a complaint.

5. Contact Us

Our contact details in respect of any issues in relation to privacy are: