RATIONALE Skincare Pty Ltd ABN 54 070 218 012 and its related corporations (RATIONALE, we, us or our) respects your privacy and we are committed to handling your personal information in accordance with our obligations with the Australian Privacy Principles under the Privacy Act 1988 (Cth) (‘Privacy Act’) and other relevant laws, including where applicable the Singapore Personal Data Protection Act (No 26 of 2012) (‘Singapore PDPA’), the Personal Data (Privacy) Ordinance of Hong Kong, the UK Data Protection Act 2018, General Data Protection Regulation (‘GDPR’), The California Consumer Privacy Act of 2018 ('CCPA') and the US Privacy Act of 1974.
1. THE PERSONAL INFORMATION THAT WE COLLECT
The types of personal information that we collect and hold about you could include:
· your ID and contact information, such as your name, postal or email address, telephone numbers and date of birth
· your social media handles;
· billing information, such as your credit card number and bank account details;
· information about your communications and interactions with us, including about the products and services that you have purchased from us, orders you have placed on the RATIONALE website or any purchases you have made in one of our store locations (‘Flagships’);
· information relevant to your skin care, including skin type, images of your face and skin, skin sensitivity, the colour of your skin, eyes and hair, lifestyle information (e.g. smoking and use of solariums) and family history; and
· other information that we consider is reasonably necessary to perform our business functions or activities.
Sometimes we also collect sensitive information about you in order to provide certain products and services. This information includes information about your ethnic heritage and health information such as information about your health conditions, DNA cheek swab tests and the results of such tests, skin treatments and medications. Unless we are otherwise authorised by law, we only collect sensitive information with your consent, such as when you are completing a treatment consent form in one of our Flagships.
2. HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect personal information about you via a variety of ways, this includes when you fill out a form with us, when you visit or submit information through our website, when you purchase a product or service from us or one of our stockists, if you apply for a job with us, including any information that you may provide during the recruitment process and from publicly available sources (such as social media channels).
If you provide incomplete or inaccurate information or do not want to provide your personal information to us, we may not be able to provide you with the product or service that you want, or, personalise your experience with us.
3. WHY WE HANDLE YOUR PERSONAL INFORMATION
We collect, store, use, disclose and/or process personal information for purposes including to provide, review and improve our products and services, understand your preferences and needs, communicate with you, customise your experience with us (including on our website and social media channels), maintain and update our records and facilitate our business operations (including any sale or potential sale of our business) and if you have applied for a job with us, to consider your employment application and manage the recruitment process.
The types of third parties with which we share personal information include our agents, related companies, RATIONALE group companies, business partners, suppliers and third party service providers such as providers of website services, delivery, payment, data management, legal, accounting and insurance services.
Subject to first obtaining your consent, we also exchange sensitive information, in particular relating to DNA cheek swab tests, with our third party service provider SkinDNA as part of providing the RATIONALE Platinum Consultation, The Platinum Experience and The Platinum Facial in our Flagships.
Some of the third parties we disclose personal information to may be located in USA, Denmark and other countries.
RATIONALE partners with Rakuten Advertising, who may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalisation of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use, and sale of your personal information and your rights, please use the below links here: https://rakutenadvertising.com/legal-notices/services-privacy-policy/ and here: https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/.
You may withdraw your consent by contacting us at the details below.
4. QUALITY OF YOUR PERSONAL INFORMATION
We aim to ensure that your personal information is accurate, complete and up to date. If you believe that the information we have about you is not accurate, complete or up-to-date, please contact us at the details below and we will use all reasonable efforts to correct the information.
5. HOW WE KEEP YOUR INFORMATION SECURE
We take the protection of the information that you provide to us seriously and have implemented a range of measures designed to protect your personal information from loss, misuse and interference, from unauthorised access, collection, use, copying, disposal, modification or disclosure, and from similar risks and from the loss of any storage medium or device on which personal information is stored. Depending on the circumstances, those measures include electronic access controls, premises security and network firewalls.
We hold personal information electronically and in hard copy form, both at our own premises and with the assistance of our service providers.
6. RETENTION OF YOUR PERSONAL INFORMATION
We will retain any personal information for as long as is reasonably necessary, having regard to the purpose for which it was obtained and other permitted purposes. Our data retention period will be determined by a number of factors, including your interactions with us and any legal or applicable tax obligations. After this period has expired, we will take appropriate steps in accordance with those legal obligations, to securely destroy or de-identify the information.
7. VISITING OUR WEBSITE
When you visit RATIONALE’s website, we may collect information such as your IP address, the date and time of your visit, the number of pages that you viewed, navigation patterns, what country you visited from, what system you used to access the website, and, when entering our website from an external website, the address of that website through the use of 'cookies'. This information on its own does not identify an individual but it does provide RATIONALE with statistics that we can use to analyse and improve our website.
A 'cookie' is a packet of information that allows the server (the computer that houses the website) to identify and interact more effectively with your computer. When you use our website, we send you a temporary cookie that gives you a unique identification number. A different identification number is sent each time you use our website. Cookies do not identify individual users, although they do identify a user's browser type and your Internet Service Provider (ISP).
You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Please refer to your browser instructions or help screens to learn more about these functions. Our order entry system does require cookies during the order entry process; however, it does not use the information once the order is complete. At the end of your interaction with our website, you can have your computer ensure that the cookie is deleted. This means it no longer exists on your computer and can’t be used for further identification or access to your computer.
Online service providers
8. HOW WE MARKET OUR PRODUCT AND SERVICES TO YOU
You may be a subscriber to our newsletters and we may send you information on promotions, product updates and general RATIONALE news. If you decide you no longer wish to receive communication from us, you can opt-out of receiving them by following the instructions included in every newsletter or communication, by unchecking the newsletter subscription box in your RATIONALE online account, or by contacting customer service at firstname.lastname@example.org or writing to us at the address below:
PO Box 188
Clifton Hill 3068
9. ADDITIONAL INFORMATION FOR EMPLOYEES AND JOB APPLICANTS
If you apply for a position with us, we may also collect the information necessary to manage and consider your application including your resume, employment history, qualifications, experience, screening checks (including references and police or other background checks) and interview notes.
We collect, use and disclose your personal information to assess your job application, conduct screening checks and consider and contact you regarding other positions. We may exchange your personal information with academic institutions, recruiters, screening check providers, professional and trade associations, law enforcement agencies, referees and your current and previous employers. Without your personal information we may not be able to progress considering you for positions with us.
This section applies to our current and former employees and contractors in addition to the job applicants’ section above.
We may collect information relating to your current or former employment or engagement including information about your training, disciplining, resignation, termination, terms and conditions, emergency contact details, performance, conduct, use of our IT resources, payroll matters, union or professional/trade association membership, recreation, leave and taxation, banking or superannuation affairs. We are required or authorised to collect your personal information under various laws including the Fair Work Act, Superannuation Guarantee (Administration) Act and Taxation Administration Act.
We collect, use and disclose your personal information for purposes relating to your employment or engagement with us including engagement, training, disciplining, payroll, superannuation/pension or applicable funds, health and safety, administration, insurance and staff management purposes. We may exchange your personal information with your representatives (including unions) and our service providers including providers of payroll, banking, staff benefits, surveillance and training services. Without your personal information we may not be able to effectively manage your employment or engagement.
11. HOW CAN YOU ACCESS AND CORRECT YOUR PERSONAL INFORMATION?
At your request, we will provide you with access to your personal information that we hold, and the ability to update, correct or delete it, unless there is a legal basis not to, in which case we will let you know. Such requests can be made by contacting us at the details provided below. Please provide as much detail as you can about the particular information you are enquiring about, in order to help us locate it. We may need to verify your identity.
12. RESOLVING YOUR PRIVACY REQUESTS AND COMPLAINTS
Att: Privacy Officer
PO Box 188
Clifton Hill 3068
13. MORE INFORMATION ABOUT PRIVACY
If you would like further information regarding privacy issues generally, visit the:
Australia: Office of the Australian Information Commissioner’s website at www.oaic.gov.au.
Singapore: Personal Data Protection Commission's website at https://www.pdpc.gov.sg/.