Privacy Policy

Gro International Oceania Pty Ltd (ABN 35 668 651 796) (we, us or our) is committed to protecting your privacy. This policy explains how we collect, use and protect your personal information. It applies to all personal information we handle, whether we collect it through our Website, in person, or through other means.

Quick overview

We collect information you provide to us and information we gather when we interact with you
We use this information to provide our services and improve your experience
We protect your information using secure systems and processes
You have rights regarding your personal information, including access and correction rights

1. About Gro Clinics

Gro International Oceania Pty Ltd operates as an omnichannel hair restoration provider through our clinics and online platform at www.groclinics.com.au (Website).

At Gro Clinics, we:

Compile and link information about different aspects relating to hair loss and its impact on people;
Facilitate private consultations between our clients;
Certified Australian medical and health professionals, such as doctors and nurses (Practitioners);
Trained personnel, like Hair Growth Advisors (Personnel); and
Other accredited Australian health service providers, like pathology labs and pharmacies (Partner Providers),

(collectively referred to as Partners or Associates).

This Privacy Policy offers a comprehensive understanding of how we handle your personal data, which refers to any information or opinion about you, whether factual or not, that identifies you or can be used to identify you.

2. Information we collect

Identity and contact details

Name, address, email address and phone number
Professional details

Service related information

Payment and transaction details for products and services you've purchased from us or enquiries about our products and services
Your preferences for our services and your marketing preferences
Feedback and survey responses

Digital information

IP address and general location information derived from your IP address
Search and browsing behaviour
Website usage patterns
Cookie preferences

Recordings

Call recordings
Records of meetings and decisions

Professional information (for job applicants and workers)

Employment history
Professional experience
Required authorisations and licences
Professional registrations
Information about your right to work in the relevant jurisdiction

Sensitive Information

We handle sensitive information with extra care and protection, and we only collect this information with your consent or when legally permitted. This includes:

Health information

Individual or family medical history (to provide healthcare services and support tailored to your needs/ to ensure we can provide safe and appropriate services)
Treatment reports
Medicare details and Medicare number
Individual Healthcare Identifier (IHI) number
My Health Record information (when accessed with your consent)
Prescriptions and medication information
Pathology results and other diagnostic information
Other health or sensitive data necessary for our services

3. How we collect personal information

Directly from you when you: when you interact with us, contact us, fill out forms.
Automatically when you: visit our Website, use our technologies, interact with our online services.
From third parties: service providers, business partners, public sources, government organisations and organisations or people authorised by you.
Government databases: Medicare, My Health Record system, or other relevant government entities connected to our service provision
From publicly available sources: such as ASIC and other regulatory bodies and professional networking sites such as LinkedIn.
Through website and advertising lead forms, including consultation request forms and enquiry forms on our Website or third-party advertising platforms, which may result in phone calls, emails or other client communications.

4. Why we collect, hold, use and disclose personal information

We collect and use your personal information to run our business and provide our services as set out below.

Business operations

To manage our relationship with you as a customer or supplier
To process and deliver our products and services
To handle your inquiries, support requests, and communications
To maintain accurate records for billing and administration
To verify your identity when required or permitted by law

Communication and support

To respond to your questions and support requests
To communicate important updates about our services
To handle inquiries made through our Website or platforms, including those submitted via website and advertising lead forms
To manage your participation in surveys, feedback sessions, or events
To manage enquiries and communications through our customer relationship management (CRM) systems and marketing automation tools

Service improvement

To conduct analytics and market research
To improve our business operations and services
To develop and enhance our applications and platforms
To understand how our services are used

Marketing and promotions

To send you promotional information about our services and events
To inform you about products or services that may interest you
To manage your marketing preferences
To run competitions, promotions, and special offers
To provide additional benefits to our customers
To run and measure the performance of advertising campaigns across platforms such as social media and Google

Employment purposes

To assess employment applications
To evaluate candidate qualifications
To manage professional certifications and licences
To maintain employment records

Legal and compliance

To comply with our legal obligations
To respond to court orders or legal processes
To maintain required business records
To fulfill regulatory requirements or reporting obligations
To protect our legal rights and interests or as authorised by law

Healthcare service provision

To provide our hair restoration and healthcare products and services
To facilitate consultations between you and our Practitioners, Personnel, and Partner Providers
To enable our Associates to assess your health needs and provide appropriate treatment
To process prescriptions and arrange pathology services
To access and update your My Health Record (with your consent)
To coordinate care between different healthcare providers
To ensure safe and appropriate healthcare delivery

5. Our disclosures of personal information to third parties

We may disclose personal information to:

Service providers

IT service providers
Data storage providers
Web hosting and server providers
Payment processors
Marketing and advertising providers, including advertising platforms used to run campaigns and measure performance (such as social media platforms and Google)
Customer relationship management (CRM) and marketing automation providers used to manage enquiries and communications
Analytics providers

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioural metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimisation, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

Professional advisers

Bankers
Auditors
Insurers and insurance brokers
Legal advisers

Business partners

Our existing or potential agents
Our business partners or contractors

Corporate transactions

If we merge with or are acquired by another company, or sell our business assets:

Your information may be disclosed to our advisers
Your information may be disclosed to the potential purchaser's advisers
Your information may be included in the transferred assets

Legal and regulatory bodies

Courts and tribunals
Regulatory authorities including as required for reporting obligations
Law enforcement officers

Healthcare providers and Associates

Practitioners (certified Australian medical and health professionals, such as doctors and nurses)
Personnel (trained personnel, like Hair Growth Advisors)
Partner Providers (accredited Australian health service providers, like pathology labs and pharmacies)
Other healthcare professionals involved in your care

Other parties

Third parties you have authorised
Emergency services when necessary
Any other parties as required or permitted by law

6. Overseas disclosure

Storage and access

We store your personal information in Australia. However, your information may be accessed from or transferred to locations outside Australia in these circumstances:

When our service providers are located overseas
When we work with overseas business partners
When using cloud-based services or data storage solutions

Our approach to overseas disclosure

Before disclosing your personal information overseas, we take reasonable steps to ensure that the recipient treats your information in accordance with applicable law by only sending what is necessary, requiring recipients to protect your information through contractual agreements which require the recipient to comply with the privacy standards in applicable law or through other mechanisms that provide comparable safeguards and by monitoring how recipients handle your information.

7. Your privacy rights and choices

Providing information

You can choose whether to provide personal information to us, however, if you don't provide certain information, we may not be able to provide some services. Let us know if you don't want to provide information and we will let you know when information is required versus optional.

Access to your information

You can request access to the personal information we hold about you and we will respond to your request within a reasonable time. We may charge a reasonable administrative fee for providing access and if we cannot provide access, we will explain why and explore alternative ways to share relevant information.

Correction rights

You can ask us to correct any information that is inaccurate, out of date, incomplete, irrelevant or misleading and we will take reasonable steps to correct your information promptly. If we cannot make the correction, we will explain why and discuss alternatives. You can ask us to add a statement to your information noting your requested correction.

Marketing communications

You can opt-out of receiving marketing communications at any time. Each marketing communication will include an unsubscribe option. You can change your marketing preferences by contacting us. We will process your request as soon as practicable.

How to contact us about your rights or to make a complaint and what happens next

Step 1: Contact our privacy officer

Email: privacy@groclinics.com.au
Post: PO Box H67, Sydney 1215, NSW, AU

What to include:

Your full name, contact details, clear details about your request or complaint, and any relevant dates or reference numbers.

Step 2: Our response

We will:

Verify your identity before processing your request
Investigate thoroughly (for complaints) or process your request (for rights)
Respond to you in writing within reasonable timeframes and as required by law
Explain what actions we will take and keep you updated on progress
Not charge you for making a request (except for reasonable access fees if applicable)
Help you understand and exercise your rights

Step 3: If you're not satisfied (complaints only)

If you're not satisfied with our response to your complaint, you can:

Ask for a review by our senior management, or
Contact external bodies:
Australian residents: Office of the Australian Information Commissioner (Phone: 1300 363 992, Website: www.oaic.gov.au)
New Zealand residents: Office of the New Zealand Privacy Commissioner

This is the same process whether you want to access your information, correct mistakes, change marketing preferences, or make a complaint about our privacy practices.

8. Protecting your information

We use multiple layers of security to protect your information.

Technical safeguards

Enterprise-grade encryption for data storage and transmission
Regular security testing and monitoring
Automated threat detection systems

Operational security

Staff training on security and privacy
Strict access controls based on job requirements
Regular security audits and incident response procedures testing

Physical security

Secure premises with controlled access
Secure disposal of physical documents
Equipment security protocols

Public information

Please note that any information you choose to share publicly on online platforms (such as comments or reviews) can be accessed and used by others. We cannot control or protect information that you make publicly available.

9. How long we keep your information

We keep your personal information only as long as we need it for the purposes we collected it, or as required by law (including healthcare record retention requirements). When we no longer need it, we securely destroy or de-identify it.

10. Cookies and Analytics

What We Use

We use cookies, tracking pixels, and similar technologies on our Website and in our emails to improve your experience and our services.

Cookies

Small text files stored on your device
Help remember your preferences
Enable certain Website functions
Make your interactions with our Website more efficient

Tracking Pixels

Tiny, invisible images in web pages and emails
Help us understand how you interact with our content
Allow us to measure email engagement
Enable more relevant content delivery

How we use these technologies

Essential Functions

Remember your login status
Maintain your session security
Store your preferences
Enable core Website features

Analytics and Performance

Understand how our Website is used
Measure page views and traffic
Analyse user navigation patterns
Identify areas for improvement

Personalisation

Remember your preferences
Tailor content to your interests
Improve your browsing experience
Provide relevant recommendations

Your control

You can manage these technologies by:

Adjusting your browser settings to block or delete cookies
Using privacy-focused browser extensions
Configuring your email client to block images
Using our cookie preference settings

Note: Blocking all cookies may affect Website functionality and your user experience.

Google Analytics

We use Google Analytics to understand how people use our Website. This involves cookies that collect information about your browsing activity. You can opt out of Google's advertising features through your Google account settings, browser add-ons, or your device's privacy settings. Google provides various tools and options to control how your data is used for advertising purposes. You can learn more about how Google uses your data and your available options on Google's privacy pages.

Meta advertising tools

We use Meta's advertising tools (such as Meta Pixel) to understand how our ads perform and to show you more relevant advertisements on Meta platforms like Facebook and Instagram when you visit our Website or app. You can manage whether we connect information from our Website with your Meta account for advertising purposes by adjusting your settings within your Meta account preferences.

Advertising platforms

We use third-party advertising platforms, including social media platforms and Google, to run campaigns and measure their performance. These platforms may collect information about your interactions with our advertisements and Website. You can manage your advertising preferences through the relevant platform's settings.

11. When you sign in with another account (like Facebook or Google)

What we collect

When you use single sign-on to connect with us, we'll receive personal information from that provider based on your privacy settings with them. This may include your name, username, profile picture, and other details you've chosen to share.

How we use it

We use this information to create your profile on our platform and give you access to our services.

Your rights

If you connected through Facebook, you can ask us to delete the personal information we received from Facebook. To do this, email us at our email below and tell us what information you'd like deleted. If we can't delete certain information, we'll explain why.

12. Artificial Intelligence (AI) Technologies

Overview

We use artificial intelligence and machine learning technologies in our business operations and services, including AI tools provided by third parties. We only use these technologies when legally permitted and necessary for our business.

How we use AI

We may use AI technologies to:

Conduct analysis and data processing
Generate and modify content and coding
Improve and optimise our services and operations
Automate routine tasks and communications
Personalise your experience with our services
Support quality assurance processes
Assist with customer support and queries

Data protection and security

When we work with third-party AI providers, we ensure they handle your personal information in accordance with privacy laws through contractual requirements and appropriate safeguards.

Your rights and our commitments

Any information generated or inferred about you by AI technologies is treated as personal information, and you maintain all the rights outlined in this privacy policy. When using AI with your personal information, we commit to:

Transparency and control

We'll inform you when AI is used to make decisions that may significantly affect you
We maintain human oversight and review of significant AI-generated decisions
Our staff are trained to understand AI limitations and verify outputs before relying on them
We implement processes to verify the accuracy of AI-generated outputs

Security

We use appropriate technical and organisational measures to maintain the security and integrity of your personal information
We regularly test and monitor AI outputs for accuracy and reliability

Risk mitigation

We regularly assess and document risks associated with using AI to process personal information
We implement appropriate measures to address these risks
We continuously monitor AI performance and regularly review their impact

13. Amendments

We may update this policy at any time by posting the revised version on our Website. We recommend that you review our Website regularly to stay current with any policy changes.