Privacy Policy

Gro International Oceania Pty Ltd ACN 668 651 796, and its subsidiaries and related entities (collectively Gro Clinics, we, us, our), operate an omnichannel hair restoration platform through in-clinic locations (in-clinic) and Prescription Haircare (PHC), an online telehealth service accessible at groclinics.com.au.

We take your privacy seriously. This Privacy Policy explains what personal information we collect across all Gro Clinics services - including in-clinic consultations, e-commerce purchases, and the PHC telehealth subscription service - why we collect it, how we use it, and your rights in relation to it.

We comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). We also comply with applicable state health privacy legislation. Health information you share with us may be subject to mandatory retention obligations under state law even if you ask us to delete it.

1. What Information We Collect

Personal information

We collect personal information including:
• your name, date of birth, and contact details (email, phone, address)
• payment and billing information
• device identifiers, IP address, and usage data when you visit our website
• identity verification information (such as Medicare details, driver's licence, or a photo ID) where required
• employment information, where relevant (e.g. job applications)

Health information

We collect health information about you only with your consent, or as otherwise permitted by law. This includes:
• your medical history and current health conditions
• information about your hair loss history and treatment goals
• consultation notes and treatment plans prepared by your Practitioner
• prescriptions issued to you
• pathology test results and referrals (where applicable in an in-clinic context)
• My Health Record information, where applicable
• any other health information you provide during consultations or intake

Health information is sensitive information under Australian law and is handled with additional care.

Photographs and recordings

Your Practitioner may request photographs of your scalp or hair or of relevant areas to assist with clinical assessment. We recommend covering any identification numbers on any photo ID you provide.

Consultations may be recorded for clinical record-keeping, quality assurance and training purposes. You may notify us at any time if you do not wish to be recorded.

Device and app data

If you use any mobile application or connected device operated by us, we may collect device-related information such as serial number, Bluetooth address, or other device identifiers to provide optimal services.

2. How We Collect Your Information

We collect information directly from you when you:
• visit our website or subscribe to our content
• communicate with us by phone, email, chat, or through our website
• make an inquiry through our website or in-clinic
• book or attend a consultation (telehealth or in-person)
• make a purchase or start/manage a subscription
• complete any intake forms, online surveys, or feedback requests
• participate in any of our services

We may also collect information from:
• your Practitioner following a consultation
• our partner pharmacies (in connection with dispensing your prescription)
• our e-scripting platform (Parchment Health), for PHC subscribers
• our payment processors (HubSpot Payments / Stripe / Shopify)
• our group companies and related entities
• publicly available sources and third parties such as suppliers and business partners
• government sources such as Medicare, My Health Record, or other relevant government authorities

3. Why We Collect and Use Your Information

We use your personal and health information to:
• provide you with in-clinic and/or PHC telehealth services
• connect you with Practitioners (Doctors, Nurse Practitioners, Hair Growth Advisors, and other health professionals)
• transmit your prescription to a partner pharmacy for dispensing (PHC)
• manage your subscription, process payments, and send renewal reminders
• communicate with you about your treatment and any clinical follow-up
• send announcements, updates, and support communications
• send marketing and promotional communications about our services (see Section 6)
• comply with our legal and regulatory obligations
• improve our services
• manage business operations including insurance, legal, and quality assurance
• consider applications for employment, where relevant

4. Who We Share Your Information With

We share your personal information only as necessary and in accordance with this policy. Recipients may include:
• Practitioners (Doctors, Nurse Practitioners, Hair Growth Advisors, and other registered health professionals)
• partner pharmacies, to enable them to dispense your prescription
• e-scripting platforms (Script Pad for in-clinic, Parchment Health for PHC)
• HubSpot, Zenoti, Stripe, and Shopify, for payment processing
• delivery providers, to arrange shipment of medication
• our group companies, contractors and related entities
• government authorities, where required by law or in connection with health service provision
• cloud service providers and IT support providers
• our professional advisors (legal, accounting, insurance)
• emergency services, where a Practitioner forms a professional opinion that you are at risk of imminent harm

We will not sell your personal information to third parties.

5. Overseas Storage

Some of our service providers store data on servers located overseas, including in the United States, Asia, or Europe. We take reasonable steps to ensure your information is protected to a standard consistent with Australian privacy law. By using our services, you consent to your information being stored overseas.

Where it is not possible to ensure equivalent protection, Australian Privacy Principle 8.1 may not apply, and you acknowledge that you may not be able to seek redress under the Privacy Act in relation to an overseas provider's breach.

6. Marketing

With your consent, we may send you marketing communications about our services and promotions via email or SMS.

You can opt out of marketing communications at any time by following the unsubscribe link in any email, or by contacting us at info@groclinics.com.au. Opting out of marketing does not affect your ability to receive service-related communications.

7. Security

We maintain appropriate physical, technical and organisational measures to protect your personal information from unauthorised access, disclosure, alteration or destruction.

Access to your personal information is restricted to staff and contractors who need it to perform their role.

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. Health records are subject to retention obligations under applicable state legislation.

8. Accessing and Correcting Your Information

You have the right to access the personal and health information we hold about you, and to request corrections. To make a request, contact our Privacy Officer at privacy@groclinics.com.au.

We will respond to all access and correction requests within a reasonable timeframe. In rare circumstances where we refuse a request, we will provide you with a written explanation.

9. Cookies

Our website uses cookies to help us understand how visitors use our site and to improve your experience. Cookies identify your device but do not identify you personally. You can manage cookie preferences through your browser settings.

We may use third-party vendors to display ads based on your prior visits to our website. These vendors may use analytics data to inform and optimise advertising campaigns.

10. Contact and Complaints

If you have questions or concerns about this Privacy Policy or how we handle your information, please contact our Privacy Officer:

Privacy Officer
Gro International Oceania Pty Ltd / Gro Clinics
Level 2/14 Edgewater Ct, Robina QLD 4226
Email: privacy@groclinics.com.au

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC):

GPO Box 5218 Sydney NSW 2001
Phone: 1300 363 992 | www.oaic.gov.au

11. Changes to This Policy

We reserve the right to update this Privacy Policy from time to time. An up-to-date copy is available on our website. We encourage you to check periodically.

Last updated: May 2026