Privacy Policy
1. URBAN SMILE’S COMMITMENT TO PRIVACY
1.1. Urban Smile Pty Ltd A.C.N. 652 955 069 and its related entities (Urban Smile, we, our, or us) respects your privacy, and is committed to complying with its obligations contained in the Privacy Act 1988 (Cth) (Act).
1.2. This Privacy Policy sets out what information we collect, how information is collected, used and handled, when information may be disclosed to third parties with your consent, your rights for requesting access to or amending your personal information, as well as how you can provide us with feedback or make a complaint.
1.3. Urban Smile is committed to protecting the privacy of all individuals it deals with, and will treat your personal information confidentially and according to the Act, which include the Australian Privacy Principles (APPs), which set out the ways in which an organisation can collect, use, disclose, store, and provide access to personal information.
1.4. Personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. Personal information also includes sensitive information, which includes information about an individual’s health.
1.5. This Privacy Policy however expressly does not apply to personal and sensitive information of our Australian employees since employee records are exempt from the Act.
2. HOW WE COLLECT YOUR PERSONAL INFORMATION
2.1. Urban Smile will collect your personal information in a fair and lawful manner. Where it is practical to do so, we will collect your personal information directly from you, and only to the extent necessary to provide you with our products or services and carry out our operations. However, sometimes we also collect your personal information from the following mediums:
a. the Urban Smile website (which might include the time and date you accessed it);
b. your dentist, specialists or other health practitioners, but only with your prior written consent;
c. your parent or guardian;
d. our business service providers and contractors.
2.2. Urban Smile may collect personal information from you when:
a. you submit an enquiry or consultation form online via the Urban Smile website;
b. you submit any other information directly via the Urban Smile website;
c. you post to, comment on a post, tag or send a message to the Urban Smile Facebook page;
d. you comment on a post, tag or send a message to the Urban Smile Instagram page, to Linkedin, TikTok or other social media;
e. in performing Urban Smile’s assessment of your enquiry, including any subsequent discussions in any form, whether verbally, in writing, electronically or otherwise;
f. it is administering any of its services;
g. you contact Urban Smile by telephone;
h. you email or send an SMS Urban Smile; or
i. you have contact with Urban Smile in person.
2.3. Urban Smile will collect, use and disclose your personal information only for the particular purpose that you provided it, or for a directly related purpose (see clause 4.3). Urban Smile may otherwise use your personal information where that other use is:
a. required or permitted by law; or
b. with your express or implied consent.
2.4. For completeness, Express consent can be written (e.g. when you sign a form or send us correspondence) or verbal (e.g. when you give us your permission over the phone or in face-to-face conversations). Your consent will be implied when we can reasonably form a conclusion from our pre-established relationship with you that you have given consent by either taking action or deciding not to take action.
3. TYPES OF PERSONAL INFORMATION WE COLLECT
3.1. The kinds of personal information that Urban Smile will collect about you will depend on the type of interaction that we have with you. For example, Urban Smile may collect your personal and sensitive information when you apply to become our patient and use our services, which may include your name and contact details, date of birth and details of previous medical providers. More specifically:
a. Patients, Prospective Patients and the General Public
We may collect your name, address, telephone and email contact details, personal details such as age and gender, dental and medical history, Medicare number, family medical history, health information including x-rays, photos, videos and any dental assessment, health insurance details, employer details (if applicable to an offer) payment details (including credit card and debit card details) as well as any previous dental services and products that you may have received from us or other providers.
b. Business Service Providers and Contractors
In the context of our business relationship, we may collect your name, ABN or ACN, address telephone number and email address.
c. Job Applicants
We may collect your name, telephone and email address, as well as information, references and reports arising out of the assessment of your potential suitability as our employee.
3.2. Urban Smile may also collect your name and contact details which you provide to us, in order to respond to your questions and comments about Urban Smile and its products and services.
3.3. Urban Smile will only collect your personal and sensitive information where you have consented, or otherwise in accordance with the law.
3.4. When Urban Smile collects personal information from you, it will take reasonable steps to ensure that you are made aware of the details of the collection (including the purposes for which the information was collected and the organisations to which the information will be disclosed) and the fact that this Privacy Policy contains details on how you may access or correct your information and how to raise any complaints.
3.5. Personal information that Urban Smile collects is held in different formats, including in both hard copy and electronically.
3.6. If Urban Smile receives personal information about you that it has not requested, and Urban Smile would not be able to collect this information under the APPs if it had requested it, then Urban Smile will destroy or de-identify the information where lawful and reasonable to do so.
3.7. You are not required to disclose your personal information to Urban Smile, however, if you do not do so, we may not be able to provide you with the services that you have requested, or provide you with an appropriate response to your enquiries.
4. USE AND SHARING OF YOUR PERSONAL INFORMATION
4.1. The way in which Urban Smile will use and disclose your personal information depends on the reasons for which it was collected.
4.2. Urban Smile will only use or disclose your personal information for the main reason for which it was collected (such as to provide you with products or services, or to respond to your enquiry), for a directly related purpose, or otherwise where you have consented to such use or disclosure or the use or disclosure is in accordance with the law.
4.3. Some of the specific instances where Urban Smile will collect, use and disclose your information is to:
a. assess and review your employment enquiry;
b. provide you with marketing and promotional material regarding dental and orthodontic opportunities and information concerning the dental and orthodontics industry;
c. undertake research (i.e. market research or dental and orthodontic services and products research, the results of which may be published and in study groups or at seminars and lectures as this may benefit other patients (in which case your personal identity will not be disclosed, except with your prior consent));
d. provide you with any of our products and services;
e. manage and administer our products and services;
f. carry out internal functions such as administration; accounting, quality insurance and information technology including any practice management software;
g. add you to our mailing list where you have subscribed to our edm; and
h. investigate your feedback regarding our products and services including resolving complaints.
4.4. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Policy.
4.5. In order to allow us to manage and administer services and products to you and to operate an efficient and sustainable business, we may be required to disclose your information to third parties. This may include disclosure in the following circumstances:
a. to your nominated relatives in an emergency;
b. to government and regulatory bodies;
c. to auditors and other service providers we may appoint to ensure the integrity of our operations and services;
d. to any person or entity acting on our behalf;
e. to specialists and other healthcare professionals, for the purpose of seeking a second opinion or a referral, where you have consented to us obtaining the second opinion or the referral;
f. to third party health benefit providers and insurance companies (contact information only) to assist in the processing of a claim for reimbursement or payment of all or part of the cost of dental treatment submitted by You or on Your behalf;
g. to third party suppliers such as dental applications or platforms;
h. to carry out a review of the studio for the purposes of improving the quality of care provided; or
i. where disclosure is required by law, for example, compulsory notices from courts of law, tribunals or government agencies.
5. DIRECT MARKETING
5.1. Urban Smile may, from time to time, use your personal information to provide you with dental and orthodontic updates and information, information about other products and services, details of current promotions and so that it can undertake market research or research into dental and orthodontic services and products. This information may be shared with you using a variety of channels, such as direct mail, email, telephone or SMS. We may also collect and use your demographic and other data for market research, statistical, advertising and promotional purposes via third party providers or otherwise.
5.2. We may share your personal information on a confidential basis with our related entities, related bodies corporate and third parties engaged by us so that they can offer you products and services and fulfil offers to you. When you become our Patient, you consent to us using your personal information for direct marketing purposes (as described in this document), unless you have contacted us to withdraw your consent. If you do not wish to receive marketing material from us, you can contact us at any time to let us know. Our contact details are set out below.
5.3. Urban Smile will only provide you with such communications in accordance with the law. If you do not wish to receive these communications from Urban Smile, please email us at hello@urbansmile.com.au.
5.4. If you request not to receive marketing material, please note that we will still contact you in relation to our on-going relationship with you. For example, we will still send you any bills, statements and notices that are relevant to the products and services you have purchased from us.
6. DISCLOSURE AND STORAGE OF YOUR PERSONAL INFORMATION
6.1. In the course of our day-to-day business activities and those of our related entities, affiliates and service providers, your personal information, photographs and x-rays (including sensitive information), may be transferred, accessed, processed and/or stored both in and outside of Australia. This includes but is not limited to any data hosting and other service providers.
6.2. We will take all reasonable steps to ensure transferred information is kept secure in accordance with the Act. By submitting your personal information to us you agree that you do not object to any such transfer, processing or storage. If we merge, combine or sell a part of our business, we may also pass on your details to our new colleagues and any entity through which they operate unless prohibited from doing so by law. This information may also be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.
7. ANONYMITY AND USING A PSEUDONM
Where lawful and practicable, you have the option of dealing with Urban Smile anonymously or by using a pseudonym, including through our website and social media pages. However, Urban Smile will generally require your contact details if you would like us to transact with you.
8. SECURITY OF YOUR PERSONAL INFORMATION
8.1. Urban Smile will take all reasonable steps to ensure that your personal information is protected against misuse, interference and loss, and unauthorised access, modification or disclosure.
8.2. When your personal information is no longer needed for the purposes for which Urban Smile is authorised to use or disclose it, we will take reasonable steps to destroy the information or ensure it is de-identified unless such information is required to be retained by law.
9. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
9.1. You have the right to request access to the personal information you provide, and to correct or update your personal information. This right is subject to certain exceptions allowed by law.
9.2. To obtain access to your personal information:
a. you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
b. you will need to be reasonably specific about the information you require; and
c. Urban Smile may charge you a reasonable administration fee, which reflects the cost to us for providing access in accordance with your request.
9.3. In certain circumstances, Urban Smile may refuse to allow you access to your personal information where this is authorised by the law, such as where giving access would have an unreasonable impact on the privacy of others, or where providing you with access would be unlawful.
9.4. Urban Smile takes all reasonable steps to ensure that the personal information it collects, uses and discloses is accurate, up-to-date and complete, relevant and not misleading. If you believe that the personal information we hold about you requires correction, you may request that the information be corrected by contacting us using the details in this Privacy Policy. Where Urban Smile corrects your personal information, it will also take reasonable steps to notify third parties that have previously been disclosed your information of the correction.
9.5. If Urban Smile refuses your request for access or correction, it will provide you with written reasons for the refusal, and how you may complain about the decision.
9.6. Furthermore, you may instruct us to remove any previous consent you may have provided to receive marketing communications from Urban Smile or to remove you from its database.
10. ONLINE VISITORS AND COOKIES
10.1. Urban Smile may collect your personal information through its website www.urbansmile.com.au, such as your email address and contact details when you submit an online enquiry. Urban Smile will handle such information in accordance with this Privacy Policy and the law.
10.2. Urban Smile will also collect site usage data through its use of internet cookie technology or similar devices. Cookies are small data files which record your visit and may collect statistical information about your visit (such as the pages you visit on our website) in order to customise and improve your website experience. Most internet browsers will accept cookies automatically, but you can delete or disable cookies by changing your browser settings, however some parts of our site may not work properly if you do. This information may be analysed to provide us with insights into users interests and behaviour, and may include the use of websites using a range of common technical tools, including cookies, pixels and transparent GIF files.
10.3. For completeness, a cookie is a small file of letters and numbers that is put on your computer if your browser settings allow this. These cookies allow our service provider to distinguish you from other users of the website which helps them to provide you with a good experience when you browse our websites, and also allows us to improve our site.
10.4. For completeness, the third-party analytics services applied to our website also track a user’s online activities across unrelated websites and allows for customised presentation of advertising material to your browser (using adware). We do not receive reports that identify you, however the providers of the analytic services may be able to identify users from your IP address, and may use this personal information about your internet use for their own purposes or those of other Patients.
10.5. Furthermore, our webpages may contain links to other third-party sites. Whilst we take reasonable steps to ensure this is always clear, we do not take responsibility for any collection or use of personal information if you choose to click on these links, and you should refer to the privacy policies of the relevant third party in this regard.
10.6. Our websites use industry standard tools to safeguard any personal information. There are however inherent risks in transmitting personal information over the Internet, and neither Urban Smile nor its service providers can guarantee the security of information you choose to provide through our websites.
11. YOUR ACKNOWLEDGEMENT OF URBAN SMILE’S PRIVACY POLICY
11.1. This Privacy Policy meets Urban Smile’s obligations under the APP’s which requires us to set out our policies on the management of personal information in a clearly expressed document which is available to anyone that asks for it.
11.2. Without limiting the generality of the above statement, your access to this communication constitutes an acknowledgement that you have been made aware of Urban Smile’s Privacy Policy.
11.3. This policy does not create or confer upon any individual any rights or impose upon Urban Smile any rights or obligations outside of, or in addition to, those imposed by the Act.
12. CONTACT DETAILS AND COMPLAINT HANDLING
12.1. Urban Smile is committed to working with its patients and members of the public to obtain a fair resolution of any complaint or concern about privacy. To contact us with a query, compliment or complaint, please provide our Privacy Officer with the full details of your complaint and any supporting documentation, using the following contact information:
a. Telephone: (03) 9123 1940
b. Address: Urban Smile
Attn: Privacy Officer
747 Glenferrie Road
HAWTHORN VIC 3122
12.2. Upon receipt of your query, compliment or complaint, our Privacy Officer will endeavour to:
a. provide an initial response to you within 10 business days;
b. investigate and attempt to resolve your query or complaint within 30 business days or such longer period as is necessary and notified to you by our Privacy Officer.
12.3. In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner.
13. POLICY UPDATE
13.1. Urban Smile reserves the right to amend this Privacy Policy at any time, and any amended Privacy Policy is effective upon posting to the Urban Smile website.
13.2. Urban Smile will make every effort to communicate any significant changes to you via email, however your continued use of the Urban Smile website, and acceptance of Urban Smile’s products and services, will be deemed acceptance of any amended Privacy Policy.
This Privacy Policy was last updated in August 2024.