We respect the privacy of individuals who visit our website, deal with our head office and are customers of our clinics.
Personal information is information about an identified individual or an individual who is reasonably identifiable.
In this Policy, the term “TCC Group” and “we” or “us” refers individually or collectively to
- The Cosmetic Clinic Limited (New Zealand franchisor);
- The Cosmetic Clinic New Zealand Limited (the Country Development Licensee),
- each of The Cosmetic Clinic independently owned and operated clinics in New Zealand,
- the international licensor Australian Skin Clinics Pty Ltd and its associated entities.
“Head Office” means The Cosmetic Clinic Limited or its agent The Cosmetic Clinic New Zealand Limited.
- Persons accessing or using this website;
- Persons providing or submitting personal information to us that is or could identify them;
- Other Persons about whom we collect, hold or store personal information.
Information that is provided to one or more of the TCC Group entities may be shared with, kept, stored and used with any other TCC Group entity for the purposes set out in this policy.
What general personal information might we collect?
Personally identifiable information such as your name, e-mail address, residence address, gender, phone number, date of birth, is collected when sent or provided to us by:
- Members of the public and customers via emails, our website, Facebook or other social media; for example in registering for e-mail communications, making enquiries, participating in promotions and competitions, completing surveys or otherwise submitting information in any format;
- Customers and potential customers visiting or directly contacting clinics in the TCC Group; for example, making enquiries, completing our new customer and consent forms and discussing their requirements; and
- Prospective franchisees when making enquiries about franchising opportunities to the Franchisor or Country Development Licensee; and
- Prospective employees or independent contractors when making enquires or applications to work at a clinic; and
- Anyone else that voluntarily provides us with personal information for any reason.
What additional information might be collected about our customers?
In addition to the above information, we may collect healthcare provider details, subscriber status, and credit card number (when purchasing products or services) take before and after photographs of you, write file notes about your skin, your treatment, medical conditions and your leisure activities. Personal information may also be collected from third parties such as your other health practitioners.
What additional information is collected about potential franchisees and staff?
We may also collect information about your current employment including your position, period of employment, experience, criminal history and credit checks, your IRD number, your financial position including assets, liabilities and funding sources. Personal information may also be collected from third parties such as your bankers, accountant or personal or business referees
Why do we collect personal information and what might we do with it?
- Individual Customers
- Understand individual requirements and provide customers with the appropriate product or service;
- Monitor the progress of our services to you and tailor the services to suit your particular needs;
- Respond to enquiries or requests;
- Manage complaints and disputes and report to dispute resolution bodies;
- Product and Service Development and Improvement
- Set up, administer and manage our products and services;
- Manage, train and develop our employees and representatives in product and service knowledge and delivery;
- Get a better understanding of customers and potential customers, their needs, behaviours and how people interact with us, so we can engage in product and service research, development and manage the delivery of our services and products via the way we communicate with you; and
- Marketing Purposes
- Gather and aggregate information for statistical, reporting and research purposes;
- Contacting you and direct marketing (unless you have opted out)
- For administrative, marketing (including direct marketing), promotional, planning and quality control purposes;
- Compiling and maintaining mailing lists derived from our website, from our clinics or from other entities within the Group and communicating with persons on those lists;
- Assessing a person’s application for employment or a franchise with us;
- As otherwise required or permitted by any law.
Disclosure of your personal information to others:
We may disclose (only as strictly necessary and not in breach of any Medical confidentiality) any of your personal information to and/or collect your personal information from:
- Any entity where disclosure to, or collection from, such entity is required or authorised by law or under a medical or industry code or regulations;
- Data warehouse and data partners;
- Social media and other virtual communities and networks where people create, share or exchange information;
- Publicly available sources of information;
- Member loyalty or rewards programs and other industry relevant organisations;
- A third party that we’ve contracted to provide business, administration or consultancy services – for example: information technology providers, consultancy firms, auditors and business management consultants, sales agents, marketing agencies and other marketing service providers and print/mail/digital service/imaging/document management providers;
- Your and our advisers, agents, representatives or consultants;
- Government, statutory or regulatory bodies and enforcement bodies;
- Any external dispute resolution body;
- Any organisation that assists us to gather or aggregate information for statistical, reporting or research purposes;
- Any organisation or person in connection with the sale of a clinic, its assets or any part or whole of the Group;
- Any other organisation or person, where you’ve asked them to provide your personal information to us or asked us to obtain personal information from them; or
- As required or permitted by any law to enforce compliance with the policies governing medical practices and applicable laws; and
- To protect and enforce the intellectual property and other legal rights of the Group.
- To an appropriate person, authority or organisation where we reasonably believe that a failure to disclose such information places the customer or another person at risk to health or safety.
Email communications and direct marketing
By supplying us with your email address and any other personal information you authorise anyone in the TCC Group or its agents to contact you directly or send you updates and promotional information by email, telephone, social media, SMS or posted mail about the TCC Group, its products and services from time to time.
This may include communication or information from third parties that we have an association with or have entered into joint promotions activities with that are related to the TCC products and services.
You can contact us at any time to update your marketing preferences or elect not to receive any further communication or marketing material from us and we will comply with such a request within a reasonable time frame. If you do not wish to receive new information and marketing material from us, please email us directly at email@example.com.
Access, Storage and transmission of personal information
You have the right to access and seek correction of your personal information held by us at any time. Please send full details of your request to Head Office at firstname.lastname@example.org or the customer service manager at your local clinic.
The TCC Group will take all reasonable steps to protect the security of the personal information transmitted to and from us, and stored by us or by our agents on our behalf including using firewalls, SSL encryption technology and other security technologies as deemed appropriate by us for information in digital format and in a secure manner under the strict control of the clinic treating the customer for hard copy material. In some cases secure servers are owned by third party suppliers and may be located outside New Zealand. Older records may be stored off site at a secure document storage facility. Our staff, agents and suppliers are obliged to respect the confidentiality of personal and/or sensitive information held by us. We will destroy or de-identify personal information we no longer need or that becomes obsolete, or as requested by that person wherever possible
You acknowledge that any transmission of data by email, hard copy mail or any other method may be illegally intercepted and used by third parties. We shall not be responsible or liable to any person for any interception or loss or unauthorised use of data transmitted to or from us or for any breach or lapse of security of our information storage or processing systems caused by factors outside our control.
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. If you follow a link or click through to third party website you do so at your own risk.
How to make a complaint
All such enquiries or complaints will be taken seriously and handled with impartiality and discretion. If you wish to submit a complaint, please provide us with all relevant details such as the date and time of the incident or communication, the circumstances surrounding the event and your concerns about what was said or done. Once you have submitted your complaint, we will assess it to determine whether or not you have complained about a privacy issue which is covered by the Privacy Laws. If your complaint is covered by the Privacy Laws, we will thoroughly investigate all aspects of your complaint including ascertaining the relevant facts and what your expectations are for any resolution. During our investigation we may need to seek further information from you as to the nature of or factual circumstances surrounding your complaint.
We will endeavour to respond to you at all times promptly and to offer a practical solution which is consistent with our legal obligations.