Smilo.ai Privacy Policy

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This Privacy Policy sets out how and why we collect your Personal Information, how we store, use and disclose your Personal Information, and how to contact us if you have any questions about how we handle your Personal Information or would like to access the Personal Information we hold about you.

We comply with the Privacy Act 1988 (Cth) ("Privacy Act") and the applicable Australian Privacy Principles under that Act in Australia, and any other applicable privacy laws when handling Personal Information. We take the protection of your Personal Information seriously and we have put measures in place to maintain the integrity of your Personal Information and provide full transparency and accountability of our conduct.

We provide a range of services relating to oral health and provide these primarily through our Technology. We are constantly evolving our services, and new services may be offered from time to time.

In this Privacy Policy:

What is Personal Information?

Personal Information has the meaning given to that term in the Privacy Act as updated or amended from time to time, which is accessible here. At the time of publishing this Privacy Policy the Privacy Act defines Personal Information as meaning any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

Health Information has the meaning given to that term in the Privacy Act as updated or amended from time to time, which is accessible here. At the time of publishing this Privacy Policy the Privacy Act defines Health Information as a subset of Personal Information. It includes information or an opinion about a person's health, including an illness, disability or injury, expressed wishes about their future health care and about a health service which has been or will be provided to them. Health Information also includes genetic information about a person in a form that can predict their health or that of their genetic relative.

Sensitive Information has the meaning given to that term in the Privacy Act as updated or amended from time to time, which is accessible here. At the time of publishing this Privacy Policy the Privacy Act defines Sensitive Information as a subset of Personal Information. It includes information or an opinion about a person's racial or ethnic origin; political opinions; membership of political or professional groups or trade associations or unions; religious or philosophical beliefs or affiliations; sexual orientation or practices; and criminal record. Sensitive Information also includes Health Information and information to be used for biometric identification.

What types of Personal Information do we collect?

Visitors to our website

Examples of Personal Information we may collect include people's names, dates of birth, their source of inquiry, contact details (e.g. telephone number, email address and home/postal address), health aids and services required, body height and weight, languages spoken and financial details for payment for services. We also collect Survey information which includes, but is not limited to, details of general health, oral health, symptoms, recent treatment and any future treatment you believe you may require

Names and contact details may also be collected from industry related contacts.

By using our health and wellness-focussed Technology, you consent to us collecting Personal Information, Health Information and Sensitive Information including photographic, videographic, radiographic and other images, and written information about your oral and general health and circumstances.

Health Information and Sensitive Information is only ever used for the purpose it was collected, which may necessarily include disclosure to our technology partners for the purpose of Technology development; disclosure to our dental and other health professional partners for the purpose clinical professional development; and disclosure to entities which will provide you with health services to ensure the most appropriate services are offered to you. We will require those individuals or entities to agree that they will only use that information strictly for the purpose for which it has been disclosed to them.

How do we collect and hold Personal Information?

Users of our Technology

If you visit our Technology, our technology service provider may record certain information about your visit, which may include but is not limited to:

The Technical Information is aggregated for analysis as de-identified data.

If you register for an account with us we collect identifying Personal Information, including:

To fully interact with the Technology we will request that you disclose to us Personal Information, including Health Information and Sensitive Information, including:

We collect the Technical Information and Demographic Data to:

We collect the Oral Health Data to:

When you use the Technology, we may collect the Images via:

We obtain only the specific Images selected by you for use with the Technology even if you grant us access to your whole photo album.

Please note that while we do not require or request any metadata to be attached to the Images provided by you, metadata (including, for example, geotags) may be associated these images by default.

We use pixels, or transparent GIF files, in the Technology to help manage online advertising and email marketing. These files enable our service providers to recognise a unique cookie in your web browser, which in turn enables us and our service providers to learn which advertisements and emails brought you to the Technology, and how you use the Technology. GIF files are used to:

If we offer the functionality, and if you choose to login to the Technology, or download it, via a third-party platform or social media network (for example, but not limited to, Facebook, Google, Twitter, the Apple App Store and Google Play Store), or otherwise connect your account on the third-party platform or network to the Technology, we may collect information from that platform or network. The information we collect may include, but is not limited to, your social media alias, your name and, depending on your settings for the third-party platform or network, a list of your friends or connections (though we do not use, store or disclose this information). Our collection and processing of the information we obtain from social media platforms is governed by the requirements these social media platforms impose on us in their relevant terms and conditions (including their own privacy policies).

Oral Health Forum

The Technology includes the Oral Health Forum where users may ask general oral health questions or describe their own symptoms and receive answers from the administrators of the Technology or associated Dental Health Practitioners. Any posts uploaded by an individual user, and the answers to those posts from the administrators, will be displayed on the Technology for other users to see, including the name of the user and their profile picture if they have chosen to upload one to their profile.

Apple Vision Framework

For users of Apple devices, the Technology uses the Apple Vision Framework each time you choose to take an image from the camera of your smart device. While the Technology allows you to store and share your image, the Technology does not collect, store or share any Vision Framework data during this process.

However, to ensure the continued improvement and reliability of the Technology, we use the Apple Vision Framework to collect information from the debug log, including:

We will not disclose this information to any third party, other than our Technology developers who are bound by confidentiality obligations and this Privacy Policy.

Dental Health Practitioners

We collect a range of information from dental health practitioners registered with our Technology, which may include:

We collect the Dental Health Practitioner Data to refer users for oral and dental health services.

Use of Personal Information

The purposes for which we collect, hold, use and disclose Personal Information include:

Disclosure of Personal Information

In the course of our business, we may disclose Personal Information to:

We also engage third party providers to manage our advertising on other websites. These providers use cookies and other methods to collect information about your activities on the Technology to serve you with advertisements regarding our products and services, and to help determine the effectiveness of our promotional or advertising campaigns. This type of online, targeted advertising – known as “retargeting” – is used to re-engage you and other users who previously visited the Technology. You may separately opt-out of some of this online behavioural advertising using the instructions provided through the Technology.

You should be aware that we may disclose your Personal Information through the sale, distribution, subscription or licencing of our Technology to outside entities, including those located overseas. However, we will only ever disclose your Demographic Data in an aggregated and deidentified manner (eg. we may disclose a summary of all of our users by gender, aged group and locations).

You should also be aware that your Oral Health Data may become part of the Technology to increase the effectiveness of the Technology. Therefore, we may disclose your Oral Health Data through the sale, distribution, subscription or licencing of the Technology to third parties.

Where your Oral Health Data becomes part of the Technology and includes Images, we will make reasonable efforts to crop, blur, distort or otherwise deidentify any parts of the Images which identify you as a person and which are not required for recognising dental and oral health issues. Images in this form may be visible to other users of the Technology, including members of the general public.

Where your Oral Health Data becomes part of the Technology and includes information about your oral or general health issues and responses to surveys, this will only be disclosed after it has been aggregated and deidentified.

Also, the Personal Information of a user is only ever stored on servers in the country of residence as advised by the user to us.

If you are a Dental Health Practitioner who has provided your details for the purposes of receiving referrals, we will make the information you provide publicly available including on the Technology.

Dental Health Practitioner Information Sharing

If you consent within the Technology and request us to do so, we will share you Personal Information stored on the Technology to your Dental Health Practitioner if they are also a user of the Technology. We will only share your Personal Information in this manner with your request and consent but in requesting us to do this you acknowledge that your Dental Health Practitioner will then be able to collect and hold your Personal Information on their systems which are subject to different privacy policies and security systems to that used in the Technology.

Direct marketing

You consent to us using your Personal Information to send direct marketing material in relation to our products or services, Associates' products or services, or the products or services of third parties.

You also consent to us disclosing your Personal Information to Associates, our partners, co-publishers, our sponsors and other third parties, in order to facilitate direct marketing by those parties.

If you do not wish to receive marketing information from us, you may at any time opt-out of receipt of further marketing communications by contacting our Privacy Officer (contact details below). If direct marketing is by email, you may also use the unsubscribe function.

You may contact our Privacy Officer if you do not wish us to disclose your Personal Information to third parties for direct marketing purposes.

Cookies and Other Technologies

Cookies and other technologies may be used by us or by third parties when you visit the Technology. In some cases, we may collect Personal Information from the cookies.

A cookie is a small text file that the Technology may place on your device to store information. We may use persistent cookies (which remain on your device even after you close your browser or application) to store information that may speed up your use of the Technology for any of your future visits. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the Technology. We may also use persistent and session cookies to determine your use of the Technology and its performance. You may refuse to use cookies or other measurement software features by selecting the appropriate settings on your browser or the settings section of your device. However, please note that if you do this, you may not be able to use the full functionality of the Technology.

We may also collect anonymous data (which is not Personal Information) about performance and errors that occur while you use the Technology.

The information collected from cookies and other technologies is used solely for our internal purposes in managing the Technology and improving its functionality and reliability, as well as to assist us to better target advertising, report statistics, analyse trends, administer our services, diagnose any errors so that we can provide you with the best service.

Government related identifiers

We do not use any government related identifiers, such as driver's licence or Medicare numbers. We will not use or disclose any government related identifiers other than in accordance with the Privacy Act, or as otherwise required or authorised by law.

Data integrity and security

We endeavour to ensure that all Personal Information we hold is accurate, complete and up-to-date, however, we rely on the accuracy of the Personal Information provided by you or third parties authorised by you. To assist us with this, you should contact us if any of your Personal Information changes, or if you believe that the Personal Information we have is not accurate or complete.

We take reasonable steps to protect the Personal Information that we hold from misuse, interference or loss and unauthorised access, modification or disclosure. We implement security measures, including IT security procedures such as password protection, network firewalls, encryption, intrusion detection and site monitoring.

If we no longer require Personal Information that we hold (including when we are no longer required by law to keep records relating to you), we will take such steps as are reasonable in the circumstances to destroy the information or ensure that it is de-identified.

Disclosure overseas

As mentioned under Disclosure of Personal Information, we may disclose your Personal Information overseas but this will only be done in the manner described under Disclosure of Personal Information above.

At the time of publication we currently house data on servers located in Australia whose operators are bound by the Privacy Act. Where we disclose your information to third parties through the sale, distribution, subscription or licencing of the Technology, we will require those third parties to first be bound by privacy and confidentiality obligations, which comply with this Privacy Policy.

Access and correction

You can ask us for access to your Personal Information or for us to correct or update your Personal Information by sending a written request to our Privacy Officer at the address below. We do not impose any charges for requests for access, correction or updates but may charge a small fee for providing printed information.

Before correcting or providing access to Personal Information, we will require your identity to be confirmed. While the Privacy Act provides you the option of not identifying yourself or of using a pseudonym, we must confirm your identity before we provide you with access or the ability to correct your Personal Information in order to maintain its security and integrity.

Requests for access or correction may be refused upon the grounds contained in the Privacy Act. Further, in some circumstances, we may not be able to comply with a request that you make in respect of your Personal Information. Reasons for this may include, but are not limited to, a legal requirement for us to retain certain Personal Information. If we refuse to provide access, or to correct Personal Information, we will provide you with reasons for the refusal.

If we do agree to your request for the deletion or de-identification of your Personal Information, we will delete or de-identify that Personal Information but assume that you would prefer us to keep a note of your email address on a confidential register of individuals who do not wish to be contacted to avoid sending you marketing and other information in future. If you would prefer us not to do this, you may direct us not to keep this information at any time but will need to acknowledge that we may market to you if you disclose, or consent to the disclosure of, your Personal Information to us in a separate and future manner.

Complaints

Privacy related complaints should be directed to our Privacy Officer in writing at the email or postal address shown below. No charge will be imposed for making a complaint, or for dealing with the complaint. Once a complaint has been lodged, our Privacy Officer will acknowledge its receipt to you as soon as possible and we will endeavour to respond to your complaint as soon as possible.

We will do our best to ensure that our investigation is completed, and a decision on your complaint is communicated to you, within 30 days of our receipt of the written complaint. We will inform you if we need more time

If we are not able to resolve your complaint to your satisfaction you may also contact the Australian Information Commissioner on the following details:

Office of the Australian Information Commissioner GPO Box 5218 SYDNEY NSW 2001 Telephone: 1300 363 992 Website: www.oaic.gov.au

Contact us

If you have any questions about this Privacy Policy or if you wish to request access to your Personal Information, correct or update your details or raise any privacy concerns, please contact us at:

Address: Privacy Officer Address: PO Box 568, Sandgate QLD 4017 Telephone: +61 447 344 323 Email: info@smilo.ai Website: Smilo.ai

Changes to this policy

We may amend this Privacy Policy, in whole or part, in our sole discretion at any time.

This Privacy Policy was last updated in January 2020 and is accurate at the time of publication.