RATIONALE Skincare Pty Ltd ABN 54 070 218 012 and its related corporations (RATIONALE, we, us or our) respects your privacy and we are committed to handling your personal information in accordance with our obligations with the Australian Privacy Principles under the Privacy Act 1988 (Cth) (‘Privacy Act’) and other relevant laws, including where applicable the Singapore Personal Data Protection Act (No 26 of 2012) (‘Singapore PDPA’), the Personal Data (Privacy) Ordinance of Hong Kong, the UK Data Protection Act 2018, General Data Protection Regulation (‘GDPR’), The California Consumer Privacy Act of 2018 ('CCPA') and the US Privacy Act of 1974.

This Privacy Policy applies to the RATIONALE products, services and website(s) that we provide to you and if you work for us or apply for an employment position with us (see section 9 below), and explains how we handle your personal information. By interacting with us, submitting information to us (including on or through our website(s)), using our website(s), or signing up for any products and/or services offered by us, you agree and consent to us, as well as our respective representatives and/or agents, collecting, using, disclosing and sharing amongst themselves your personal information, and disclosing such personal information to our business partners, authorised service providers, vendors, sub-contractors and relevant third parties in the manner and for any of the purposes set forth in this Privacy Policy. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as may be updated from time to time on our website.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your personal information, and your consents herein are cumulative and additional to any rights which we may have at law to collect, use, disclose and/or process your personal information. This Privacy Policy does not affect any rights which we may have at law in connection with the collection, use, disclosure and/or processing of your personal information.

1. THE PERSONAL INFORMATION THAT WE COLLECT

Interpretation

As used in this Privacy Policy, 'personal information' means all data that falls within the definition of personal information, personal data, personally identifiable information, health information or similar language under the any applicable law relating to the protection, privacy and security, collection, use, disclosure and/or processing of sensitive or other personally identifiable information.  

General information  

The types of personal information that we collect and hold about you could include:

·       your ID and contact information, such as your name, postal or email address, telephone numbers and date of birth

·       your social media handles; 

·       billing information, such as your credit card number and bank account details;

·       information about your communications and interactions with us, including about the products and services that you have purchased from us, orders you have placed on the RATIONALE website or any purchases you have made in one of our store locations (‘Flagships’);

·       information relevant to your skin care, including skin type, images of your face and skin, skin sensitivity, the colour of your skin, eyes and hair, lifestyle information (e.g. smoking and use of solariums) and family history; and

·       other information that we consider is reasonably necessary to perform our business functions or activities. 

Personal information  

Sometimes we also collect sensitive information about you in order to provide certain products and services. This information includes information about your ethnic heritage and health information such as information about your health conditions, DNA cheek swab tests and the results of such tests, skin treatments and medications. Unless we are otherwise authorised by law, we only collect sensitive information with your consent, such as when you are completing a treatment consent form in one of our Flagships.   

2. HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information about you via a variety of ways, this includes when you fill out a form with us, when you visit or submit information through our website, when you purchase a product or service from us or one of our stockists, if you apply for a job with us, including any information that you may provide during the recruitment process and from publicly available sources (such as social media channels).

If you provide incomplete or inaccurate information or do not want to provide your personal information to us, we may not be able to provide you with the product or service that you want, or, personalise your experience with us. 

3. WHY WE HANDLE YOUR PERSONAL INFORMATION

We collect, store, use, disclose and/or process personal information for purposes including to provide, review and improve our products and services, understand your preferences and needs, communicate with you, customise your experience with us (including on our website and social media channels), maintain and update our records and facilitate our business operations (including any sale or potential sale of our business) and if you have applied for a job with us, to consider your employment application and manage the recruitment process.  

The types of third parties with which we share personal information include our agents, related companies, RATIONALE group companies, business partners, suppliers and third party service providers such as providers of website services, delivery, payment, data management, legal, accounting and insurance services.

Subject to first obtaining your consent, we also exchange sensitive information, in particular relating to DNA cheek swab tests, with our third party service provider SkinDNA as part of providing the RATIONALE Platinum Consultation, The Platinum Experience and The Platinum Facial in our Flagships.   

Some of the third parties we disclose personal information to may be located in USA, Denmark and other countries.

RATIONALE partners with Rakuten Advertising, who may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalisation of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use, and sale of your personal information and your rights, please use the below links here: https://rakutenadvertising.com/legal-notices/services-privacy-policy/ and here: https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/.

You may withdraw your consent by contacting us at the details below.

4. QUALITY OF YOUR PERSONAL INFORMATION

We aim to ensure that your personal information is accurate, complete and up to date. If you believe that the information we have about you is not accurate, complete or up-to-date, please contact us at the details below and we will use all reasonable efforts to correct the information. 

5. HOW WE KEEP YOUR INFORMATION SECURE

We take the protection of the information that you provide to us seriously and have implemented a range of measures designed to protect your personal information from loss, misuse and interference, from unauthorised access, collection, use, copying, disposal, modification or disclosure, and from similar risks and from the loss of any storage medium or device on which personal information is stored. Depending on the circumstances, those measures include electronic access controls, premises security and network firewalls.  

We hold personal information electronically and in hard copy form, both at our own premises and with the assistance of our service providers.  

6.  RETENTION OF YOUR PERSONAL INFORMATION

We will retain any personal information for as long as is reasonably necessary, having regard to the purpose for which it was obtained and other permitted purposes.  Our data retention period will be determined by a number of factors, including your interactions with us and any legal or applicable tax obligations. After this period has expired, we will take appropriate steps in accordance with those legal obligations, to securely destroy or de-identify the information. 

7. VISITING OUR WEBSITE 

Cookies 

When you visit RATIONALE’s website, we may collect information such as your IP address, the date and time of your visit, the number of pages that you viewed, navigation patterns, what country you visited from, what system you used to access the website, and, when entering our website from an external website, the address of that website through the use of 'cookies'. This information on its own does not identify an individual but it does provide RATIONALE with statistics that we can use to analyse and improve our website.   

A 'cookie' is a packet of information that allows the server (the computer that houses the website) to identify and interact more effectively with your computer. When you use our website, we send you a temporary cookie that gives you a unique identification number. A different identification number is sent each time you use our website. Cookies do not identify individual users, although they do identify a user's browser type and your Internet Service Provider (ISP).   

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Please refer to your browser instructions or help screens to learn more about these functions. Our order entry system does require cookies during the order entry process; however, it does not use the information once the order is complete. At the end of your interaction with our website, you can have your computer ensure that the cookie is deleted. This means it no longer exists on your computer and can’t be used for further identification or access to your computer. 

Online service providers  

We also use third parties for the provision of online services such as personalised advertising and website analytics, to collect anonymous internet usage data and for social media engagement. These third parties may use cookies and other tracking technologies, such as web beacons on our website in connection with the online services that they provide. For example, with personalised advertising, we can customise the delivery and content of our ads on third party websites and online services for people who have previously visited our websites (this is also known as remarketing) so that we can serve advertisements and content that we think may be of relevance to you. Advertisements or content may also be targeted to users based on location (identified via an IP address), gender, age and interests. No personal information will be collected on these occasions. These third parties may also transfer this information to other parties including where they are required to do so by law, or where such other parties process the information on their behalf. 

We may use Google services such as Google Analytics and Google Ads from time to time to provide the services set out above. For more information about how Google collects and processes data, including information on how to opt-out of certain conduct, please see Google’s privacy policy and their information at www.google.com/policies/privacy/partners/. There are also opt-out facilities which cover multiple online services, such as http://www.youronlinechoices.com.au/opt-out-help/.   

If you visit our website via an external website, or click on a link on the RATIONALE website to other websites, please be aware that we are not responsible for the privacy practices of these other websites. This Privacy Policy applies only to personal information that we collect from you as set out here. We encourage you to be aware of the privacy practices and privacy policies of these third party websites. 

8. HOW WE MARKET OUR PRODUCT AND SERVICES TO YOU 

You may be a subscriber to our newsletters and we may send you information on promotions, product updates and general RATIONALE news. If you decide you no longer wish to receive communication from us, you can opt-out of receiving them by following the instructions included in every newsletter or communication, by unchecking the newsletter subscription box in your RATIONALE online account, or by contacting customer service at consultant@rationale.com or writing to us at the address below:

RATIONALE  

Privacy Officer

PO Box 188

Clifton Hill 3068

Victoria, Australia

9. ADDITIONAL INFORMATION FOR EMPLOYEES AND JOB APPLICANTS 

Job applicants  

If you apply for a position with us, we may also collect the information necessary to manage and consider your application including your resume, employment history, qualifications, experience, screening checks (including references and police or other background checks) and interview notes.  

We collect, use and disclose your personal information to assess your job application, conduct screening checks and consider and contact you regarding other positions. We may exchange your personal information with academic institutions, recruiters, screening check providers, professional and trade associations, law enforcement agencies, referees and your current and previous employers. Without your personal information we may not be able to progress considering you for positions with us.

Our employees

This section applies to our current and former employees and contractors in addition to the job applicants’ section above.  

We may collect information relating to your current or former employment or engagement including information about your training, disciplining, resignation, termination, terms and conditions, emergency contact details, performance, conduct, use of our IT resources, payroll matters, union or professional/trade association membership, recreation, leave and taxation, banking or superannuation affairs. We are required or authorised to collect your personal information under various laws including the Fair Work Act, Superannuation Guarantee (Administration) Act and Taxation Administration Act.  

We collect, use and disclose your personal information for purposes relating to your employment or engagement with us including engagement, training, disciplining, payroll, superannuation/pension or applicable funds, health and safety, administration, insurance and staff management purposes. We may exchange your personal information with your representatives (including unions) and our service providers including providers of payroll, banking, staff benefits, surveillance and training services. Without your personal information we may not be able to effectively manage your employment or engagement.

Please note that we may rely on an employee records exemption in the Privacy Act, or a similar exemption under applicable laws, notwithstanding this Privacy Policy.   

10. CHANGES TO THIS PRIVACY POLICY  

We may make changes to this Privacy Policy from time to time for any reason. We will publish those changes on our website. The Privacy Policy was last updated on September 19th 2022.  

11. HOW CAN YOU ACCESS AND CORRECT YOUR PERSONAL INFORMATION?

At your request, we will provide you with access to your personal information that we hold, and the ability to update, correct or delete it, unless there is a legal basis not to, in which case we will let you know. Such requests can be made by contacting us at the details provided below. Please provide as much detail as you can about the particular information you are enquiring about, in order to help us locate it. We may need to verify your identity. 

12. RESOLVING YOUR PRIVACY REQUESTS AND COMPLAINTS

If you have a query or complaint about how we handle your personal information, would like to withdraw your consent to any use of your personal information as set out in this Privacy Policy, or any requests, issues or concerns regarding your personal information or any aspect of this Privacy Policy, then please contact us on the details provided below. We may request additional details from you regarding your concerns, and may need to engage or consult with other parties in order to investigate and deal with your issue. We will keep records of your request and any resolution. 

RATIONALE

Att: Privacy Officer

PO Box 188

Clifton Hill 3068

Victoria, Australia

dataprivacyofficer@rationale.com

13. MORE INFORMATION ABOUT PRIVACY

If you would like further information regarding privacy issues generally, visit the:

Australia: Office of the Australian Information Commissioner’s website at www.oaic.gov.au.

Singapore: Personal Data Protection Commission's website at https://www.pdpc.gov.sg/.