Privacy Policy

Air Health Group Privacy Policy

Air Health Group Pty Ltd ACN 637 287 560 and its related entities (Air Health, we, us) understand the importance of, and are committed to, protecting your privacy. We comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs), which regulate how we may collect, use and disclose personal information.

We collect information provided to us in connection with our:

website located at airsmile.com (Website); and
AirSmile mobile software application (AirSmile App),

(together the AirSmile Platform).

The AirSmile Platform is an informational tool that is designed to assist our members to make informed decisions about the dental services they purchase. AirSmile Members may use the AirSmile App to, among other things, peruse profiles of AirSmile Dentists and AirSmile Partners, compare quotes, book appointments and leave reviews.

The nature of the AirSmile App’s functionality means that we collect, handle and disclose a broad range of personal information, including health information.

Who does this Privacy Policy apply to?

This Privacy Policy applies to all personal information we collect and hold, including personal information you provide to us via our AirSmile App and Website.

Please take a moment to read this Privacy Policy as it describes what happens to the personal information we collect about you. If you do not agree with the practices described in this Privacy Policy, please do not provide us with your personal information or interact with the AirSmile App, Website or social media pages.

Purpose

The purpose of this Privacy Policy is to:

help you understand your rights (and our obligations) under the Privacy Act; and
keep you informed of the ways we gather, manage, store, disclose and protect your personal information.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time so please check our Website regularly to stay informed of any updates. The updated Privacy Policy will be posted on our website, with the date of the update shown.

What is ‘personal information’ and why do we collect it?

‘Personal information’ is information or an opinion about you (whether true or not) that identifies you or from which your identity is reasonably identifiable.

We collect personal information about you that we reasonably need for our business functions and activities, which primarily consists of operating our AirSmile Platform.

The nature of the personal information collected and maintained by us varies depending upon who you are and the purpose we are collecting the information. If you are an AirSmile Member, we will generally collect the following types of information about you:

your name, email address and phone number;
a record of the information and preferences (such as preferred location) you input when using our AirSmile App;
if you upload a treatment plan onto the AirSmile App, all information on that plan as well as any other medical or health related information you provide to us; and
your IP address and information about the device you use to access our website or AirSmile App and a record of access date and times, including a record of Dentist profiles you interact with.

If you are an AirSmile Dentist, then we will typically collect information regarding your work contact details, hours of practice, pricing, photographs of your previous work, your professional qualifications, and details of your medical registration with the Australian Health Dentist Regulation Agency (AHPRA) and insurance.

We may also collect and use your personal information for activities in support of our primary business functions, such as administration, marketing, IT, legal, and customer support.

What sensitive information do we collect about you?

We may collect sensitive information about our AirSmile Members, such as medical records and treatment plans.

Sensitive information is a sub-set of personal information and includes health information about an individual. Your health information includes any information collected about your health or disability, and any information collected in relation to a health service you have received. Health information includes, but is not limited to:

notes of your diagnosis and the treatment plan given to you;
specialist x-rays and digital imaging;
specialist reports and test results;
appointment and billing details;
a list of current medications; and
healthcare identifiers, including Medicare numbers and private health fund details.

We generally only collect sensitive information you provide to us directly, such as when you upload a treatment plan onto the AirSmile App. By proving us with your health information when using the AirSmile App, you consent to us using that information to match you with profiles of AirSmile Dentists. If you book an appointment with an AirSmile Dentist, we will disclose your health information to that AirSmile Dentist and the associated AirSmile Partner.

In some cases, we may collect health information about you from third parties, such as a dental practice, if you ask that third party to release medical records to us.

How do we collect information about you?

How do we collect personal information?

We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way. Where it is reasonably practical to do so, we will collect your personal information directly from you. For example, we collect the information you provide to us when you register for an account through the AirSmile Platform, complete online forms on our Webiste, or contact us via phone or email with an enquiry, complaint or feedback.

If you subscribe to receive promotional material from us via email or SMS, we will collect information you provide us concerning your contact details and communication preferences. In certain circumstances we may collect personal information from publically available sources and third parties, such as:

a dental practice, if you ask that practice to release medical records to us; and
AHPRA, to verify details of your registration and insurance, if you are an AirSmile Dentist.

If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.

Unsolicited information

If we receive personal information about you that we have not requested, and if we determine that we could not have lawfully collected that information under the Privacy Act if we had requested it, we will destroy or de-identify the information (if it is lawful and reasonable to do so). If we collect your personal information in an unsolicited manner, we take reasonable steps to inform you of such collection and also how we use, disclose and secure your personal information. Such reasonable steps may include referring you to this Privacy Policy.

Information we collect through our Website

If you use our Website, we automatically collect the following information:

web usage information (e.g. IP address); your login information including last login and any failed attempts to login, anonymised demographic information (e.g. age bracket or gender); device type, model, and screen dimensions; browser type and version; IP location, local language setting and time zone setting; operating system and platform; and
information about your visit, including: the full Uniform Resource Locators (URLs); clickstream to, through and from our website (including date and time); time on page; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks and mouse-overs).

Where we collect information about you in the ways described above, we do so on the basis that it is in our legitimate interests to collect and process this data for statistical purposes. We collect and process this information to ensure that our Website is functioning properly and that our user experience is to the standard that you and we expect.

Do you need to provide us with your personal information?

You can deal with us anonymously (without giving us your name and contact details) or by using a pseudonym or nickname. If you contact us with a general enquiry we will generally not seek identifying information unless we need it to respond to your request.

If you choose to deal with us anonymously or by using a nickname, there are some things we cannot do. For example, if you do not upload your treatment plan and preferences, we may not be able to match you with an AirSmile Dentist.

Why do we collect and handle your personal information?

As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances. We collect, hold, use and disclose personal information (including your treatment plan) and Metadata:

to provide the AirSmile App and its functionality to you and other users and to administer our dealings with you;
as directed by you, including by the preference settings of your Member Account;
for statistical analysis (such as compiling and analysing statistics on treatment patterns in Australia);
to communicate with you and provide you with relevant information;
to seek feedback to improve our AirSmile App, Website and other services;
to comply with our legal and regulatory obligations; and
as otherwise necessary to manage our business.

Where we use or disclose your information for statistical analysis purposes we will anonymise the data so that your identity is no longer identifiable.

We may disclose personal information between our related entities and to third parties such as:

to an AirSmile Dentist or AirSmile Partner, if you book an appointment with them or otherwise ask us to do so;
to relevant Federal, State and Territory health authorities for the purposes of investigating an Office of the Health Ombudsman (OHO) complaint; and
to our technology, marketing and other service providers for the purposes of operating and improving our business and services.

We will not use or disclose your personal information for any other purpose unless set out expressly in this Privacy Policy or you have consented to that use or disclosure. If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do.

Protection of personal information

We will hold personal information electronically in cloud storage. Air Health is primarily hosted in Australia. From time to time we may engage an overseas recipient to provide services to us, such as cloud-based storage solutions.

Air Health is committed to ensuring the protection of your personal information. The cloud-based storage solution we engage uses industry standard security technology and procedures to ensure the confidentiality of your personal information.

We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of personal information. This also applies to disposal of personal information.

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.

Marketing

Like most businesses, marketing is important to our continued success. We may use your personal information (such as your contact details) to send you:

push notifications (if enabled on your device);
SMS messages; and
e-newsletters and other email or social media communications about services we think may be of interest to you.

We may disclose personal information to marketing agencies or service providers who are acting on behalf of Air Health for the purpose of marketing Air Health’s products and services. Your personal information may accordingly be transmitted to and stored by those service provides.

You may opt out at any time if you no longer wish to receive marketing material from us. The process for opting out depends on the form of marketing communication you are receiving. To opt out of push notification marketing, disable push notifications from the AirSmile App on your device. To opt out of email marketing, please contact us at [email protected] or use the ‘unsubscribe’ function embedded in our marketing emails. To opt out of SMS marketing, please reply ‘STOP’.

Cookies

A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre-defined period of time. We use cookies to identify specific machines in order to collect aggregate information on how visitors are experiencing our website. This information will help to better adapt our website to suit personal requirements. While cookies allow a computer to be identified, they do not permit any reference to a specific individual. For information on cookie settings of your internet browser, please refer to your browser’s manual.

Overseas disclosures

From time to time we may engage an overseas recipient to provide services to us, such as Amazon Web Services and other providers of cloud-based data storage solutions. Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider.

By providing your personal information to us, you:

consent to us sharing your personal information with our overseas service providers, including Amazon Web Services, for the purpose of hosting;
consent to your personal information being transmitted and stored in servers located outside of Australia, and acknowledge APP 8.1, as outlined in Schedule 1 to the Privacy Act, will not apply to the use of the information; and
acknowledge that some of our service providers may not be subject to the Privacy Act and, in the event that an overseas recipient breaches the APPs, that entity will not be bound by the Privacy Act, and you may need to seek redress under laws of other jurisdictions.

Accessing and correcting your personal information

You may contact our Privacy Officer to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. We will deal with your request within a reasonable time.

On the rare occasions when we refuse access, we will provide you with a written notice stating our reasons for refusing access. We will also provide you with avenues to complain about our refusal to provide you with access to the information.

We are not obliged to correct any of your personal information if we do not agree that it requires correction. If we refuse a correction request, we will provide you with a written notice stating our reasons for the refusal.

To exercise any of the above rights, please contact our Privacy Officer on the details below.

Definitions

In this Privacy Policy:

AirSmile Dentist means a dentist that has been registered on the AirSmile Platform in connection with an AirSmile Partner’s account.
AirSmile Member means a user of the AirSmile Platform that has completed the member registration process on the AirSmile App or Website.
AirSmile Partner means an entity operating a dental practice that has completed the AirSmile Partner on-boarding and registration process on the Website.
Metadata means any system-generated data that is created or generated in connection with your use of the AirSmile Platform, including in the use, processing, storing or hosting of any information, material, data, dataset and any descriptive, structural and administrative metadata.
Member Account means the account unique to each AirSmile Member.
Website means the AirSmile website, which can be accessed at airsmile.com.

Who to contact

If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your personal information, please contact our Privacy Officer using the contact details provided below.

Air Health Group Pty Ltd
Address: PO Box 462 Fortitude Valley QLD 4006
Email: admin@airsmile.com

We take all complaints seriously, and will respond to your complaint within a reasonable period. You may also lodge a complaint with the Office of the Australian Information Commissioner using the contact details provided below.

Office of the Australian Information Commissioner
Address: GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992
Email: [email protected]

Last updated: 21 April 2020