Privacy Policy

Pearlii Pty Limited ABN 87 637 995 512 (“Pearlii”, “us”, “we” or “our”) recognises the importance of your privacy and understands that the security of your personal information is important to you.

This Privacy Policy explains how Pearlii manages the personal information that we collect, hold, use and disclose and how to contact us if you have any further queries about our management of your personal information.

Background

Personal information is 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.

Special provisions apply to the collection of personal information which is sensitive information. This includes health information and information about a person’s race, ethnic origin, political opinions, membership of political, professional or trade associations, religious or philosophical beliefs, sexual preferences and criminal history.

In this Privacy Policy, all references to personal information include sensitive information unless indicated otherwise.

What personal information does Pearlii collect?

In the course of our business, Pearlii may collect personal information about you that is necessary for us to perform our functions and activities. Pearlii will only collect personal information about you by lawful and fair means and not in an unreasonably intrusive manner.

The types of personal information we may collect and hold may vary depending on the nature of our interaction with you and may include:

• identifying and contact information (such as name, gender, age, email address and telephone phone number);
• information about your dental health and history (such as photos of your teeth, oral health questionnaire responses and any dental check-ups or treatments you have received);
• information about your upcoming dental appointments booked through Pearlii’s mobile app;
• location and browsing history; and
• from time to time, records of any communications you have with us.

Pearlii may collect personal information about:

• consumers who use Pearlii’s products and services such as Pearlii’s mobile app;
• dental providers;
• third parties providing a service to Pearlii; and
• employees and contractors of Pearlii.

How does Pearlii collect personal information?

Pearlii may collect your personal information in a number of ways including through Pearlii’s mobile app.

Pearlii typically collects your personal information directly from you. On some occasions, Pearlii may collect your personal information from third parties such as, if you choose to sign up or register to Pearlii via a social media platform or third party platform (including Google, Facebook, the Apple App Store and Google Play Store), we may collect information from the operator of that platform.

For what purposes does Pearlii collect, hold, use and disclose your personal information?

In general, Pearlii collects, holds, uses and discloses personal information for the following purposes:

• to provide you with, develop and continue to improve, Pearlii’s mobile app;
• to facilitate your dental health consultation with a dentist, including by disclosing such information to third party online booking providers (noting you may also provide your personal information directly to such providers);
• to review, develop, improve, build and train the machine learning algorithms for identification of dental concerns;
• to assist in identifying information which may be relevant to you in our mobile app including in relation to dental concerns;
• to send you notifications with respect to our mobile app;
• to manage our relationship with you;
• to conduct research and data analysis;
• to answer your queries and requests;
• to verify and update personal information held by us;
• to resolve any complaints or issues;
• to comply with legal or regulatory obligations; and
• for other purposes required or authorised by or under law, including purposes for which you have provided your express or implied consent.

Our range of products and services and our functions and activities may change from time to time.

If you provide your email address, telephone and/or mobile phone number, you also consent to Pearlii using your email address, telephone and/or mobile phone number to contact you (including by telephone call, SMS or email) for any of the above purposes.

To whom may Pearlii disclose your personal information?

In order to carry out the above purposes, Pearlii may disclose your personal information to:

• dental providers for the purpose of facilitating your dental health consultations, including disclosing photographs of your teeth and oral health questionnaire responses;
• our service providers who assist us to perform our functions and activities including data storage providers, IT service providers and online booking providers;
• regulatory authorities; and
• parties involved in a prospective or actual transfer of our assets or business.

What happens if you don’t provide Pearlii with your personal information?

If you do not provide personal information requested of you to Pearlii, we may be unable to provide the products and services you or others request of us.

How does Pearlii hold your personal information and manage the data quality and security of your personal information?

Pearlii stores your personal information as encrypted electronic data on Amazon Web Services servers located in Sydney and on Stripe servers located in Australia, with high level security and access only available by password.

To the extent required by the Privacy Act 1988 (Cth) (Privacy Act), Pearlii will take reasonable steps to:

• make sure that the personal information that we collect, hold, use and disclose is accurate, complete and up to date; and
• protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure.

Pearlii will take reasonable steps to ensure that personal information that is held which is no longer required, including under any contractual or legal requirement, is destroyed or de-identified in a secure manner.

Does Pearlii transfer personal information overseas?

Pearlii is unlikely to transfer your personal information overseas.

In the event Pearlii transfers your personal information outside Australia, we will comply with the requirements of the Privacy Act that relate to transborder data flows.

Marketing

Pearlii may use your personal information to send direct marketing information in relation to our products and services or the products and services of third parties that we consider may be of interest to you. If you provide your email address or mobile phone number, you also consent to Pearlii using your email address or mobile phone number to send you (including by SMS or email) the direct marketing information listed above.

You may opt-out of receiving direct marketing information from Pearlii at any time by contacting us using the contact details which appear immediately below under the heading “How can you access or correct your personal information and contact Pearlii?”.

How can you access or correct your personal information and contact Pearlii?

Please contact us if you would like to seek access to or request that we correct the personal information we hold about you:

• By email: support@pearlii.com

Pearlii will generally provide you with access to your personal information if practicable, and will take reasonable steps to amend any personal information about you which is inaccurate or out of date. In some circumstances and in accordance with the Privacy Act, Pearlii may not permit you access to your personal information, or may refuse to correct your personal information, in which case we will provide you reasons for this decision.

How to exercise the right to delete your data

Any requests to have your Personal Data deleted or otherwise removed can be directed to the Owner through the contact details provided above. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

How Pearlii handles complaints

If you have any concerns or complaints about the manner in which your personal information has been collected or handled by Pearlii, please advise us of your concern or complaint in writing and send it to the Privacy Officer using the email address set out above. Your concern or complaint will be considered or investigated and we will endeavour to respond to your complaint within 14 days.

It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response, you may contact the Office of the Australian Information Commissioner who may investigate your complaint further.

Further information

Further information about the application of the Privacy Act can be found at the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.

Changes to our Privacy Policy

This Privacy Policy is effective from 10/11/2020. As this Privacy Policy is updated from time to time, to obtain a copy of the latest version at any time, you should visit our website at www.pearlii.com or contact the Privacy Officer as above.