Updated: 21 September 2020
Toogetha is strongly committed to protecting your privacy when you interact with us, our content, products and services.
Our goal is to provide you, the client, with experiences that inform and educate. Sometimes this means that we use information that you provide to us about yourself to customise that experience. We do this to improve your understanding of our products and services. In providing our services to you, Toogetha will be transparent about how and why we collect and use your information. In some cases, if you do not want us to collect or use your information in a particular way, then we will give you the opportunity to say so.
- the kind of information Toogetha may collect about you, how we collect it, and how we use it;
- how we may disclose that information;
- how you can access the information we hold about you;
- when we may use your information to contact you;
- the protection of your personal information;
- how and why we collect and use additional information when you visit Toogetha, either at one of the clinics or online.
This policy applies only to Toogetha. It does not apply to any other company or organisation, including those whose digital services have links to Toogetha’s treatments or services. Third party services which have links to Toogetha will govern the use of personal information you submit to them, which may also be collected by cookies when you visit or use them. We do not accept any responsibility or liability for the privacy practices of such third party digital services.
Toogetha will review this policy regularly, and may update it from time to time. If we make changes, we will post those changes on the privacy page of Toogetha’s website.
2. Collection and use of personal information
2.1 Toogetha collects personal information about you:
- because you have provided it to us, for instance if you contact us to make comments, complaints or to ask us questions, or you have interacted with one of our digital services (including online and mobile services), for instance by participating in forums, polls or competitions;
- because we need it to provide a treatment, product or service that you have requested, for instance, if you subscribe to an email list, enter a competition, or purchase products from Toogetha;
- because you work for us, or apply to us for a job or work experience;
for purposes directly related to any of the above.
2.2 How we collect information when you use a digital service (including online and mobile services)
Broadly, there are two types of information or data we collect:
Information that you specifically give us, for example, you may provide information about yourself when you are filling in a form or when you sign up to a service. This type of information may include your name, email address and age. The information that you give us may be:
- Personal information that is required. In some instances, you must provide personal information if you wish to use a particular treatment or service.
- Personal information that is optional. You may choose to provide some personal information which is not required but is directly related to Toogetha’s functions or activities. Usually this type of information will enable Toogetha to improve or broaden the treatment, products and services we can offer you. If you choose not to provide this optional information, we would still be able to offer you the treatment, product and/or service, but perhaps with fewer options than if you had provided the optional information. For example, if you tell us your interests in a particular area, we may be able to provide you with specific Toogetha information that matches your interests. If you provide us with unsolicited information that we do not require or which is not directly related to Toogetha’s functions or activities, Toogetha may be required to destroy or de-identify that information, provided it is lawful and reasonable to do so.
- Permissions. Sometimes you will be asked to confirm that you agree to a particular treatment, product and/or service. For example, you may need to expressly agree that you would like to receive a newsletter or to confirm that you agree to the terms and conditions of a competition.
You may be able to make changes to the information you provided us (for example, if you change your email address) or withdraw the permission you gave us for a particular service. We will make it clear how you do that.
Data we collect that tracks your activity, automatically gathers information to monitor the use of our digital services (including online and mobile services), like the numbers and frequency of visitors to Toogetha’s website.
This information helps us improve our services by learning what our audiences use and don’t use. It can also help us identify if there are any problems with our services that need fixing.
Most of the data we collect is aggregated, and this information is effectively anonymous to us.
In some cases we may collect data that can be linked to you individually. For example, when you log in to Toogetha’s digital service as a registered user, we may store records of information such as the comments you make, the pages you viewed or links you click on. Similarly, if you use our email newsletters we may collect data about the mailings you open and the links you click on from that newsletter.
As well as helping to improve our services, we may use this data to provide recommendations that you might find helpful based on your activity. In some cases, a digital profile may be formed based on your activity. We do this in order to improve your experience or to improve our ability to provide a service. Though surveys usually collect aggregate data, we will make it clear to you if any survey information is being collected in a way that could personally identify you.
If you use Toogetha, further information may need to be collected because of the commercial nature of this site. Additional privacy information about Toogetha is set out below.
3. Disclosure of personal information
3.1 Disclosure of personal information to third parties
Toogetha may disclose your personal information to third parties for the following purposes:
- to provide the service you wish to use;
- for research purposes relating to the performance, quality, maintenance and improvement of Toogetha’s services and products;
- to customise and promote Toogetha’s services which may be of interest to you;
- to provide technical support to you to use the Toogetha’s services;
- if permitted or required by law; or
- otherwise with your consent.
Toogetha is assisted by a variety of third parties to deliver the services and products offered. These third parties are too numerous to list, and they change from time to time. Some examples of the types of third parties include:
- technology service providers including:
- Internet service providers such as Telstra
- ASIT Management Services
- Promotion or marketing service providers such as Mailchimp and Hubspot
- Subscription service providers
In many cases, Toogetha imposes contractual restrictions equivalent to those imposed on Toogetha under the Privacy Act in respect of collection and use of personal information by those third parties. In some cases, such as social media networks, Toogetha’s ability to impose contractual restrictions is limited. In those circumstances, Toogetha will carefully consider the risks to the protection of personal information when entering into arrangements with third parties.
These third parties may be located in Australia or overseas locations.
Toogetha may disclose your personal information (excluding sensitive information about you) to third parties for the purposes of direct marketing of Toogetha services. Toogetha will obtain your specific consent to disclose sensitive information for the purposes of direct marketing of Toogetha services. You will be able to opt-out of direct marketing at any time if you so choose.
Under no circumstances will Toogetha sell or receive payment for licensing or disclosing your personal information.
3.2 Information that you disclose publicly
Toogetha provides content and services on a range of platforms with interactive features that you can contribute to. These include: guestbooks, forums, event diaries, reviews, recipes, online voting, blogs, and comments on opinion articles.
When using digital services (including online and mobile services), we suggest that you use your discretion and exercise caution when providing your personal information. For instance, if you “share” information that you have posted on Toogetha’s Facebook page using a social media tool, it is likely that you will be sharing your personal information. Toogetha has a limited capacity to protect personal information that you choose to share in this way.
Note that whenever you post personal information in publicly accessible places, such as chat rooms or message boards, this information becomes available to anyone with access to the internet. This information can be collected and used by others. In short, if you post personal information (such as your contact details) online, you may receive unwanted messages from other parties in return. Therefore, we recommend that you refrain from posting any information that you do not want seen in these public areas. For example, when participating in Toogetha forum or guest book, your name will appear on the message board. In some cases, it may be appropriate to use a pen name or pseudonym rather than your real name when you are online. You must not intentionally use the name of another living person.
Ultimately, you are responsible for maintaining the secrecy of your passwords and/or any personal information. Be responsible whenever you are online or using a digital service.
3.3 Information that is disclosed via other platforms or services
Some Toogetha services may be integrated with external services, including social media networks. This may mean that information, for instance about your interests and activities, is tracked or pulled from other places (such as Facebook). If you are signed in to a Toogetha service which is integrated with other media tools, this information may be available to others depending on the privacy settings you have in place on other platforms.
The number and nature of social media platforms is changing rapidly, and the way in which information is shared between them is becoming increasingly complex. To help you manage and protect your personal information, Toogetha will ask you to opt-in before making your personal information available through an integrated service. You may also opt-out of your participation in most of Toogetha’s digital services. Information about how to opt-out will be provided in the particular service. However, you should be aware that Toogetha may continue to store personal information provided by you prior to you opting-out.
Your ability to opt-out of a third party tool or platform will depend on the conditions governing your agreement with that third party.
4. Accessing your personal information
You have the right to request access to personal information that is held by Toogetha about you. Requests for access will be dealt with by Toogetha in accordance with the Freedom of Information Act 1982.
You also have the right to request the correction of any of your personal information that Toogetha holds. Toogetha will take reasonable steps to make appropriate corrections to personal information so that it is accurate, complete and up-to-date. To seek access to, or correction of, your personal information please contact Toogetha as follows:
(02) 6600 1509
P.O. Box 1854
5. Use of your personal information to contact you
We will never knowingly send you unsolicited commercial electronic messages. More information on the Spam Act 2003 is available from the regulator’s website: www.acma.gov.au/spam
We may use information that we know about your likes and interests to tell you about other Toogetha products and services when you are online. We may know about your likes and interests because you have provided that information, for instance via a social media platform, or because we have inferred this based on your browsing history, or other data related to your behaviour on Toogetha digital services.
6. Protection of your personal information
Toogetha will take all reasonable and practicable steps to ensure that your personal information is properly protected from misuse or loss, and unauthorised access, modification or disclosure.
At the same time, we are committed to providing innovative and interactive experiences, and to being available to audiences on multiple platforms. Some of those platforms are not operated or controlled by Toogetha, and our ability to protect your personal information is limited.
We encourage you to be vigilant about the protection of your own personal information when using third party digital services (such as social media platforms). As far as reasonably practicable, we will make sure that our relationships with those third parties include appropriate protection of your privacy.
Toogetha uses a “cookie” system on its digital services. A “cookie” is a small data file placed on your machine or device which lets our digital service store information. This information allows us to make our digital services easier to use and more relevant.
Credit card information is never stored in a cookie.
7.1 Controlling and deleting cookies
Popular browsers will usually give users a level of control over cookies.
You can set your browsers to accept or reject all, or certain, cookies. You can also set your browser to prompt you each time a cookie is offered.
Most cookies are easy to delete, and the Help function within your browser should tell you how. Some digital services may not load properly or function as intended if cookies are disabled, however it is up to you to determine the balance of convenience and computer privacy that you are comfortable with.
7.2 Cookies used by Toogetha
Toogetha uses the following types of cookies:
Session Computer Browser Cookies – Session cookies let you move from page to page without the need to repeatedly sign in. For instance, these cookies are used by Toogetha’s website to keep track of things such as what you put in your shopping cart. A session browser cookie is stored in the browser and deleted when the browser shuts down.
Persistent Cookies – Persistent cookies are used to help us monitor the performance of our digital services by recording your browsing behaviour within the particular digital service.
These browser cookies can only be read by the company that places the cookies on the computer. Persistent cookies are saved to the hard drive until they expire. Unlike session browser cookies, they are not deleted when the browser is shut down.
Flash Cookies – also known as Local Shared Objects, are used to track activity in Applications that are running in Adobe Flash Player. Designed for usability, they allow user’s custom settings to persist between visits.
Toogetha uses web beacons in combination with cookies to track activity. Turning off a browser’s cookies will prevent web beacons from tracking activity.
7.3 Third Party Cookies
Toogetha uses a number of suppliers who also set cookies on our digital services on our behalf in order to deliver the services that they are providing.
For instance, if we embed photos and video content from third parties such as shutterstock and YouTube, those third parties may have set cookies relating to that content. If you then “share” that content, another third party cookie may be set by the service you have chosen to share content through. Toogetha does not control these cookies, and does not block cookies set by third parties in these ways.
8. Additional information for parents and young people
Some digital services provided by Toogetha are specifically designed for persons of 18-years and older. Toogetha discourages the use of its digital services to those younger 18-years. We strongly encourage parents and carers to monitor and participate in their children’s use of Toogetha’s digital services.
9. Additional information about Cosmedicentre
In addition to the General Principles outlined above, the following information is relevant to Toogetha.
9.1 Collecting information about you
We collect personal information about you:
- to manage and deliver orders that you make now and in the future
- so we have a record of your order should you wish to return or exchange an item at a later date
- to contact you with offers specific to your order
- if you send us a query
- if you subscribe to an email list
- with your permission, to advise you of Toogetha special promotions
- as part of an entry to a competition or product review
- to run cookies on our website (see above)
- as part of our customer database
- for statistical and research purposes
- for purposes directly related to all of the above.
Toogetha automatically collects general website traffic information (such as how many people have visited the site, most popular pages etc). This information is collated into aggregate results in order to evaluate our service and business practice in an effort to provide you with an optimum shopping service.
9.2 Disclosure of information
We may share non-personal, aggregated information with other our partners and product distributors for research purposes. We never identify or disclose individual customers or visitors’ information or purchases but we may disclose how many customers bought a specific item or used a specific service.
We may disclose personal information to third parties as set out above.
9.3 Access to your personal information
Personal information that you have provided to Toogetha (such as your name, invoice and delivery addresses, phone number, or email address) is accessible by registering with Toogetha. By registering with Toogetha you will need to retain a username and password. Toogetha recommends that you update your personal information if your details change so that our records are accurate, complete and up-to-date.
9.4 Credit card information
Crucially, your credit card details are only stored and transmitted in encrypted form. Unencrypted credit card information is NOT stored on our internet servers. Credit card information is never stored in a cookie.
If you use your credit card and the transaction is manual rather than electronic, the imprinted record will be stored by Toogetha for the period that financial records are required to be retained.
9.5 Your Choice – Online or Offline Shopping
If you do not wish to place your order on the internet, we offer you the option of phoning or emailing
Phone: (02) 6600 1509
10. Privacy complaints and enquiries
Toogetha welcomes feedback about privacy issues and will attend to all questions and complaints promptly.
You can contact Toogetha about any privacy issues as follows:
(02) 6600 1509
P.O. Box 1854
If Toogetha takes more than 30 days to respond to your privacy complaint, or if you are dissatisfied with the outcome, you can make a complaint to the Privacy Commissioner at the Office of the Australian Information Commissioner. The OAIC can be contacted on 1300 363 992 or at www.oaic.gov.au
Page last updated 21 September 2020