1. INTRODUCTION
This document sets out the privacy policy of COS MEDCONNECT PTY LTD ACN 684 251 983 (referred to in this privacy policy as ‘we’, ‘us’, or ‘our’).
The Privacy Act 1988 (Cth) (Privacy Act) requires entities bound by the Australian Privacy Principles to have a privacy policy. We take our privacy obligations seriously and we’ve created this privacy policy to explain how we store, maintain, use and disclose personal information.
By providing personal information (including sensitive information) to us, you consent to our storage, maintenance, use and disclosing of personal information in accordance with this privacy policy.
We may change this privacy policy from time to time by posting an updated copy on our website and we encourage you to check our website regularly to ensure that you are aware of our most current privacy policy.
2. TYPES OF PERSONAL INFORMATION WE COLLECT
The personal information we collect may include the following:
(a) name;
(b) mailing or street address;
(c) email address;
(d) social media information;
(e) telephone number and other contact details;
(f) age;
(g) date of birth;
(h) sensitive information (such as your health information, medical history (including medical documents and previous surgeries), family history and photos of your body before and after any operation);
(i) information about your business or personal circumstances;
(j) information in connection with client surveys, questionnaires and promotions;
(k) your device identity and type, I.P. address, geo-location information, page view statistics, advertising data and standard web log information;
(l) information about third parties; and
(m) any other information provided by you to us via our website or our online presence, or otherwise required by us or provided by you.
3. HOW PERSONAL INFORMATION IS COLLECTED
We will collect your personal information in a lawful and fair way. We will only collect your personal information where you have consented to it, or otherwise in accordance with the law.
How we collect information from you
We may collect personal information where you:
(a) contact us through our website;
(b) receive goods or services from us;
(c) submit any of our online inquiry forms;
(d) communicate with us via email, telephone, SMS, social applications (such as LinkedIn or Facebook) or otherwise;
(e) interact with our website, social applications, services, content and advertising; and
(f) invest in our business or enquire as to a potential purchase in our business.
How we collect information from third parties
Where possible, we collect your personal information directly from you. However, there may be occasions when we collect personal information (including sensitive information) about you from someone else, such as the hospital, clinic or health professional to whom we have referred you.
How you provide information for someone else
If you are providing personal and/or sensitive information on behalf of someone else, you must have the consent of that person to provide their personal and/or sensitive information to us to be collected, used, and disclosed in accordance with this privacy policy.
How we collect information from cookies
We may also collect personal information from you when you use or access our website or our social media pages. This may be done through use of web analytics tools, ‘cookies’ or other similar tracking technologies that allow us to track and analyse your website usage. Cookies are small files that store information on your computer, mobile phone or other device and enable and allow the creator of the cookie to identify when you visit different websites. If you do not wish information to be stored as a cookie, you can disable cookies in your web browser.
We may use Google Analytics and Meta Pixel to collect and process data, including when you use third-party websites or apps. To learn more, please see How Google uses data when you use our partners’ sites or apps and Facebook’s Data Policy.
4. USE OF YOUR PERSONAL INFORMATION
We collect and use personal information for the following primary purposes:
(a) to provide goods, services or information to you;
(b) for record keeping and administrative purposes;
(c) to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing goods or services to you;
(d) to improve and optimise our service offering and customer experience;
(e) to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;
(f) to send you administrative messages, reminders, notices, updates, security alerts, and other information requested by you; and
(g) to use your personal information and images (including before and after photos) on our website, marketing materials, and social media channels to promote our services, with your consent where required by law;
We may also use your personal information for:
(h) secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use;
(i) such purposes where we reasonably believe that use of your personal information is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety, and it is unreasonable or impracticable to obtain your consent;
(j) any other purpose for which we receive consent from you; or
(k) any other purpose which is permitted or required under applicable privacy laws.
5. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We respect your privacy, and we will take reasonable steps to keep your personal information confidential and protected. We may disclose your personal information to:
(a) a hospital, clinic or other health care providers we refer you to;
(b) third parties who assist in your care or travel arrangements, including transport providers, accommodation services and post-operative care providers;
(c) our professional advisors such as lawyers, accountants and auditors;
(d) our related entities; or
(e) any third parties you have consented personal information to be disclosed to.
We may also disclose personal information to third party contractors as required for us to provide our goods and services to you, such as cloud-service providers, IT professionals, marketing agencies and debt collection agencies.
We take care to work with such third parties who we believe maintain an acceptable standard of data security and require them not to use your personal information for any purpose except for those activities we have asked them to perform on our behalf.
We will not otherwise disclose your personal information unless:
(f) you have consented to us disclosing your personal information for particular circumstances;
(g) as needed in an emergency or in investigation suspected criminal activity;
(h) we are required to disclose under a subpoena, court order or other mandatory reporting requirements;
(i) we reasonably believe that disclosure of your information is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety, and it is unreasonable or impracticable to obtain your consent;
(j) it is reasonably necessary for the establishment, exercise or defence of a legal claim; or
(k) it is otherwise authorised or required by law.
6. STORAGE OF YOUR PERSONAL INFORMATION
All personal information we collect is stored using third-party platforms, including JotForm and Customer Relationship Management (CRM) systems like HubSpot, which may store data on servers located outside of Australia. While we take reasonable steps to protect your personal information, some data may be stored or accessed by overseas service providers, including for system support or disaster recovery purposes.
By providing your personal information to us, you consent to the storage and processing of your information in this manner, including by overseas providers where necessary for us to deliver our services to you.
When you communicate with us through a social media service such as Facebook or Twitter, the social media provider and its partners may collect and hold your personal information overseas.
7. SENSITIVE INFORMATION
Collection of sensitive information
We may collect sensitive information about you during the course of providing you our goods and services. We will only collect this sensitive information where you consent to such collection and either directly provide us with this information or it is provided by a referring health care provider.
Types of sensitive information we collect
The sensitive information we collect may include the following:
(a) health information, history and reports, including medical reports, documents, details of any previous surgeries, and family medical history;
(b) photos of your body before and after any procedure;
(c) details of any companions who will accompany you to any procedures;
(d) private health fund and private health insurance cover details;
(e) any other sensitive information provided by you or a third party to us via our website or platforms, or otherwise provided by you or a third party to us.
How we use your sensitive information
Your sensitive information will only be used for the purpose of:
(f) assisting you to access goods and services from third-party providers, including hospitals, clinics and other related providers (such as accommodation or transport providers);
(g) complying with our legal obligations, resolving disputes or enforcing our agreements with you;
(h) sending you messages, reminders, notices, updates, security alerts, and other information requested by you; or
(i) any other purpose which is permitted or required under applicable privacy laws.
How we disclose your sensitive information
Your sensitive information will only be disclosed to third parties for the purpose of:
(j) referring you to, or facilitating your access to, third-party providers (such as hospitals, clinics, surgeons and other providers);
(k) coordinating services that support your procedure, such as transport providers, accommodation providers, or support personnel involved in your post-procedure recovery;
(l) enabling consultations, surgical planning and the delivery of healthcare services by the relevant providers;
(m) storing your information securely on third-party platforms we use;
(n) any other purpose which is permitted or required under applicable privacy laws.
How you can withdraw consent
If you wish to withdraw your consent to our collection, use or disclosure of your sensitive information, please contact us using the contact details set out below. We will deal with all such requests within a reasonable timeframe.
8. MARKETING
We may at times send you marketing communications which will be done in accordance with the Spam Act 2003 (Cth) (Spam Act).
If we do, we may use email, SMS, social media, phone or mail to send you direct marketing communications.
Where consent is needed, we will ask you for your consent before sending you marketing communications, except where you:
(a) have explicitly opted-in to receiving email marketing from us in the past; or
(b) were given the option to opt-out of email marketing when you initially signed up for one of our platforms and you did not do so.
You can, at any time, opt out of receiving marketing materials from us by using the opt-out facility provided (e.g., an unsubscribe link on emails we send you) or by contacting us via the details provided at the end of this privacy policy. We will implement such a request as soon as possible, however, cannot guarantee that such a response will be immediate.
9. SECURITY
We take reasonable steps to ensure that your personal and sensitive information is secure and protected from misuse, interference, loss, unauthorised access, modification, or disclosure.
Information collected through our forms is stored securely on JotForm, a third-party online platform that implements its own security measures, including encryption and secure servers. Access to the information is restricted to authorised personnel only and is protected by password and access controls.
While we take reasonable steps to protect your information and only use reputable service providers, we cannot guarantee the absolute security of any data transmitted or stored electronically.
10. LINKS
Our website may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites and we suggest you review the privacy policies of those websites before using them.
11. REQUESTING ACCESS OR CORRECTING YOUR PERSONAL INFORMATION
If you wish to request access to the personal information we hold about you, please contact us using the contact details set out below including your name and contact details. We may need to verify your identity before providing you with your personal information. In some cases, we may be unable to provide you with access to all your personal information and where this occurs, we will explain why. We will deal with all requests for access to personal information within a reasonable timeframe.
If you think that any personal information, we hold about you is inaccurate, please contact us using the contact details set out below and we will take reasonable steps to ensure that it is corrected.
12. COMPLAINTS
If you wish to complain about how we handle your personal information held by us, please contact us using the details set out below including your name and contact details. We will investigate your complaint promptly and respond to you within a reasonable timeframe.
13. CONTACT US
For further information about our privacy policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:
Name: Jane Luong
Email: jane@cosmedconnect.com
Our privacy policy was last updated on 12 June 2025
