1. Introduction

1.1 Who we are

In this document, ‘we’, ‘us’, ‘our’ and ‘Bupa Optical’ refers to Bupa Optical (Bupa) Pty Ltd and its subsidiaries trading under the name ‘Bupa Optical’, their related entities and bodies corporate. We are part of the Bupa Australia Group of companies.

1.2 Protecting your privacy

Your privacy and maintaining the confidentiality of your personal information is important to Bupa Optical. This document sets out how we handle your personal information, including the collection, storage, use and disclosure of your personal information, as well as how you can access and change your information, provide us with feedback or make a complaint. This document is amended from time to time.

1.3 Definitions

Consent means your permission. Your consent can be express or implied. Express consent can be written (e.g. when you sign a form or send us correspondence) or verbal (e.g. when you give us your permission over the phone or in face-to-face conversations). Your consent will be implied when we can reasonably form a conclusion from our pre established relationship with you that you have given consent by either taking action or deciding not to take action.

Personal information has the same meaning that it has under the Privacy Act 1988 (Cth), namely information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

2. Collection of your personal information

2.1 What kinds of personal information does Bupa Optical collect?

The amount and type of personal information we collect from you and hold about you will vary depending on whether you are an existing customer, have made enquiries about our products and services and also the extent to which you have used our products and services. If you apply to be, are currently or have in the past been our customer, the personal information that we hold about you may include:

• your name, address, telephone and email contact details;
• your gender, date of birth and marital status;
• results of any eye tests performed, your prescription and other health information;
• records of service contacts such as system notes and voice recordings of telephone conversations you have had with our employees;
• census and statistical information for purposes including product development and risk assessment;
• your Medicare number;
• details of purchases made and professional services used, including the date, etc.

If you have previously contacted us to make an enquiry about our products and services we may hold the information you gave us at that time. In addition, where a customer provides us with information about another person, or where another person is designated to act on behalf of a customer, we may hold that person’s information.

2.2 How does Bupa Optical collect personal information?

• We may collect personal information from you in a range of ways, including:
• when you contact us in person, by phone, via mail, email or online;
• when you subscribe to newsletters or other direct marketing materials;
• when you use professional services;
• when you purchase goods.

If you have provided us with information about another person, then you need to tell that other person that you have done so, that they have a right to access their information and that they can refer to this document for information on how Bupa Optical will handle their personal information.

2.3 If you do not provide us with your personal information

If you do not provide us with your personal information, we may be unable to provide you with the products or services that you are requesting.

3. Use and disclosure of your personal information

3.1 How does Bupa Optical use your personal information?

We use your personal information primarily to provide, manage and administer our products and services to you and to operate an efficient and sustainable business. As part of these processes, we may disclose your personal information on a confidential basis to our related entities within the Bupa Australia Group of companies and Bupa Optical businesses. In addition, we may use your information to:

• provide and administer our products and services to you;
• contact you in relation to any matter relating to you or the products and services provided to you;
• answer your enquiries and deliver customer services to you;
• carry out internal functions such as administration, accounting, quality assurance and information technology;
• monitor, price and evaluate products and services;
• resolve complaints;
• conduct customer surveys;
• conduct marketing, research and statistical analysis;
• personalise how we provide and market our products and services to you (for example, in our communications to you or advertisements on websites and social media platforms that you access);
• comply with any laws or regulations;
• fulfil marketing promotions.

3.2 Direct marketing

From time to time, we may contact you to provide you with information about other products and services offered by us, our related entities and our business partners that may be of benefit to you and your family. This includes information about eyecare or services that can help you improve your wellbeing. When we contact you it may be via mail, phone, email, SMS, digital app, social media or other means that become available from time to time. We may share your personal information on a confidential basis with our related entities and bodies corporate so that they can offer you products and services and fulfil offers to you.

When you become our customer, you consent to us using your personal information for direct marketing purposes (as described in this document), unless you have contacted us to withdraw your consent. If you do not wish to receive marketing material from us you can contact us at any time to let us know. Our contact details are at the end of this policy. When you contact us to make this request, we will action your request within 5 working days.

If you request not to receive marketing material, please note that we will still contact you in relation to our on-going relationship with you. For example, we will still send you any bills, statements and notices that are relevant to the products and services you have purchased from us.

3.3 Who does Bupa Optical disclose your personal information to?

Bupa Optical operates across Australia. In the course of conducting our business and providing our products and services to you, we may disclose your information to our related entities and bodies corporate. In addition, in order to allow us to provide, manage and administer our products and services to you and to operate an efficient and sustainable business, we may be required to disclose your information to third parties. This may include disclosure in the following circumstances:

• government and regulatory bodies, e.g. Medicare;
• other healthcare providers, for example, if you have obtained a referral to an eye specialist;
• auditors and other service providers we may appoint to ensure the integrity of our operations;
• any person or entity acting on our behalf;
• where disclosure is required by law, e.g. compulsory notices from courts of law, tribunals or government agencies
• agencies; and
• to any of our business partners or service providers (including website hosts and platform operators).

Some of our business partners and service providers with whom we share personal information as described above may be located outside of Australia. This includes Shopify Inc. (‘Shopify’), who powers our online store. Shopify may store and process personal information in Canada and the United States of America and will handle your information in accordance with their privacy policy, which you can view at www.shopify.com/legal/privacy. When personal information is processed outside of Australia, you may not be able to seek redress under the Privacy Act 1988 (Cth) and the laws of other countries may not offer the equivalent level of protection as under Australian law.

It is possible that information may be transferred to a jurisdiction where you will not be able to seek redress under the Privacy Act 1988 (Cth) and that does not have an equivalent level of data protection as Australia. To the extent permitted by law, we will not be accountable for how these overseas recipients handle your personal information.

By providing your personal information to us, you consent to our disclosure of your personal information to these parties. If you have any concerns regarding the transfer of your personal information overseas, please contact us using the details provided below.

3.4 How does Bupa Optical store personal information and for how long?

We will take all reasonable steps to ensure that your personal information is stored securely and is protected from misuse and loss and from unauthorised access, modification or disclosure. This includes a range of systems and communication security measures, as well as the secure storage of hard copy documents. In addition, access to your personal information will be restricted to those properly authorised to have access.

We keep your personal information for as long as it is required to provide you with the products and services you requested from us and to comply with legal requirements.

If we no longer require your personal information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or de-identify your personal information except in limited permitted circumstances.

4. Accessing and Correcting your Personal Information

4.1 Can I access my personal information?

You can ask us for access to the information that we hold about you at any time. Simply contact us (our contact details are listed below) to make your request. We will always endeavour to meet your request for access within a reasonable time and in the manner requested by you if it is reasonable to do so. However in some circumstances, access to certain information may be declined. This includes the following circumstances:

• we no longer hold or use the information;
• providing access would have an unreasonable impact on the privacy of others;
• the request is frivolous or vexatious;
• the information relates to existing or anticipated legal proceedings and would not normally be disclosed as part of those proceedings;
• providing access would be unlawful;
• denying access is required by law;
• providing access would be likely to prejudice the prevention, detection, investigation and prosecution of possible unlawful activity;
• the information would reveal our commercially sensitive decision-making process; and
• where access would pose a threat to the life or health of any individual.
• the information would reveal our commercially sensitive decision-making process; and
• where access would pose a threat to the life or health of any individual.

If we are unable to give you access to the information you have requested, we will give you written reasons for this decision when we respond to your request. If you have any concerns about the refusal, please see section 6 for further information.

We may charge you a reasonable fee for access to some types of information. This charge will be limited to the cost of recouping our costs for providing you with the information. For example, document retrieval, photocopy, labour and delivery to you. We will not charge you to make a request to access your information.

You may request access to your personal information by contacting us as per the contact details at the end of this document.

4.2 Correcting your personal information

To enable us to provide you with the best possible service, it is important that the information we hold about you is accurate.
We will take reasonable steps to ensure that your personal information is accurate, complete and up-to-date at the time of collecting, using or disclosing it. If you believe any information we hold about you is inaccurate, incomplete or out-of-date, you should contact us to let us know. We will respond to your request within a reasonable period and will take reasonable steps to amend your records.

5. Your Privacy Online

5.1 Online data collection and use

The information handling processes outlined in this document also relate to any personal information collected online via any Bupa Optical website. When an individual accesses any Bupa Optical website, anonymous technical information may be collected about user activities on the website. This may include information such as the type of browser used to access the website and the pages visited. This information is used by Bupa Optical to make decisions about maintaining and improving our websites and online services. This information remains anonymous and is not linked in any way to personal identification details.

5.2 Cookies

A “cookie” is a small text file placed on your computer by a web server when you access a website. Cookies are frequently used on websites. Cookies in themselves do not identify the individual user, just the computer used. We use cookies to collect data to help us determine which pages are most popular, peak usage times and other information that helps us make our websites easier and more efficient for you to use.

When you visit our websites we may set a cookie on your machine so that when you next visit our websites it links to your personal information that is stored on our system. You can choose if and how a cookie will be accepted by configuring your preferences and options in your browser. For example, you can set your browser to notify you when you receive a cookie or to reject cookies. However, if you decide not to display cookies, then you may not be able to gain access to all the content and facilities of this website.

6. Resolving your Concerns

You can contact us at any time if you have any questions or concerns about this document or about how your personal information has been handled.

You can contact our Business Operations Manager by directing your correspondence to:

Bupa Optical Head Office
Level 15, 33 Exhibition Street, Melbourne, Victoria 3000

You can also contact us by email at feedback@bupaoptical.com.au or by visiting a Bupa Optical store.

All our contact details can also be found online at bupaoptical.com.au/customer-service/contact-us

Bupa Optical will manage any concerns internally, directly with you.
If you are not happy with our response, or if you do not feel your complaint has been resolved, you are able to seek advice from the Office of the Australian Information Commissioner by calling 1300 363 992.

Shopify Privacy Collection Notice

Our online store is powered by Shopify Inc. (‘Shopify’). When you place an online order, your data may be shared with Shopify who will handle it in accordance with their privacy policy, which you can view at www.shopify.com/legal/privacy.

When you use our online store, your information may be disclosed by Shopify and its affiliates to recipients located outside of Australia, including in Canada and the United States of America. It is possible that your information may be transferred to a jurisdiction where you will not be able to seek redress under the Australian Privacy Act 1988 (Cth), and that does not have an equivalent level of data protection as Australia. To the extent permitted by law, Bupa Optical will not be accountable for how these overseas recipients handle your personal information.

By providing your personal information to us, you consent to our disclosure of this information to Shopify.

If you have any concerns regarding the transfer of your personal information overseas, please contact us or place an order through one of our physical retail stores