• Vita Spot Holdings Pty Ltd, ABN 42 692 629 815, trading as Charlie Pet Health; and
• any related entities of Vita Spot Holdings Pty Ltd, including its holding company and any subsidiaries.

We operate Charlie Pet Health, a technology platform that connects pet owners with independent, registered veterinary professionals who perform veterinary services in their own professional capacity. We provide pet owners with the ability to baseline, track and manage their pets' health data over time, and we integrate with veterinary diagnostic and patient management systems so that test results and health records are returned to and stored within the Platform.

We do not provide veterinary services. All veterinary services available through Charlie Pet Health are provided by independent, registered veterinary professionals in their own professional capacity. This privacy policy governs how we, as the operator of the Platform, handle your personal information. It does not govern how a Veterinary Professional handles personal information they collect or access in the course of providing veterinary services to you — each Veterinary Professional is independently responsible for meeting their own obligations under the Privacy Act 1988 (Cth).

Your privacy is important to us and we are dedicated to ensuring your personal information remains private. The following privacy policy sets out how we handle your personal information, consistent with the Australian Privacy Principles within the Privacy Act 1988 (Cth).

For the purposes of this policy, personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable.

In general, we will only use your personal information for the purposes that you gave it to us for. We review this policy periodically to ensure it is kept relevant and up to date and we may make changes at any time by publishing the amended version on our website.

 

 

1. Information we collect

In the process of operating Charlie Pet Health, we may collect a range of personal information from pet owners, veterinary professionals, partner clinic personnel, service providers, job applicants and other individuals where it is necessary in order to operate our business. The kind of information collected will depend on the nature of your dealings with us, but may include:

From Pet Owners:

• contact information and identification, such as your name, date of birth, contact number, email address, residential and/or business address, and demographic information such as your postcode, age and gender;
• payment details, such as credit card details and payment-related information in connection with your purchase of veterinary services through Charlie Pet Health;
• pet information, including your pet's name, species, breed, age, weight, microchip number, desexing status and other identifying details;
• pet health information, including Pet Records, diagnostic test results, blood biomarker screening results, radiological imaging reports, clinical notes, veterinary history, wellness assessments and any other health data relating to your pet that is created, uploaded or stored within Charlie Pet Health by you, a Veterinary Professional or a third-party diagnostic provider;
• booking and transaction history, including details of Veterinary Services you have requested, received or cancelled through Charlie Pet Health;
• communications you send or receive through Charlie Pet Health, including messages to Veterinary Professionals; and
• information collected from marketing campaigns, surveys and your interactions with us, including via social media.

From Veterinary Professionals:

• contact information and identification, such as your name, business name, ABN, contact number, email address and business address;
• professional registration details, including veterinary board registration numbers, certificates of good standing and jurisdiction of registration;
• insurance details, including certificates of currency for professional indemnity and public liability insurance;
• superannuation fund details, including fund name, member number and account details;
• banking and payment details for the purpose of remuneration under your contractor agreement;
• information published on your Veterinary Professional Profile; and
• clinical records, consultation notes and other data you enter into the patient management system (PMS) in the course of providing Veterinary Services.

From Partner Clinics and Third-Party Diagnostic Providers:

If you do not provide us with the personal information we request, we may be unable to provide you with the full range of our services and, depending on the information withheld, you may be ineligible to use Charlie Pet Health.

Sensitive information

We will only collect sensitive information about you with your consent, unless we are otherwise allowed or required by law to collect that information. Pet health information may contain sensitive information about a pet owner (for example, where a pet's medical history reveals information about the owner's circumstances). We treat all pet health information with the highest confidence.

 

 

2. How we collect information

Information collected from you

Most of the personal information we collect will be collected directly from you. This may occur when you:

• register for an account on Charlie Pet Health;
• create or update a pet profile or a Veterinary Professional Profile;
• request, confirm, cancel or complete a Booking;
• enter or update clinical records, diagnostic requisitions or consultation notes in the PMS;
• make or receive a payment through Charlie Pet Health;
• contact or interact with us in person, by email, phone or other forms of communication, or via forms on our website or social media accounts;
• respond to any of our job advertisements; or
• attend events hosted or operated by us.

Information collected from third parties

We may sometimes collect your information from third parties, such as:

• Veterinary Professionals who enter clinical notes, diagnostic results or other information about you or your pet into the PMS in the course of providing Veterinary Services;
• partner clinics and third-party diagnostic providers who return test results, pathology reports or imaging reports to Charlie Pet Health;
• information held by online third-party services that you have granted us access to (e.g. Google, Facebook);
• Stripe or other payment processors, in connection with payment transactions;
• parties you refer us to, or who refer us to you;
• contractors that we engage to provide services to us; or
• marketing agencies or providers of similar lists or information which have been legally acquired by us.

Information collected automatically

When you visit or interact with our website, our mobile application, or any other online platform operated by us (Platforms), we, as well as any of our third-party service providers, may use a variety of technologies that automatically or passively record information about how the Platform is accessed and used (Usage Data). Usage Data may include your IP address or other unique identifier for the device used to access a Platform, browser type, device type, date and time of visit, pages viewed and your use of features or applications on the Platform. Usage Data helps us to keep the Platforms relevant for our users. Usage Data is usually non-identifying, but if it can be used to identify you, we will treat it as personal information.

We may use Cookies (data files placed on a device when it is used to visit a Platform) to keep track of personal preferences and compile aggregate data about Platform traffic and online interactions with us, so that we can offer you better experiences and tools in the future. Cookies may be used by us or our service providers for security purposes, or to facilitate site navigation and personalise your experience on the Platform. You should be able to configure your computer or other web browsing device so that it disables cookies or does not accept them. However, if you reject all cookies, you may not be able to use features of Charlie Pet Health that require you to sign in, and you may not be able to take full advantage of our services.

 

 

3. Purpose of use or disclosure

We collect, use and disclose your personal information for a variety of purposes, including:

• to provide you with access to Charlie Pet Health and the services available through it;
• to facilitate Bookings and connect Pet Owners with Veterinary Professionals;
• to process payments for Veterinary Services, Ancillary Charges and any Fees;
• to store and manage Pet Records, diagnostic test results and clinical notes within the PMS;
• to enable Veterinary Professionals to create patient files, place diagnostic requisitions and receive results through the PMS;
• to coordinate with partner clinics and third-party diagnostic providers in connection with Veterinary Services;
• to remunerate Veterinary Professionals in accordance with their contractor agreements;
• to administer refunds, cancellations and Refundable Issues;
• for any purpose which we notify you about when we collect your information, or to which you have provided your consent;
• to notify users of news, updates and event information;
• for security and safety purposes;
• responding to your enquiries, concerns or complaints;
• to consider and assess your application as a potential job applicant or contractor;
• to distribute promotional material and inform you about products, services, special offers and events;
• to customise, measure and improve our services, including through data analytics, product planning and research;
• to comply with the law, including a lawful request from law enforcement; and
• other purposes related to the operation of Charlie Pet Health.

 

 

4. Disclosing your personal information

We may disclose your information to third parties, including:

• Veterinary Professionals — where you are a Pet Owner, we share relevant personal information and pet information with the Veterinary Professional you have engaged through a Booking, to enable them to provide Veterinary Services to you;
• Pet Owners — where you are a Veterinary Professional, we share your professional profile information, registration details and availability with Pet Owners through Charlie Pet Health;
• partner clinics and third-party diagnostic providers — we share relevant pet information and diagnostic requisitions with partner clinics to facilitate diagnostic testing, imaging and pathology services in connection with Veterinary Services;
• Stripe and payment processors — we share payment-related information with Stripe and other payment processors to facilitate transactions through Charlie Pet Health;
• IDEXX and PMS providers — Pet Records, clinical notes and diagnostic data are stored and managed within the PMS, which is currently licensed from IDEXX;
• our agents or contractors who perform a particular function or service on our behalf, including:
  • mail distribution providers;
  • secure data storage and hosting providers;
  • information technology service providers;
  • accountants, lawyers and other professional advisors; and
  • analytics and marketing service providers.

We may also disclose your information to third parties where required or authorised by or under law.

We will not sell or provide your information to a third party for the purposes of direct marketing without your informed consent.

 

 

5. Pet Records and pet health information

Charlie Pet Health stores Pet Records within the Platform. Pet Records may include health data, diagnostic test results, veterinary history, clinical notes and other information relating to a pet. Pet Records are accessible to the relevant Pet Owner and any Veterinary Professional engaged by that Pet Owner through the Platform.

Pet Records are created and maintained within the PMS by the relevant Veterinary Professional in their professional capacity as a registered veterinarian and as the clinical record-keeper for regulatory purposes. We host those records within the Platform infrastructure. We do not make any independent clinical assessment of the accuracy or completeness of any Pet Record.

Although animals are not "individuals" under the Privacy Act 1988 (Cth), Pet Records typically contain personal information of pet owners (such as the owner's name, contact details and communications with a Veterinary Professional) and we therefore treat Pet Records as containing personal information for the purposes of this policy.

 

 

6. Veterinary Professionals and privacy

Each Veterinary Professional who provides Veterinary Services through Charlie Pet Health is an independent contractor, not an employee of ours. Veterinary Professionals access and use personal information (including pet health information) through the Platform in the course of providing Veterinary Services.

 

We are not responsible for how a Veterinary Professional handles personal information. 

 

Each Veterinary Professional is independently responsible for complying with the Privacy Act 1988 (Cth), the Australian Privacy Principles and any applicable state or territory privacy legislation. Each Veterinary Professional's obligations regarding the handling of personal information, pet-related records and owner information are set out in the Veterinary Professional's contractor agreement with us.

If you have a concern about how a Veterinary Professional has handled your personal information, you should raise that concern directly with the Veterinary Professional in the first instance.

 

 

7. Direct marketing

Direct marketing is the promotion of goods and services directly to you, including through emails, SMS, phone calls and the post. We will only send you direct marketing materials if you would reasonably expect to receive them, or you have consented. If it is impractical to gain your consent, we will always provide a simple and easy means for you to request not to receive the material.

Charlie Pet Health may send you emails, text messages, push notifications and other alerts on behalf of us or a Veterinary Professional that has provided Veterinary Services to you. These communications may include booking confirmations, appointment reminders, diagnostic result notifications, wellness recommendations and administrative notices. You may opt out of non-essential communications at any time through your account settings or by contacting us.

 

 

8. Cross-border disclosure

Our preference is to use third-party service providers who are based in Australia, however we may use overseas service providers to process your personal information if we reasonably believe that the overseas entity is subject to the same or similar privacy laws to those found in Australia, or you have otherwise consented to us disclosing your personal information to the overseas entity.

Where we use third-party services such as Stripe, IDEXX or cloud hosting providers that may process or store data outside Australia, we take reasonable steps to ensure that those providers handle your personal information in accordance with the Australian Privacy Principles.

 

 

9. Security

The security of your personal information is important to us and we take reasonable steps to protect your information from unauthorised access or disclosure and ensure the accuracy and proper use of your personal information, including using a range of physical, technical and administrative measures such as:

• using SSL encryption to store and transfer personal information on our Platforms;
• hosting of our Platforms on servers located in secure third-party data centres, who use best-practice procedures to ensure the security of data;
• reviewing the adequacy of technical and physical security measures used by any third-party suppliers who will be processing or storing your personal information (including IDEXX as our PMS provider and Stripe as our payment processor);
• restricting access to personal information and Pet Records to authorised personnel, Veterinary Professionals and Pet Owners on a need-to-access basis; and
• ensuring that all personnel or staff engaged by us are made aware of the contents of this privacy policy and any additional policies and procedures relating to the use, protection and disclosure of personal information.

While we take all reasonable steps to ensure that your personal information is protected from misuse, interference or loss, no method of transmission over the internet, or method of electronic storage, is 100% secure. Each individual that provides personal information to us via the internet or by post does so at their own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to, personal information where the security of the information is not within our control.

If a data breach occurs, and there is a real risk of serious harm to you as a result of such breach, we will notify you and the Office of the Australian Information Commissioner as soon as practicable, in accordance with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988 (Cth).

In addition to the measures we take to protect your personal information, you should ensure that you keep secret and regularly change any access passwords to any accounts on our Platforms, and always log out of any secure pages at the end of your session.

 

 

10. Destruction

When we no longer need your personal information for a permitted purpose and we are not required to keep it to comply with any laws, we will take such steps as are reasonable in the circumstances to destroy your personal information, or to ensure that the information is de-identified.

In respect of Pet Records, we may retain records for a period required by applicable veterinary record-keeping legislation or professional standards, even after your account is closed or a Veterinary Professional's engagement with us has ended.

 

 

11. Access and correction

If you are a user of Charlie Pet Health, you can view and update certain personal information at any time via your account on the Platform. Pet Owners may access Pet Records for any pet registered on their account at any time.

If requested by you by contacting us using the details contained in this privacy policy, we will take such steps as are reasonable in the circumstances to ensure that your personal information is accurate, up-to-date, complete and relevant.

Upon your written request we will provide you with a copy of your personal information that we hold, unless there is a legitimate reason at law not to do so. We will take reasonable steps to correct your personal information if we are satisfied that it is inaccurate, out-of-date, incomplete, irrelevant or misleading. This extends to third parties that we have provided your personal information to, unless it is impracticable or unlawful to do so.

 

 

12. Resolving concerns

If you have a concern or complaint relating to our handling of your personal information, or if you feel that we have breached the privacy laws, please contact us in writing using the contact details provided below, outlining the nature of the complaint.

We will endeavour to respond to your complaint within 30 days of receipt. If your complaint is not satisfactorily resolved, you can contact us to discuss your concerns, or the complaint may be taken to the Office of the Australian Information Commissioner.

 

Office of the Australian Information Commissioner

• Website: www.oaic.gov.au
• Phone: 1300 363 992
• Email: enquiries@oaic.gov.au
• Post: GPO Box 5218, Sydney NSW 2001

 

 

13. Contact us

If you have questions or suggestions about this privacy policy or how we handle your personal information, please contact us at:

Vita Spot Holdings Pty Ltd (trading as Charlie Pet Health)

• Email: info@charliepethealth.com.au
• Mailing address: 118/810 Elizabeth Street, Waterloo NSW 2017
• Website: www.charliepethealth.com.au

 

 

14. Updating this policy

If we decide to change this privacy policy, we will post the changes on our webpage at www.charliepethealth.com.au/privacy-policy. Please refer back to this privacy policy to review any amendments.

 

We may do things in addition to what is stated in this privacy policy to comply with the Australian Privacy Principles, and nothing in this privacy policy shall deem us to have not complied with the Australian Privacy Principles.