Privacy & Legal Information
A Summary of Our Privacy Practices
- Age Restrictions
Although anyone can view our websites, our mobile applications and services, they are not directed to individuals under the age of 16 years. Therefore, if you are under 16 years of age, please do not provide Personal Information through our mobile applications or services. If you are a parent or guardian and your child has provided us with their Personal Information, please contact us so that we can delete it from our records.
- What is “Personal Information”?
“Personal Information” is information or an opinion from which your identity is either clear or can reasonably be determined. Personal Information may include your name, email address, birth date, phone number, gender, location and any other Sensitive Information.
- What is “Sensitive Information”?
“Sensitive information” includes personal information about your physical or mental health or disability (at any time); any information you provide about future health services you may require or about a health service provided or to be provided to you; any genetic information you provide; personal information (such as date of birth, gender, race, sexuality or religion); or other healthcare identifiers.
- Who collects your Personal Information?
Netura is a parent company, so the Personal Information you provide to us will be controlled by Netura and any of our related subsidiary companies listed below:
– Better Nature Aus Pty Ltd
– Itchy baby co Aus Pty Ltd
– Itchy baby co UK Pty Ltd
- What we collect?
We collect Personal Information when you voluntarily provide it to us, such as where you:
– contact us to make an enquiry or request whether it is via email, our sites, mobile applications or otherwise
– submit an online form or register for an account including via any of our sites and social media sites.
– provide information to your healthcare practitioner about our products or services with your personal data which you may provide, or where necessary to purchase a product.
– participate in trade promotions and competitions
– visit and use our sites, or services, or view our advertisements
– voluntarily provide us your Personal Information in any other circumstance
- Why we collect it?
We may use the Personal Information we collect for the following purposes:
– to provide you with our products or services
– to communicate with you
– for marketing, promotions, and advertising (including online interest-based advertising)
– for our internal operations
– as described in any express permission you give
– as required by law
- What Personal Information we hold?
– Information that you provide to us
– Information we passively collect as described in the section of this Policy called “Non-Personal Information”
– Information from other companies who have your consent to share it with us
- When would we share your Personal Information?
– With our selected partners who may want to send you information about their own products or services, if you have consented
– With other companies we work with in our business, if required for internal business purposes only
– If required to do so by law or government authorities
– To enforce our terms and conditions; or to protect our rights, privacy, safety or property (including yours or of our partners).
- International Data
If you are an EU resident, you also have other personal data rights such as the right to:
– access the Personal Information we hold about you
– update or amend your Personal Information
– ask us to delete or transfer your Personal Information to you, or to someone else
- Do you have to give us your personal Information?
You can use any of our sites without disclosing any of your Personal Information. However, unless you provide us with the requested Personal Information, you may not be able to access some of our services (such as if you want to purchase products or services online, enter competitions or be involved in clinical research trials).
Please read more about how we collect, hold, use and disclose your Personal Information below.
- Personal Information – Collection, use and disclosure
You agree that we may collect, hold, use and disclose your Personal Information for any of the purposes listed in Point 5 of the Summary above.
Healthcare Professionals: We may collect Personal Information about healthcare professionals who dispense Netura’s products. If you are a healthcare professional, you will also need to provide your Personal Information so that you can use our services for your practice or with your patients. If you are a healthcare professional, you can read more under “Sensitive Information – Collection, use and disclosure”.
When you interact with us through our sites and mobile applications, we may collect information from you as described below.
1.1 Collection of Personal Information
Some elements of our sites may ask you to submit Personal Information in order for you to benefit from the specified features or participate in a certain activity, such as newsletter subscriptions, processing of online purchases, completion of surveys, or account registration. For example:
- Account Registration: If you register for an account, we may request Personal Information such as your name and contact information, such as your email address, telephone number, billing address, and delivery address.
- Sharing with Health Care Providers: If you agree to share information with your healthcare practitioner about our products or services via our sites, we may have access to any such information that you provide.
- Searches: if you are searching within our sites, we may record information identifying you or linking you to the search performed and recording information related to the search request.
- Customer Research and Surveys: if you submit Personal Information in response to a survey or customer research questionnaire in which we invite you to participate.
- Product Purchases: If you purchase an item through our sites, we will collect your name, your billing address, your shipping address, and your credit or debit card, or other financial account information.
- Subscription to Email Communications: if you subscribe to receive email communications from us, including newsletters and promotional emails.
- Communication with Us: we collect any information you provide when you communicate with us via phone, email, web chat, fax, or through any online “contact us” form.
- Comments: if any of our sites allow you to post comments or other content to sections of our sites. Please be aware that, upon submission, all content approved for publication on our sites will be available to other registered users of that sites, and that your content may be collected, used, and shared outside of our control.
We may combine information you submit through our sites and mobile applications with other information we have collected from you, whether on-line or off-line. We treat the combined information in accordance with this Privacy Statement.
1.2 Use of Personal Information
We only use the Personal Information for the purposes for which you have agreed to and/or expressly consented.
- to respond to your inquiries and fulfill your requests;
- to send you important information regarding our relationship with you or regarding our sites (such as changes to our terms, conditions, and policies, and other administrative information);
- to provide you with access to our sites or mobile applications, as requested by you;
- if you choose to complete a survey or questionnaire, we may use the information to evaluate your feedback from the survey or questionnaire;
- if you purchase goods or services via our sites, we may use your Personal Information to process your transaction and send you the item(s) that you purchased. We may also use your information to process returns and to collect any amounts owed to us.
- if you subscribe to receive promotional communications, we may use Personal Information to promote our products and services;
- for our business purposes, such as data analysis, audits, recordkeeping, developing new products or services, enhancing or improving our services, identifying usage trends, personalising your experience on our sites or mobile applications, and determining the effectiveness of our promotional campaigns;
- if necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain; and
- if we intend to collect and use Personal Information for another purpose, we may seek your permission at the time the information is collected.
We may use any information that does not personally identify you, your computer, or your device, for any purpose.
1.3 Disclosure of Personal Information
Your Personal Information may be disclosed for the following purposes:
- to our agents, representatives, contractors, and service providers so they can provide us with support services.
- as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
- As described in Section 5 below, “Disclosure to Our Partners.”
- otherwise, with your consent.
2. Sensitive Information – Collection, use and disclosure
Netura may also, in some circumstances, collect and use Sensitive Information that you voluntarily provide to us which requires greater restrictions, such as if you agree to participate in clinical trials, questionnaires or research.
Our use of your Sensitive Information is to enhance your ability to make informed decisions about your health care. If you agree to provide us with Sensitive Information, it will be used for Netura’s internal statistical or business purposes only, unless you expressly consent otherwise.
We do not disclose your Personal or Sensitive Information to our partners unless you have expressly consented to such disclosure; it has been de-identified; or if it is directly related to the primary purpose for which it was collected.
2.1 Healthcare Professionals
If you are a healthcare professional and you are using a Netura service in the provision of medical or professional healthcare services, it is your sole responsibility to obtain express consent from your patients to use their Personal Information.
3. Non-Personal (or Passive) Information – Collection, use, disclosure and choices
We may collect information about your web behaviour such as your IP address, browser type, URLs of the websites you access from our website and details of the webpages you visit (see Interest-based Advertising below), as well as other software and hardware information that may be available. This information is automatically provided to us by your web browser without revealing to us your identity or any other Personal Information. This is done in the following ways:
3.1 IP Addresses
An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet. When you visit our sites, we may view the IP address of the device you use to connect to the Internet. We use this information to determine the general physical location of the device and understand from what geographic regions our website visitors come. We also may use this information to enhance our sites or mobile applications.
3.2 Through your browser
Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and Internet browser type and version.
3.3 Social Media Widgets
Our sites may include social media tools, including social media widgets or plug-ins, to connect you to our social media pages. These features may set a cookie or use other automatic collection and tracking technologies to collect information about you and your use of the social media features through and in connection with our sites. These social media tools may be hosted by a third party. Your interactions with these tools and the corresponding social media platforms are governed by the privacy policies of the companies that provide such platforms.
We may provide Non-Personal Information to our partners, who may use it to understand how often and in what ways you use our websites and services so that they too can provide you with an optimal experience. We never disclose Non-Personal Information to a partner in a manner that would identify you personally.
4. More about Cookies and other technologies
When you visit our websites, non-personally identifiable information in the form of a “cookie” may be stored on your computer enabling automatic user recognition for when you next visit our sites or mobile applications. Cookies allow us, for example, to adapt a website to your interests or to store your location, to save you from having to re-enter the information each time you visit.
Some cookies are essential whilst others help us improve your experience. Essential cookies help make our sites and mobile applications usable by enabling basic functions like page navigation and access to secure areas. Our sites and mobile applications may not function properly without these cookies. Some other cookies may help us to comply with legal requirements like the EU’s GDPR (privacy) such as managing your consents, requests and company data.
- session, persistent and third-party “cookies” that store a small piece of data on your computers and collect certain information about your visit to our sites and mobile applications
- web beacons (either directly or from our partners), along with cookies, to determine you have visited a particular website. These beacons assist us to provide you with more relevant advertising, but we do not use data collected by cookies to identify who you are.
The cookies and web beacons we use collect non-personally identifiable information about you including: IP address, browser used to access the site, date and time, the URL of the page being loaded, users who have visited a particular website(s), any previously assigned cookie identification (a unique identifier assigned to a user to identify repeat visitors), browser window size, your geographic location, device and operating system used to access our sites or mobile applications. The information we collect from these cookies and web beacons is used to:
- Determine information about your visit to our sites, including the number of visits, average time spent, pages viewed, navigation history and other statistics. We use this information to enhance your experience while visiting our sites and mobile applications; and to improve their performance by, among other things, allowing us to monitor performance, making them easier to use, measuring the effectiveness of promotional placements, and tailoring them (including the ads and offers you receive) to better match your interests and preferences.
- Select which of our advertisements or offers are most likely to appeal to you and display them while you are on the sites and on other websites, applications, and online services that you use; and
- Track consumer responses to online advertisements.
You will also find details of how to delete cookies from your computer and other general information about cookies. You should note, however, that turning off cookies may prevent some of our websites or mobile application features from working properly.
4.3 Google Analytics
The Netura website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). This tool helps us understand how visitors engage with our website. Netura as a Google Analytics customer can view various reports on how visitors interact with our website. This allows us to make improvements based on the information generated by the tool.
You can prevent transmission of the data generated by the cookie and relating to your use of the website to Google (including your IP address) as well as processing of the data by Google by downloading and installing the browser plug-in available: http://tools.google.com/dlpage/gaoptout?hl=en
4.4 Location Information
When you are using Netura websites, your location information may be used to tailor our products or service offerings to your current location. Your mobile device’s ‘background location’ may be used to provide the services, including to send you notifications. If you have ‘background location’ turned on, we may gather information about your device’s location even if you are not directly interacting with the application. This information is not shared with others.
If you do not wish for your location to be accessed, please ensure you turn the ‘background location’ off on your mobile device.
4.5 Interest Based Advertising
We work with third-party advertising companies and networks to display ads online or on mobile applications. These ads are tailored to your individual interests based on how you use our sites, and the other websites and online services that you use. Note that these advertisements may be delivered to you on our sites, on third party websites and applications, and on a computer or device other than the device from which the information was collected.
This is called “Interest-Based Advertising” or “Online Behavioural Advertising.”
For mobile advertising, you may use your phone operating systems opt-out setting (For instructions on how to “Limit Ad Tracking” on iOS, please visit this Apple Support Document; For instructions on how to opt out of interest-based ads on Android, please visit these instructions); and
If you would like, you can discontinue using our sites.
If you use more than one device, you should renew your opt-out choices on each such device.
5. Disclosure to our partners
We may disclose your Personal Information or Non-Personal Information if we are required to do so by law, including in connection with any legal proceedings or anticipated legal proceedings, or to comply with any legal obligation, or to establish, exercise or defend our legal rights.
We may also sell, transfer, or disclose our database of Personal Information, Non-Personal and Health Information to an actual or potential successor entity, purchaser, or investor in connection with significant structural transactions involving Netura: a corporate merger, consolidation, sale of our assets or substantially all our assets, share sale, investment transaction or other corporate rearrangement.
We use up to date server, database, backup and firewall technologies for the protection of all information we hold. We have also implemented various processes and systems to ensure the security of your Personal Information, including encryption of all data when it is transferred to our service providers and limitations on access to Personal Information within our organisation.
In the event of a data breach, Netura will notify the relevant regulators within 72 hours and, in serious cases such as where there is a high risk to your rights and freedom (such as of security, confidentiality or identity theft), we will also notify you as soon as is reasonably possible.
7. Links to, and information on, other websites
Netura owns and manages websites that may contain links to other websites. Please note that Netura is not responsible for the compliance with data protection regulations by third-party providers or the contents of such websites, and we are not in any way liable for how these third parties collect, hold, use or disclose your Personal Information.
8. Disclosure of Personal Information to overseas recipients
9. Contacting us (including to correct or delete your data)
We will take all reasonable steps to ensure that information we hold about you is accurate, complete, relevant, up-to-date and not misleading on a regular and ongoing basis.If you would like to obtain access to, correct or request deletion of information we hold about you, please contact our Privacy Officer by completing an online enquiry form or:
BY MAIL: To the Netura Privacy Officer, 4/8 Alvan Street, Subiaco, Perth, Western Australia 6008
BY TELEPHONE: +61 8 9474 1777
BY EMAIL: to firstname.lastname@example.org
9.1 EU Residents
If you reside in the EU, you may request to:
- have your data permanently deleted (the right to be forgotten) or ported (the right of data portability)
- that we provide you with a copy of your data in a format that will enable you to provide it to another company.
If you wish to make a complaint about how we handle your Personal Information or Non-Personal Information, you can email our Privacy Officer (or Data Protection Officer if you are an EU resident) at email@example.com.
Please provide as much detail about the facts surrounding your complaint so we can resolve it accordingly. Allow us at least 7 days to respond to your complaint.
If we fail to resolve your complaint, you may refer the matter to the Australian Information Commissioner (see http://www.oaic.gov.au), or the supervisory authority in the Member State of your habitual residence, place or work or place of the alleged infringement.
11. Data Retention
We only retain your data for as long as is necessary for us to provide the goods or services you have requested or to which you have given consent, unless otherwise provided by law.