Privacy Policy

Current as of 1 January 2026.

INTRODUCTION

This document sets out the privacy policy of Clinrol Pty Ltd ABN 29 640 485 105. In this privacy policy, we to refer ourselves as 'we', 'us', or 'our'.

For the purposes of applicable data protection law, including the Privacy Act 1988 (Cth), the General Data Protection Regulation (EU) 2016/679 (GDPR), the UK Data Protection Act 2018, and relevant United States state privacy laws (including the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)), your data will be controlled by us.

This privacy policy applies whenever we collect your personal information and/or personal data (your personal data). This includes between you, the visitor to this website (whether directly as our customer or as personnel of our customer), and us, the owner and provider of this website and also where we are directed by a third party to process your personal data. This privacy policy applies to our use of any and all data collected by us or provided by you in relation to your use of the website and the provision of our services to you, including the usage of any of our venues, hotels and pubs.

We take our privacy obligations seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

TYPES OF PERSONAL INFORMATION WE COLLECT

The personal data we collect may include the following:

  • name;
  • mailing or street address;
  • email address;
  • social media information;
  • telephone number and other contact details;
  • age;
  • date and country of birth;
  • credit card or other payment information;
  • government issued identification documents such as driver's licence and/or passport;
  • sensitive information (such as health information) as set out below;
  • information about your business or personal circumstances;
  • information in connection with any client surveys and questionnaires you complete;
  • when we use analytical cookies, your device identity and type, I.P. address, geo-location information, page view statistics, advertising data and standard web log information;
  • information about third parties; and
  • any other information provided by you to us via this website, in the course of us providing services to you, or otherwise required by us or provided by you.

HOW PERSONAL INFORMATION IS COLLECTED

General

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 data where you:

  • contact us through on our website;
  • complete screening and pre-screening questionnaires to determine your eligibility and preferences;
  • communicate with us via email, telephone, SMS, social applications (such as Instagram, LinkedIn or Facebook) or otherwise;
  • sign-in to any of our premises using scanning of your identification;
  • enter our premises and provide us with your details;
  • enter our premises which are monitored by CCTV surveillance;
  • use our venue, consume our food or beverage, or use services provided by third parties at our venues such as ordering applications;
  • engage us to perform services to you;
  • when you or your organisation offer to provide, or provides, services to us;
  • interact with our website, social applications, services, content and advertising; and
  • invest in our business or enquire as to a potential purchase in our business.

For security reasons, we may require that each of our patrons provide us with copies of their valid, government-issued ID, such as a valid driver's license, a passport or an identity card.

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, including other health service providers we receive referrals from and provide referrals to.

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.

If you are providing personal and/or sensitive information on behalf of someone under the age of 18 (Minor), you must be that Minor's parent or legal guardian and you must provide consent for the Minor's personal and/or sensitive information 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 to collect and process data, including when you use third party websites or apps. To find out more see How Google uses data when you use our partners' sites or apps.

USE OF YOUR PERSONAL INFORMATION

Primary purpose

We collect and use personal information for the following primary purposes:

  • to provide services or information to you;
  • for record keeping and administrative purposes;
  • to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;
  • where we have your consent, including to send you marketing and promotional messages and other information that may be of interest to you. In this regard, we may use email, SMS, social media or mail to send you direct marketing communications. You can opt-out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link);
  • for our legitimate interests including:
    • to develop and carry out marketing activities and to conduct market research and analysis and develop statistics;
    • to improve and optimise our service offering and customer experience;
    • to send you administrative messages, reminders, notices, updates and other information requested by you;
    • to consider an application of employment from you; and
    • the delivery of our services.

Secondary purpose

We may also use your personal information for:

  • secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use;
  • any other purpose for which we receive consent from you; or
  • any other purpose which is permitted or required under applicable privacy laws.

HOW WE DISCLOSE OR SHARE YOUR DATA

We may share your personal data in certain circumstances, as follows:

  • where there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal data and non-personal data contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances;
  • credit-checking agencies for credit control reasons;
  • disclosures required by law or regulation; and
  • service providers and other affiliated third parties to enable us to provide our services to you including other professional advisers such as accountants, disaster recovery service providers or auditors and/or overseas counsel.

SENSITIVE INFORMATION

Collection of sensitive information

We may collect sensitive information about you during the course of providing you our goods and services.

The type of sensitive information we may collect includes:

  • health information such as medical history, current and previous diagnosis, medication history and other health records; and
  • 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:

  • responding to your queries;
  • providing you with our goods and services;
  • ensuring proper usage of our facilities and venues;
  • security purposes;
  • complying with our legal, regulatory and ethical obligations, resolving disputes or enforcing our agreements with you;
  • sending you messages, reminders, notices, updates, security alerts, and other information requested by you; or
  • any other purpose which is permitted or required under applicable privacy laws.

How we disclose your sensitive information

If you consent, your sensitive information may only be used and disclosed for purposes relating to providing you with our services, data analytics and/or referring you to medical or health service providers.

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.

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:

  • have explicitly opted-in to receiving email marketing from us in the past; or
  • 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.

DE-IDENTIFIED INFORMATION

The information we collect may have analytical, educational, or commercial value to us. Where we have de-identified the information we have collected, we reserve the right to process and distribute the information such information.

SECURITY

We take reasonable steps to ensure your personal data is secure and protected from misuse or unauthorised access. Our information technology systems are password protected, and we use a range of administrative and technical measures to protect these systems. However, we cannot guarantee the security of your personal data.

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.

YOUR RIGHTS

You have various rights with respect to our use of your personal data:

  • Access: You have the right to obtain access to your information (if we're processing it) and certain other information (similar to that provided in this privacy notice). This is so that you're aware and can check that we're using your information in accordance with data protection law.
  • Be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we're providing you with the information in this privacy policy.
  • Rectification: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us using our contact form to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.
  • Objecting: You also have the right to object to processing of your personal data in certain circumstances, including processing for direct marketing.
  • Restricting: You have the right to 'block' or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further.
  • Erasure: You have the right to ask us to erase your personal data when the personal data is no longer necessary for the purposes for which it was collected, or when, among other things, your personal data have been unlawfully processed.
  • Portability: You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format.
  • Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority. In the UK, the supervisory authority is the Information Commissioner's Office.
  • Withdraw consent: If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time. This includes your right to withdraw consent to us using your personal data for marketing purposes.

You may, at any time, exercise any of the above rights, by contacting our email address provided below.

HOW LONG WE KEEP DATA

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will securely destroy your personal data in accordance with applicable laws and regulations.

If you would like further information about our specific retention periods for your personal data, please contact us using our email address provided below.

TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA ('EEA')

To provide our services, we may transfer the personal data we collect to countries outside of the UK or EEA which do not provide the same level of data protection as the country in which you reside and are not recognised by the European Commission as providing an adequate level of data protection.

When we do this, we will make sure that it is protected to the same extent as in the EEA and UK as we will put in place appropriate safeguards to protect your personal data, which may include standard contractual clauses.

For more information, please contact us at our email address provided below.

COMPLAINTS

If you wish to complain about how we handle your personal information or 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 time.

For data which is subject to the GDPR, you have the right to lodge a complaint with the local regulator in your jurisdiction in Europe if you do not feel we have adequately upheld your rights under GDPR.

If you are located in Australia, you have the right to contact the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au/contact-us if you believe that your data has not been handled in accordance with the law.

If you are located in the United Kingdom, you have the right to contact the Information Commissioner's Office (ICO) at www.ico.org.uk if you believe your data has not been handled in accordance with the law.

UNITED STATES RESIDENTS (INCLUDING CALIFORNIA PRIVACY RIGHTS)

If you are a resident of the United States, including the State of California, certain additional rights may apply to you under applicable state privacy laws such as the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and other state laws including those in Virginia, Colorado, Connecticut and Utah.

YOUR RIGHTS

Subject to certain exceptions, US residents may have the following rights:

  • To know the categories and specific pieces of personal information we collect about you, including the sources, purpose for collection and any third parties to whom the information is disclosed
  • To request deletion of your personal information, subject to legal or contractual obligations requiring us to retain it
  • To request correction of inaccurate personal information
  • To request that we do not sell or share your personal information for advertising or marketing purposes
  • To request that we limit the use and disclosure of any sensitive personal information we hold about you
  • To be free from discrimination or retaliation for exercising any of your privacy rights

You may exercise these rights by contacting us at info@clinrol.com. We may need to verify your identity before responding to your request.

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

In the past twelve (12) months, we may have collected the following categories of personal information about you:

  • Identifiers (such as name, email address, phone number, mailing address, or online identifiers)
  • Internet or network activity (such as website browsing history, cookies and analytics data)
  • Commercial information (such as records of products or services purchased or considered)
  • Professional or employment-related information (if you apply for a position or provide services)
  • Geolocation data (if collected through cookies or analytics)
  • Sensitive information (such as health information where applicable, or government-issued identification)

We collect this information directly from you, from your use of our website or services, from social media or marketing partners, and from service providers who assist us in operating our business.

HOW WE USE PERSONAL INFORMATION

We use and disclose personal information as described in Sections 4 and 5 of this Privacy Policy. This includes providing services, maintaining security, performing analytics, improving our products and communications, and complying with legal obligations.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose personal information to service providers, business partners, or other entities as necessary to operate our business, consistent with the purposes set out in this Privacy Policy. We do not "sell" personal information as defined under the CCPA. However, we may share limited personal data with third parties for marketing, analytics, or operational purposes, which may be considered "sharing" under the CCPA.

YOUR RIGHT TO OPT OUT

You can opt out of the sale or sharing of your personal information for advertising or analytics purposes at any time by contacting us at info@clinrol.com with the subject line "Do Not Sell or Share My Personal Information". Once your request is verified, we will apply your preference as required by law.

DATA RETENTION

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The length of time we retain data may vary depending on the type of information and the nature of our relationship with you.

CONTACT US

For further information about our privacy policy or practices, or to access or correct your personal data, or make a complaint, please contact us using the details set out below:

Email: info@clinrol.com

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. Where we make any significant changes, we will endeavour to notify you by email.