Privacy Policy
This Privacy Policy, along with Clinic Terms and Conditions and Patient Terms of Use, governs the relationship between any healthcare clinic (Clinic) or patient of a Clinic (Patient) and Rebookr Pty Ltd ACN 693 645 064 (Rebookr) when browsing, accessing or otherwise using rebookr.com.au (and all related URLs or derivations thereof) (Website), the Rebookr platform (Platform), or any SMS-based appointment booking and messaging services to Patients operated by Rebookr on behalf of Clinics (SMS Services) or any data or content from the Website, Platform or SMS Services.
1. Compliance with Australian Privacy Principles
1.1 Rebookr respects and acknowledges the importance of privacy. Rebookr complies with the Australian Privacy Principles (APP) as contained within the Privacy Act 1988 (Cth) (Act), when collecting, using, disclosing and managing a Patient’s personal information.
1.2 This Privacy Policy contains information in relation to our management of personal information in accordance with the APP.
1.3 For the purposes of this Privacy Policy, the terms “personal information” and “sensitive information” have the meaning given to them in the Act.
1.4 Please read this Privacy Policy carefully.
2. Age requirements and parental consent
2.1 Rebookr is designed to support individuals aged 18 years and over. Where a Clinic’s patient base includes individuals under 18, the Clinic is responsible for ensuring that Rebookr does not process the information of minors.
2.2 If we become aware that we have inadvertently collected personal information from a Patient under 18, we will take reasonable steps to delete such information.
3. Use of personal information
3.1 Rebookr may collect and use Patients’ personal information for a variety of reasons, which may include but is not limited to the following:
- to identify Patients without future appointments by scanning Clinic databases to identify Patients without future appointments;
- to send automated personalised SMS messages to Patients on behalf of Clinics, encouraging them to re-engage and book follow up appointments;
- to present real-time available appointment slots from a Clinic’s live diary and allow Patients to confirm appointments via SMS Services;
- to detect security issues and prevent fraud on the Website, Platform and/or SMS Services;
- to request feedback on a Clinic’s or Patient’s experience with Rebookr;
- to provide analytics and reporting to the Clinic;
- to provide a Clinic or Patient with support in relation to the Website, Platform and/or SMS Services;
- to enable a Clinic or Patient to access and use the Website, Platform and/or SMS Services;
- to manage and minimise risks and identify or investigate fraud and/or other illegal activities;
- to respond to a Clinic or Patient’s enquiries which include the processing of complaints made to Rebookr;
- to resolve disputes, to collect fees and to troubleshoot problems;
- to enforce our Clinic Terms and Conditions and Patient Terms of Use;
- to deliver targeted marketing and various other notices and promotional communications based on a Clinic or Patient’s selected communication preferences;
- to protect Rebookr and its assets (including against fraud) and to sell Rebookr assets (including any assignment of debts);
- to enforce Rebookr’s rights (including undertaking debt collection) in connection with the Website, Platform and/or SMS Services;
- monitoring data, usage, records and statistics derived from a Clinic or Patient’s use of the Website, Platform and/or SMS Services for the furtherance of Rebookr’s business, the development of its services, for general market research and to be disclosed to third parties in relation to the aforementioned;
- to contact a Clinic or Patient through the use of various means e.g. telephone, text (SMS) or email messaging, advertising through the Website, third-party websites, mail, and/or any other means as authorised by our membership terms and conditions;
- Rebookr’s business development, including sending of updates and publications;
- to manage and deliver contextual and behavioural advertising; or
- in order for Rebookr to comply with legal and regulatory obligations.
4. Artificial intelligence and automated systems
4.1 Rebookr uses artificial intelligence (AI) and machine learning technology to identify patients who may benefit from re-engagement and to generate personalised appointment booking messages on behalf of Clinics.
4.2 AI outputs are used solely for scheduling and administrative purposes and do not constitute clinical recommendations or medical advice.
4.3 All AI-generated communications are sent on behalf of and under the authority of the Clinic.
5. Collection of personal information
5.1 Rebookr collects personal information through a variety of methods, which may include the following:
- directly from a Clinic or Patient in instances where the Patient interacts with appointment booking or messaging systems operated on behalf of a Clinic;
- from a Clinic through integrations with their practice management systems, including by scanning databases to identify Patients without future appointments;
- through authorised data transfers from Clinics required to operate Rebookr’s services;
- through a Clinic or Patient’s access of surveys commissioned by Rebookr;
- when a Clinic or Patient subscribes to receive information from Rebookr;
- when a Clinic or Patient communicates with Rebookr, by email, post or otherwise;
- through publicly available information; or
- through financial service providers used when processing payments.
5.2 In the event that Rebookr is unable to obtain personal information from a Clinic or Patient as outlined above, this may result in Rebookr being unable to provide a Clinic or Patient with access to the Website, Platform or SMS Services.
6. Types of personal information and storage
6.1 The type of personal information that Rebookr may hold includes the following:
- identification information including a Patient’s name, date of birth, gender, phone number, address, email address, and other contact information;
- appointment history, including dates, preferred practitioners and treatment types;
- communications records, including SMS messages sent and received on behalf of Clinics;
- a Clinic or Patient’s approximate physical location of the devices a Clinic or Patient uses to access the Website, Platform or SMS Services;
- a Clinic or Patient’s IP address and other device identifiers, including mobile advertising identifiers;
- aggregate, anonymous, or de-identified non-personal data;
- any other information provided by a Clinic or Patient in using the Website, Platform or SMS Services; and
- other information that helps us to identify a Clinic or Patient or helps us to provide or improve the Website, Platform or SMS Services.
6.2 The personal information referred to in clause 5.1 above may be held by Rebookr in both hardcopy files and also in an electronic form.
7. Health information
7.1 Rebookr acknowledges that appointment data relating to consultations with allied health professionals (such as psychologists, physiotherapists, occupational therapists and speech therapists) may constitute “health information” as defined in the Act.
7.2 Rebookr does not collect or require detailed clinical or medical records and minimises its collection of health information.
7.3 Where health information is incidentally received, Rebookr will handle it in accordance with the enhanced protections applicable to sensitive information under the APP.
8. Sensitive information
8.1 Rebookr does not intentionally collect sensitive information (as defined in the Act) directly from Patients.
8.2 If sensitive information is inadvertently received by Rebookr, it will be handled in accordance with APP and deleted or de-identified where it is not reasonably necessary for the provision of the Services.
9. Disclosure of personal information
9.1 Rebookr may be required to disclose a Clinic or Patient’s personal information to the following third parties:
- external service providers so that the third party can carry out the service that they have been provisioned for;
- our partners and the suppliers and service providers who help with our business operations including in relation to fraud prevention, identity verification, payment collection, marketing, customer service, and technology services;
- organisations that provide applications, websites, services, goods, software, programs used by Rebookr;
- third parties that may provide Rebookr with marketing or analytics reports;
- our professional advisors, including our accountants, lawyers, business advisors and consultants;
- organisations and/or individuals that Rebookr intends on entering negotiations with for any merger, sale of assets, financing, acquisition of all or a part of Rebookr’s business; or
- any legal or industry regulatory body in any of the states, territories and jurisdictions that Rebookr operates in.
9.2 Rebookr may be required to disclose a Clinic or Patient’s personal information in order to respond to subpoenas, court orders, or to investigate, prevent, defend against, or take action regarding violations of our Clinic Terms and Conditions, Patient Terms of Use, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network, customers/users or services.
9.3 If a Clinic purchases services from Rebookr, our third-party payment processor will collect the billing and financial information it needs to process a Clinic’s charges. This may include a name, address, e-mail address, and financial information. For the avoidance of doubt, such financial information (including bank account details or credit card numbers) is held solely by the third-party payment processor and is not directly stored or accessed by Rebookr.
9.4 When a Clinic or Patient accesses Rebookr’s services through the normal usage of our Platform or SMS Services, Rebookr may use a Clinic or Patient’s personal information for one or more of the purposes listed in clause 3.1 and Rebookr will handle personal information in accordance with this Privacy Policy.
9.5 Where the Act permits, Rebookr may also disclose personal information to third party suppliers and service providers located overseas for some of the purposes listed above.
10. Third-parties and sub-processors
Rebookr may use trusted third-party providers such as cloud infrastructure hosting providers, including but not limited to Amazon Web Services data centres located in Sydney, Australia, messaging providers and analytics services in order to deliver our SMS Services.
Rebookr designs its systems and internal processes in alignment with recognised information security and quality management frameworks, including ISO 27001 (Information Security Management Systems) and ISO 9001 (Quality Management Systems).
11. Cross-border disclosure of personal information
11.1 Rebookr may, from time to time, have affiliated offices operating in overseas locations. Rebookr may send a Clinic or Patient’s personal information to these offices for one or more of the purposes listed in clause 3.1. If Rebookr’s overseas offices are operated by ‘related body corporates’ of Rebookr, Rebookr will take such steps as reasonably required to ensure that there is appropriate data handling of personal information and proper security arrangements are in place.
11.2 From time to time, Rebookr may also send a Clinic or Patient’s personal information overseas for the following reasons:
- to third party service providers who store data or operate outside of Australia;
- to complete a transaction involving an international financial institution; or
- as required by laws and regulations of Australia or another country.
11.3 Before Rebookr discloses personal information about a Clinic or Patient to an overseas recipient who is not a related entity, Rebookr will take such steps as reasonably required to ensure that there is appropriate data handling of personal information and proper security arrangements are in place.
12. Marketing opt-out
12.1 Rebookr may, from time to time, contact Clinics for marketing and promotional purposes via email, mail, telephone or otherwise. The parties acknowledge that a Clinic’s consent is provided on an ongoing basis for such contact, unless its rights to opt out in accordance with this clause 12 have been exercised.
12.2 In the event that a Clinic no longer wishes to receive any promotional or marketing mail or communication from Rebookr, please let us know and we will cease any correspondence or contact relating to these purposes.
12.3 A Clinic may opt out from receiving any electronic marketing and promotional communication by following the unsubscribe instructions within any electronic communication that have been received from Rebookr. Additionally, a Clinic may opt out from such communication by contacting The Privacy Officer in writing (the details of which are contained at clause 16).
12.4 Unsubscribe or opt out requests originating from electronic communications shall be honoured within 14 days of any such request.
12.5 Any election made to not receive promotional and marketing correspondence from Rebookr will not preclude Rebookr from any of the following:
- contacting a Clinic or Patient regarding an existing or past relationship with Rebookr;
- accessing and viewing a Clinic or Patient’s personal information in the course of maintaining and improving Rebookr’s database and internal systems; or
- otherwise using a Clinic or Patient’s personal information in accordance with this Privacy Policy.
12.6 Rebookr sends automated SMS messages to Patients on behalf of Clinics for the purpose of facilitating appointment rebooking. These messages are to be sent in accordance with the Spam Act 2003 (Cth). Consent for these messages is obtained by the Clinic as part of its Patient intake process.
12.7 For the avoidance of doubt, SMS messages sent to Patients on behalf of Clinics for the purpose of appointment rebooking are not marketing communications and are not subject to this clause.
13. Cookies
13.1 Cookies are used by Rebookr in order to maximise and enhance our user experience.
13.2 When accessing the Website or Platform, small files of data may be placed on a Clinic or Patient’s device that enable Rebookr to recognise the Clinic or Patient as a Rebookr user each time they return to the Website. As a result of these cookies, Clinics or Patients avoid the need to keep inputting information throughout a session and may have these details auto filled in the Website. In addition, these cookies enable Rebookr to ascertain information regarding what web pages a Clinic or Patient visits and how regularly, enabling us to make the Website, Platform and SMS Services increasingly user friendly and to target advertising to content that a Clinic or Patient may be interested in.
13.3 A Clinic or Patient is free to decline the cookies which Rebookr utilises and can disable them through the web browser. Please note that declining or disabling cookies may affect the user experience and may render certain features inoperable.
14. Protection of personal information
14.1 Rebookr will take all reasonable steps to ensure that a Clinic or Patient’s personal information is properly protected from misuse, loss, unauthorised access, modification or disclosure.
14.2 If we become aware of an Eligible Data Breach, as defined in the Privacy Act, affecting personal information, Rebookr will notify the Clinic and affected Patients without undue delay and cooperate with obligations under the Notifiable Breaches scheme.
14.3 Rebookr stores a Clinic or Patient’s personal information in a way that reasonably protects it from unauthorised access, misuse, loss, modification or disclosure. When a Clinic or Patient’s personal information is no longer required for the purposes for which it was collected (including, but not limited to termination of the provision of SMS Services with a Clinic), Rebookr will take reasonable steps to destroy and anonymise or de-identify it. Notwithstanding this, most of the personal information that is stored in Rebookr client files and records is retained in accordance with applicable laws and regulatory requirements.
15. Confidentiality
Rebookr will maintain the confidentiality of personal information received from Clinics or Patients in connection with the provision of its SMS Services.
16. Accessing and requesting correction of personal information
16.1 The APP:
- permits a Clinic or Patient to obtain access to the personal information we hold about them in certain circumstances (APP 12); and
- allows a Clinic or Patient to correct inaccurate personal information subject to certain exceptions (APP 13).
16.2 Patients seeking access to, or correction of, their personal information should contact their Clinic in the first instance. Rebookr will assist Clinics in responding to such requests where required.
16.3 If required to be escalated to Rebookr directly, please contact the Privacy Officer at: Attention: The Privacy Officer, by email support@rebookr.com.au.
16.4 In the event that a Clinic or Patient requests access to personal information, Rebookr will endeavour to respond to that request as soon as reasonably practicable if and to the extent required by the applicable law.
16.5 If Rebookr is unable to give a Clinic or Patient access, or if Rebookr declines to amend a Clinic or Patient’s personal information, Rebookr will issue a written notice that describes our reasoning for doing so.
16.6 A Clinic or Patient may request the deletion of their account and personal information, subject to our legal obligations to retain certain data.
16.7 Rebookr reserves the right to make an administrative charge to a Clinic or Patient if it is required, to provide a Clinic or Patient with access to personal information as outlined in clauses 16.3 and 16.4 above.
17. Resolving a Clinic or Patient’s concerns
17.1 If a Clinic or Patient wishes to make a complaint regarding the way in which Rebookr manages their personal information, or that a Clinic or Patient feels that Rebookr has fallen short of the required standards set by the Act, please prepare the complaint in writing and supply it to The Privacy Officer.
17.2 A written acknowledgement of the complaint will be provided within 14 days, and Rebookr will attempt to have the concern resolved within 30 days of receipt of the complaint.
17.3 If a Clinic or Patient is not satisfied with the way the complaint has been handled and/or resolved, the Clinic or Patient may lodge a complaint with the Office of the Australian Information Commissioner via www.oaic.gov.au.
18. Access to Privacy Policy
18.1 This Privacy Policy is publicly available, free of charge through the Website.
19. Change to Privacy Policy
19.1 This Privacy Policy may change from time to time as required by Rebookr to reflect legislative and other changes. Such changes will take effect from the date of publication on the Website. We recommend it is reviewed regularly.