PRIVACY POLICY

Last Updated: [DATE]

1. Introduction

Welcome to [BUSINESS/WEBSITE NAME] ("we", "us", "our").

This Privacy Policy explains how we collect, use, store, disclose and protect personal information when you visit [WEBSITE URL], use our website, complete one of our quizzes, request information from us, subscribe to our email communications, interact with our content, or otherwise communicate with us.

Because some of our quizzes and content relate to oral health and gum care, information you provide may include information that could be considered health information, sensitive personal information or special category personal data under certain privacy laws.

We take the privacy of this information seriously.

This Privacy Policy is intended to provide information to visitors and users regardless of whether they are located in Australia, the United States, the United Kingdom or another country.

However, the privacy rights that apply to you may depend on where you live and the laws that apply to our activities.

By using our website or voluntarily providing information to us, you acknowledge that you have read this Privacy Policy.

2. Who We Are

The website and services covered by this Privacy Policy are operated by:

Business/Legal Name: [LEGAL BUSINESS NAME]
Trading Name: [TRADING NAME, IF DIFFERENT]
Website: [WEBSITE URL]
Email: [PRIVACY EMAIL ADDRESS]
Business Address: [BUSINESS ADDRESS OR REGISTERED BUSINESS ADDRESS]
Country: Australia

For privacy-related questions, requests or complaints, please contact us at:

[PRIVACY EMAIL ADDRESS]

3. What Information We Collect

We collect information that you voluntarily provide to us, information generated when you use our website, and information that may be collected automatically through cookies, analytics and advertising technologies.

The information we may collect includes the following.

3.1 Information You Provide Directly

Depending on how you interact with our website, we may collect:

  • Your first name and/or last name

  • Email address

  • Contact information

  • Quiz answers

  • Information about your gum-care goals

  • Information about your oral-health concerns that you choose to provide

  • Communications you send to us

  • Information you provide when requesting support

  • Preferences relating to the information and communications you receive from us

You do not generally need to provide your name or email address simply to browse our website.

However, an email address may be required if you want to receive quiz results, recommendations, educational information or other communications from us.

4. Health-Related Information

Some of our quizzes ask questions relating to gum care, bleeding gums, oral-health concerns, symptoms, habits or goals.

Depending on the answers you provide, this information may be considered health information or sensitive/special category personal information under applicable privacy laws.

For example, information you voluntarily provide may indicate that you:

  • experience bleeding gums;

  • have concerns about the appearance of your gums;

  • are concerned about gum health;

  • have particular oral-care habits;

  • are interested in improving your gum-care routine; or

  • have other oral-health concerns.

We collect this information only when you choose to provide it through our website or related services.

We do not intend for our quiz to collect complete medical records, dental records, diagnoses, prescriptions or other detailed medical information.

Please do not provide information that we do not request.

In particular, please do not submit:

  • medical records;

  • dental records;

  • prescription information;

  • insurance information;

  • government identification numbers;

  • financial information;

  • information about another person; or

  • other highly sensitive information that is not specifically requested.

5. How We Collect Information

We may collect information through:

Information you provide

For example, when you:

  • complete a quiz;

  • enter your email address;

  • subscribe to our email list;

  • request information;

  • contact us;

  • respond to an email; or

  • otherwise communicate with us.

Automatically collected information

When you visit our website, certain information may be collected automatically, including:

  • IP address;

  • approximate geographic location;

  • browser type;

  • device type;

  • operating system;

  • referring website;

  • pages visited;

  • links clicked;

  • approximate time spent on pages;

  • date and time of visits;

  • website interaction information; and

  • other technical information reasonably necessary to operate, secure and improve our website.

Cookies and similar technologies

We may use cookies, pixels, tags, scripts and similar technologies to:

  • operate our website;

  • remember preferences;

  • understand how visitors use our website;

  • measure advertising performance;

  • understand conversions;

  • improve our website;

  • detect fraudulent or abusive activity; and

  • support our marketing and advertising activities.

6. How We Use Your Information

We may use information we collect for the following purposes:

Providing our website and services

To:

  • operate our website;

  • provide quiz functionality;

  • provide quiz results;

  • provide recommendations based on quiz responses;

  • respond to inquiries;

  • provide customer or technical support; and

  • communicate with you about your requests.

Email communications

If you provide your email address and consent where required, we may use it to send:

  • your requested quiz results;

  • educational information;

  • information relating to gum care and oral care;

  • product information;

  • recommendations;

  • promotional communications;

  • updates;

  • offers; and

  • other communications that may be relevant to your interaction with us.

You can unsubscribe from marketing emails at any time by using the unsubscribe link included in our emails or by contacting us.

7. Marketing and Advertising

We may use information about how visitors interact with our website to measure and improve our advertising and marketing activities.

This may include the use of advertising and analytics technologies provided by third parties such as:

  • Google;

  • Meta/Facebook;

  • [OTHER ADVERTISING PLATFORM];

  • [ANALYTICS PROVIDER]; and

  • [OTHER TRACKING PROVIDERS].

These technologies may use cookies, pixels or similar technologies to help us understand:

  • how visitors arrive at our website;

  • whether an advertisement resulted in a visit;

  • whether a visitor completed a quiz;

  • whether a visitor submitted an email address;

  • how visitors interact with our website; and

  • the effectiveness of our advertising.

Where required by applicable law, we will obtain consent before placing or using non-essential cookies or similar tracking technologies.

8. Quiz Information and Personalisation

Our website may use your quiz responses to provide you with information or recommendations that are more relevant to the answers you provided.

For example, we may use your responses to:

  • determine which educational information to display;

  • provide a personalised quiz result;

  • identify an appropriate category of gum-care information;

  • present a product or service recommendation; or

  • tailor follow-up communications.

The quiz is not a medical diagnostic tool.

Our quiz does not diagnose gum disease, periodontal disease, infection or any other medical condition.

Our recommendations should not be interpreted as a medical diagnosis or personalised medical treatment plan.

Where applicable law gives you rights relating to profiling or automated decision-making, those rights are described in the section of this Privacy Policy dealing with your privacy rights.

9. Legal Bases for Processing — United Kingdom and European Economic Area

If you are located in the United Kingdom or European Economic Area and applicable data protection law applies to our processing of your personal information, we will process your personal information on one or more lawful bases permitted by applicable law.

Depending on the circumstances, these may include:

  • Consent — where you have given us permission to process your information for a specific purpose;

  • Contract — where processing is necessary to provide something you have requested;

  • Legitimate interests — where processing is necessary for our legitimate business interests and those interests are not overridden by your rights;

  • Legal obligation — where processing is necessary to comply with a legal obligation; or

  • Other lawful bases permitted under applicable law.

Where we process information that constitutes special category data, such as health-related information, we will rely on an applicable additional legal condition where required by law.

You may withdraw consent at any time where our processing relies on your consent.

Withdrawal of consent does not affect the lawfulness of processing that occurred before withdrawal.

UK GDPR guidance recognises health information as special category data and requires organisations processing such data to identify both an Article 6 lawful basis and an appropriate Article 9 condition where applicable.

10. Australian Privacy

If you are located in Australia, your personal information may be protected by the Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs"), where applicable.

Health information is treated as sensitive information under Australian privacy law and receives additional protections.

Where the Australian Privacy Act applies to our handling of your information, we will handle your personal information in accordance with applicable Australian privacy requirements.

Our practices include providing information about:

  • the types of information we collect;

  • how we collect and hold information;

  • why we collect and use information;

  • how information may be disclosed;

  • overseas disclosures;

  • how you may access or correct information; and

  • how you may make a privacy complaint.

These are among the matters covered by APP 1.4.

11. United States Privacy

If you are located in the United States, additional federal or state privacy laws may apply depending on your location and our activities.

For example, certain states provide residents with specific rights concerning personal information.

California residents

If you are a California resident and the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), applies to our business, you may have additional rights concerning your personal information.

These may include rights to:

  • know what personal information we collect;

  • know how personal information is used and disclosed;

  • request deletion of personal information, subject to legal exceptions;

  • correct certain inaccurate personal information;

  • opt out of certain sales or sharing of personal information;

  • limit certain uses of sensitive personal information where applicable;

  • receive equal treatment for exercising applicable privacy rights; and

  • exercise other rights provided under applicable California law.

California recognises health information as sensitive personal information in circumstances covered by the CCPA.

To exercise an applicable California privacy right, contact:

[PRIVACY EMAIL ADDRESS]

We may need to verify your identity before completing certain requests.

We will not discriminate against you for exercising privacy rights that apply to you.

12. How We Share Information

We do not disclose your personal information indiscriminately.

We may disclose information to trusted third parties where reasonably necessary to operate our business, provide our services, communicate with you, operate our website, measure advertising or comply with legal obligations.

These third parties may include:

Email and marketing providers

We may use third-party email marketing and automation providers to store email addresses and deliver communications.

Current provider(s): [EMAIL PLATFORM]

Website and technology providers

We may use providers for:

  • website hosting;

  • domain services;

  • website security;

  • quiz software;

  • form processing;

  • data storage;

  • technical support; and

  • website functionality.

Current provider(s): [LIST PROVIDERS]

Analytics providers

We may use analytics services to understand website traffic and user behaviour.

Current provider(s): [GOOGLE ANALYTICS / OTHER PROVIDERS]

Advertising providers

We may use advertising platforms such as Google Ads and Meta to advertise our website and measure advertising performance.

Current provider(s): [GOOGLE ADS / META / OTHER PROVIDERS]

Professional advisers

We may disclose information where reasonably necessary to professional advisers such as lawyers, accountants, insurers or other professional service providers.

Legal and regulatory purposes

We may disclose information where reasonably necessary to:

  • comply with applicable law;

  • respond to lawful requests;

  • enforce our agreements;

  • protect our rights;

  • protect the safety of our users or others; or

  • detect, prevent or investigate fraud, security incidents or other unlawful activity.

13. Affiliate Marketing

Some links on our website may be affiliate links.

If you click an affiliate link and subsequently make a purchase, we may receive a commission or other compensation from the relevant merchant or affiliate program.

Our affiliate relationships do not normally require us to receive your payment information.

When you purchase a product directly from a third-party merchant, your transaction is generally governed by that merchant's own privacy policy and terms.

We encourage you to review the privacy policy and terms of any third-party website you visit.

For more information, please see our Affiliate Disclosure.

14. Third-Party Websites

Our website may contain links to websites operated by third parties.

These may include:

  • product websites;

  • affiliate websites;

  • payment providers;

  • social media websites;

  • educational resources; and

  • other third-party websites.

We are not responsible for the privacy practices, security or content of third-party websites.

Once you leave our website, the privacy policy of the website you visit will apply.

We encourage you to review the privacy policy of every third-party website before providing personal information.

15. International Transfers

Because we operate online and may use service providers located in different countries, your personal information may be processed or stored outside the country in which you live.

For example, service providers we use may operate in Australia, the United States, the United Kingdom, the European Economic Area or other jurisdictions.

Where applicable law requires safeguards for international transfers of personal information, we will take reasonable steps to use appropriate safeguards.

For Australian users, our privacy policy will identify overseas disclosure arrangements where required under applicable Australian privacy law. APP 1.4 specifically requires an applicable entity to address whether personal information is likely to be disclosed overseas and, where practicable, identify the countries involved.

16. How We Protect Your Information

We take reasonable administrative, technical and organisational measures designed to protect personal information against:

  • unauthorised access;

  • unauthorised disclosure;

  • misuse;

  • loss;

  • alteration;

  • destruction; and

  • other security threats.

These measures may include appropriate access controls, secure service providers, password protections, encryption where appropriate, website security measures and restricted access to personal information.

However, no method of transmitting information over the internet or storing information electronically is completely secure.

Therefore, we cannot guarantee absolute security.

17. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

The appropriate retention period depends on factors including:

  • why the information was collected;

  • whether we have an ongoing relationship with you;

  • legal and regulatory requirements;

  • accounting and record-keeping obligations;

  • dispute resolution requirements;

  • security considerations; and

  • whether the information is necessary to protect our legal rights.

When personal information is no longer reasonably required, we will take reasonable steps to delete it, anonymise it or otherwise dispose of it securely, subject to applicable legal obligations.

18. Cookies

Our website may use cookies and similar technologies.

Cookies may be used to:

  • remember website settings;

  • maintain website functionality;

  • understand website usage;

  • measure advertising performance;

  • remember quiz or session information;

  • prevent fraud;

  • improve website performance; and

  • support marketing activities.

You may be able to control cookies through your browser settings.

Where required by applicable law, we will request consent before using non-essential cookies or similar technologies.

Please note that disabling certain cookies may affect the functionality of our website.

19. Email Communications

If you subscribe to our email communications, we may send you information relating to:

  • your quiz results;

  • gum care;

  • oral care;

  • educational content;

  • products;

  • services;

  • special offers; and

  • related information.

Every commercial email we send will include an unsubscribe option where required by applicable law.

You may unsubscribe at any time.

After you unsubscribe, we will take reasonable steps to stop sending you further marketing communications, subject to legally permitted or required communications such as transactional, security or administrative messages.

20. Your Privacy Rights

Depending on where you live and which privacy laws apply, you may have rights including:

  • the right to know what personal information we hold about you;

  • the right to request access to your information;

  • the right to request correction of inaccurate information;

  • the right to request deletion of information, subject to legal exceptions;

  • the right to withdraw consent;

  • the right to object to certain processing;

  • the right to restrict certain processing;

  • the right to data portability;

  • the right to opt out of certain marketing activities;

  • the right to opt out of certain sales or sharing of personal information where applicable;

  • rights relating to profiling or automated decision-making where applicable; and

  • the right to lodge a privacy complaint with a relevant regulator.

Not every right applies in every country or in every circumstance.

21. How to Exercise Your Rights

To make a privacy request, please contact us:

Email: [PRIVACY EMAIL ADDRESS]

Please include:

  • your name;

  • the email address associated with your interaction with us;

  • the nature of your request; and

  • any other information reasonably necessary for us to identify your records.

For security reasons, we may need to verify your identity before providing access to or deleting certain information.

We will respond to requests within the period required by applicable law.

22. Australian Privacy Complaints

If you are located in Australia and believe we have mishandled your personal information, please contact us first so that we have an opportunity to investigate and respond.

Privacy Contact: [PRIVACY EMAIL ADDRESS]

If you are not satisfied with our response, or we fail to respond within the applicable period, you may be able to contact the Office of the Australian Information Commissioner (OAIC).

The OAIC provides information about privacy complaints and privacy rights through its official website.

23. United Kingdom Privacy Complaints

If you are located in the United Kingdom and applicable UK data protection law applies to our processing of your information, you may have the right to complain to the Information Commissioner's Office (ICO).

You may contact us first so that we can attempt to resolve your concern.

24. European Economic Area Privacy Rights

If you are located in the European Economic Area and applicable GDPR requirements apply, you may have additional rights under the GDPR.

These may include the right to:

  • access your personal data;

  • correct inaccurate data;

  • request erasure;

  • restrict processing;

  • object to processing;

  • receive certain personal data in a portable format;

  • withdraw consent; and

  • lodge a complaint with a data protection supervisory authority.

Where applicable, you may also have rights relating to automated decision-making and profiling.

25. Children's Privacy

Our website and services are intended for adults.

We do not knowingly request or intentionally collect personal information from children under the minimum age permitted by applicable law.

If you believe that a child has provided us with personal information without appropriate consent, please contact us at:

[PRIVACY EMAIL ADDRESS]

If we become aware that we have collected personal information from a child in circumstances where we are not permitted to do so, we will take reasonable steps to delete that information.

26. Health Information Disclaimer

Our website may discuss topics relating to:

  • gums;

  • bleeding gums;

  • oral hygiene;

  • dental care;

  • gum appearance;

  • mouth rinses;

  • toothpaste;

  • oral-care products; and

  • other health-related topics.

Information collected through our quiz is used to provide general educational information and, where applicable, a product or content recommendation.

Our website and quiz are not a substitute for professional dental or medical advice.

We do not provide dental diagnosis or treatment through the website.

You should not rely on information obtained through our website as a diagnosis of any medical or dental condition.

If you have persistent, severe or concerning symptoms, including significant or persistent gum bleeding, pain, swelling, infection, loose teeth or other oral-health concerns, you should consult an appropriately qualified dental or healthcare professional.

27. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

Changes may be made to reflect:

  • changes to our business;

  • changes to our website;

  • changes to the services or technologies we use;

  • changes in applicable privacy laws;

  • changes in our information-handling practices; or

  • improvements to the clarity of this policy.

When we update this Privacy Policy, we will change the Last Updated date at the top of this page.

If a material change is required to be communicated to you under applicable law, we will take appropriate steps to notify you.

28. Contact Us

If you have questions about this Privacy Policy, our privacy practices or your personal information, please contact:

[LEGAL BUSINESS NAME]

Email: [PRIVACY EMAIL ADDRESS]

Website: [WEBSITE URL]

Address: [BUSINESS ADDRESS]

29. Important Notice About This Privacy Policy

This Privacy Policy has been written to provide a broad privacy framework for an online website, quiz and email marketing funnel that may be accessed internationally.

Privacy laws differ between countries, states and circumstances.

The fact that this website is accessible internationally does not necessarily mean that every privacy law applies to every visitor or every activity.

Where applicable, we will comply with the privacy laws that apply to our collection and processing of personal information.

© [YEAR] [LEGAL BUSINESS NAME]. All Rights Reserved.

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