GENERAL PRIVACY STATEMENT

INTRODUCTION

The use of the dp suite of products and dp connect app and the dp 4 are subject to your acceptance of this privacy and data collection policy and statements. you are required to read these statements and freely consent to them before using our website app or products. by clicking you are accetping our policy. if you have questions please contact us or seek independent legal advice before accepting these terms and policy.

DERMAPENWORLD IS COMMITTED TO PROTECTING YOUR PRIVACY

This privacy statement discloses what information we gather about you when you visit the Dermapenworld website and describes how we use that information. Our policy is to keep your personal information completely confidential and used solely for the internal purposes of completing your order. We do not and will not share your personal information with any other third party. Our Data Collection and Storage policy and compliance statements are annexed to this document. Some of our data is collected and transferred to us from the Appstore or another third party provider. Where a third party provides us with your information it is transferred securely and stored by us without any further access being granted. All third parties are compliant with the Australian Privacy Law and the GDPR.

COLLECTION OF PERSONAL INFORMATION

The personal information we collect may include your name, address, email and phone details. We may collect other information about your visit, such as the type of web browser used; the date and time you accessed the website; the pages that you accessed while at the website and the Internet address of the website from which you linked directly to our website. This information is used to administer and help improve the website, and ultimately improve your shopping experience with us. We use this information for no other reason. We also collect data about the use of our devices and the location of users and the use of consumables to comply with relevant medical protocols and as far as possible effective operation of devices and products sold.

‘Cookies’ are small files that store your data in your browser for your next visit to the website. You may disenable ‘cookies’ at any time on your browser, if you wish to remain anonymous during your visit.

USE OF YOUR PERSONAL INFORMATION.

The personal information collected on this website will be used to provide the products and services you have requested. We may use your personal information to provide you with important information about the product or service that you are using. Additionally, we may send you information about other Dermapenworld products and services from time to time. You have the option to decline this information at your discretion.

WE DO NOT, AND NEVER WILL, SHARE YOUR PERSONAL DETAILS WITH ANY OTHER PARTY.

However, Dermapenworld, like any other organisation or company, may be directed by a Law Enforcement Agency to release customer details, if you have committed any offences or crimes under Australian law.

SECURITY

When you purchase any goods from Dermapenworld, your personal details and credit card information are totally secure. We only obtain as much detail as is required to process and complete your order. All payments are made using a secure SSL-encrypted link.

Your computer IP address may be captured by our website in order to confirm you are a legitimate customer using a legitimate credit card. This action protects both Dermapenworld and you, as one of our customers, from fraud. We do this by use of credit card fraud detection software. Your computer IP address information is used for no other reason.

QUESTIONS

If you have any questions about this Privacy Statement or have concerns about the way we process your personal data, please contact us on 1300 668 755 or visit our web site Dermapenworld.com

Data Protection & Privacy Policy

Context and overview

Key details

• Policy prepared by: Shaun Kerrigan
• Approved by board / management on: 23/05/2018
• Policy became operational on: 23/05/2018
• Next review date: 01/05/2018

Introduction

Dermapenworld needs to gather and use certain information about individuals and businesses.

These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law. In particular this policy is compliant with the Australian Privacy Act 1988 and the General Data Protection Regulation (“GDPR”). For the purposes of this agreement data is collected and maintained in Australia. As far as allowable by law the user whose data is collected agrees to be bound by Australian law.

Why this policy exists

This data protection policy ensures :

• Complies with data protection law and follow good practice
• Protects the rights of staff, customers and partners
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of a data breach

Privacy and Data protection law

The Australian Privacy Act 1988 and The Data Protection Act 1998 describes how organisations — including Dermapenworld— must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

1. Be processed fairly and lawfully
2. Be obtained only for specific, lawful purposes
3. Be adequate, relevant and not excessive
4. Be accurate and kept up to date
5. Not be held for any longer than necessary
6. Processed in accordance with the rights of data subjects
7. Be protected in appropriate ways
8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

People, risks and responsibilities

Policy scope

This policy applies to:

The head office of

All branches of

All staff and volunteers of

All contractors, suppliers, authorized distributors and others who may access the data and applications held by Dermapenworld or their licensor in respect of the use and operation of all of the devices and products sold by or on behalf of Dermapenworld

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

• Names of individuals
• Postal addresses
• Email addresses
• Telephone numbers
• Data concerning product use, location and ordering information

Data protection risks

This policy helps to protect Dermapenworld from some very real data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately.
• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

Responsibilities

Everyone who works for or with Dermapenworld has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

• The board of directors is ultimately responsible for ensuring that Dermapenworld meets its legal obligations.
• The data protection officer, Stene Marshal, is responsible for:
  • Keeping the board updated about data protection responsibilities, risks and issues.
  • Reviewing all data protection procedures and related policies, in line with an agreed schedule.
  • Arranging data protection training and advice for the people covered by this policy.
  • Handling data protection questions from staff and anyone else covered by this policy.
  • Dealing with requests from individuals to see the data Dermapenworld holds about them (also called ‘subject access requests’).
  • Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
• The General Manager, Stene Marshal, is responsible for:
  • Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
  • Performing regular checks and scans to ensure security hardware and software is functioning properly.
  • Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
• The General Manager, Stene Marshal, is responsible for:
  • Approving any data protection statements attached to communications such as emails and letters.
  • Addressing any data protection queries from journalists or media outlets like newspapers.
  • Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

General staff guidelines

• The only people able to access data covered by this policy should be those who need it for their work.
• Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
• Dermapenworld will provide training to all employees to help them understand their responsibilities when handling data.
• Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
• In particular, strong passwords must be used and they should never be shared.
• Personal data should not be disclosed to unauthorised people, either within the company or externally.
• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
• Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

• When not required, the paper or files should be kept in a locked drawer or filing cabinet.
• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
• Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

• Data should be protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
• Servers containing personal data should be sited in a secure location, away from general office space.
• Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
• All servers and computers containing data should be protected by approved security software and a firewall.

Data use

Personal data is of no value to Dermapenworld unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
• Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
• Personal data should is transferred and stored outside of the European Union and users expressly give their consent for such an arrangement.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Data accuracy

The law requires Dermapenworld to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort Dermapenworld should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• Dermapenworld will make it easy for data subjects to update the information Dermapenworld holds about them. For instance, via the company website.
• Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
• It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Subject access requests

All individuals who are the subject of personal data held by Dermapenworld are entitled to:

• Ask what information the company holds about them and why.
• Ask how to gain access to it.
• Be informed how to keep it up to date.
• Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at stene@dermapenworld.com The data controller can supply a standard request form, although individuals do not have to use this.

Individuals will be charged £100 per subject access request. The data controller will aim to provide the relevant data within 14 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Disclosing data for other reasons

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, Dermapenworld will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

Providing information

Dermapenworld aims to ensure that individuals are aware that their data is being processed, and that they understand:

• How the data is being used
• How to exercise their rights

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.

[This is available on request. A version of this statement is also available on company's website]