Privacy policy
Skincare Academy Pty Ltd (ABN: 186 550 630 04)
Last updated: June 2026
1. Introduction
Skincare Academy Pty Ltd (ABN: 186 550 630 04) (we, us, our) is committed to protecting your privacy and handling your personal information responsibly, openly, and in accordance with the law.
This Privacy Policy explains how we collect, hold, use, and disclose your personal information, including sensitive information such as health information. Through our website (www.skincareacademy.com.au), online programs, and clinical services (including the Internal™ model).
We comply with the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APPs), and the Privacy and Other Legislation Amendment Act 2024 (Cth). Where the Notifiable Data Breaches (NDB) scheme applies, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) of any eligible data breach as required.
By using our website or providing your personal information to us, you consent to our collection, holding, use, and disclosure of your personal information in accordance with this policy. Please read this policy carefully before engaging with our services.
2. What is Personal Information?
"Personal information" has the meaning given in the Privacy Act, generally, any information or opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not and whether in material form or not.
"Sensitive information" is a subset of personal information and includes health information, racial or ethnic origin, religious beliefs, political opinions, criminal record, and other categories defined in the Privacy Act. Sensitive information receives a higher level of protection and will only be collected and used with your consent or as otherwise required or permitted by law.
3. What Personal Information Do We Collect?
The types of personal information we may collect include:
3.1 Personal and Contact Details
• Name, date of birth, gender, and occupation;
• Email address, phone number, and mailing address;
• Social media handles (e.g. Instagram) provided during onboarding or correspondence.
3.2 Health Information (Sensitive Information)
Due to the nature of our clinical and educational services, including the Internal™ membership model, which involves functional pathology testing and naturopathic supplementation, we may collect:
• Current and past medical history, diagnoses, and conditions;
• Current medications, supplements, and treatments;
• Allergies and food intolerances;
• Pathology and functional testing results;
• Skin condition history, including before and after photos;
• Reproductive status (e.g. pregnancy, breastfeeding, trying to conceive);
• Dietary preferences and restrictions relevant to product recommendations;
• Family health history where clinically relevant.
Health information is sensitive information under the Privacy Act and is collected only with your consent and for the primary purpose of providing our services.
3.3 Payment Information
• Credit or debit card details (processed securely via third-party payment processors, we do not store full card details);
• Transaction history for products and services purchased.
3.4 Program and Course Enrolment Information
• Details of programs and courses you have purchased or enquired about;
• Progress and engagement data within our Circle learning platform;
• Submissions, questions, and materials uploaded through course portals.
3.5 Website and Technical Information
• Browser type, operating system, and device information;
• IP address, geo-location data, and internet service provider;
• Pages visited, session duration, and browsing behaviour on our website;
• Cookie and tracking data (see Section 9 — Cookies).
3.6 Employment and Supplier Information
• Qualifications, skills, and work experience (for job applicants);
• Business details, services, and pricing (for suppliers and contractors).
4. How Do We Collect Your Personal Information?
We collect personal information directly from you wherever practicable, including when you:
• Purchase or enrol in one of our programs or courses (including Advanced Acne to g l o w®, Online Acne Specialist™, Advanced Acne Pathway™, Advanced Acne Scarring to g l o w™, Acne Flashcard Program™, or Internal™);
• Book or attend a consultation, mentoring call, or Internal™ Case Review;
• Complete an intake form, health questionnaire, or onboarding document;
• Subscribe to our mailing list, newsletter, or SMS updates;
• Contact us by email, phone, or through our website enquiry form;
• Engage with us on social media platforms including Instagram, Facebook, TikTok, YouTube, Pinterest, or LinkedIn;
• Attend an event, workshop, or online training session we host;
• Apply for employment or an internship with us;
• Visit our website (including via cookies and analytics tools).
We may also collect personal information from third parties, including:
• Your parent or guardian (if you are under 18);
• Referring Acne Specialists (Internal™ Partner Clinics) who submit client case information on your behalf;
• Other involved healthcare providers, pathology providers, or diagnostic services (where relevant and authorised);
• Third-party platforms such as Circle, Vital.ly, I Screen, payment processors, and analytics providers.
If we collect your information from a third party, we will take reasonable steps to make you aware of this.
If you do not provide us with personal information when requested, we may not be able to provide our products or services to you.
5. Why Do We Collect, Use, and Hold Your Personal Information?
We collect, hold, use, and disclose personal information for the following purposes:
• To provide our educational programs and professional development services to skin professionals;
• To deliver naturopathic clinical services under the Internal™ model, including ordering and interpreting functional pathology tests and prescribing individualised supplementation protocols;
• To provide the 15-Minute Internal Case Review™ and associated clinical services;
• To manage enrolments, bookings, and appointments;
• To communicate with you about your enrolment, program progress, or clinical care;
• For internal record keeping, administration, and invoicing;
• To comply with legal and regulatory obligations, including mandatory record-keeping of health information;
• For analytics, market research, and improvement of our programs and website;
• For advertising and marketing, including sending promotional communications about our programs and services (subject to your preferences and the Spam Act 2003 (Cth));
• To consider employment applications;
• To otherwise operate and administer our business.
When we collect your personal information, we will, where appropriate, explain why we are collecting it and how we plan to use it.
6. Sensitive Information (Health Information)
Given the clinical nature of our Internal™ model and the health-related content of our programs, we may collect sensitive information, particularly health information about your clients (where you are an Acne Specialist submitting a client case).
We will only collect, use, and disclose sensitive information:
• For the primary purpose for which it was collected (e.g. to provide naturopathic clinical services under the Internal™ model);
• For a secondary purpose directly related to the primary purpose;
• With your express consent; or
• As required or permitted by law (e.g. mandatory reporting obligations, a serious threat to life or health).
Health information collected through the Internal™ model, including pathology results, supplement prescriptions, and client health histories is handled with the highest level of privacy protection and is not used for any purpose unrelated to your clinical care.
7. Who Do We Share Your Personal Information With?
We may disclose your personal information to:
• Third-party service providers who assist us in operating our business, including IT and cloud storage providers, website hosting services, payment processors, marketing platforms, and professional advisors (legal, accounting, and business consulting);
• Circle (our learning management platform) and other course delivery tools;
• Pathology providers (including Nutripath, I Screen and others notified from time to time) for the purpose of ordering and processing functional pathology tests under the Internal™ model;
• Supplement dispensaries and practitioner-only product distributors (including Vital.ly and Ariya Health) for the purpose of fulfilling prescriptions;
• Referring Acne Specialists (Internal™ Partner Clinics) who are involved in your clinical care, for the purpose of coordinating your individualised treatment plan;
• Our employees, contractors, and related entities on a need-to-know basis to deliver our services;
• Our existing or potential agents, business partners, or successors in the event of a business transfer;
• Courts, tribunals, regulatory authorities, and law enforcement, as required by law or in connection with legal proceedings;
• Credit reporting agencies or debt collectors where necessary to recover outstanding fees;
• Analytics providers such as Google Analytics (which may involve data being stored outside Australia);
• Any person you expressly authorise us to share your information with.
We do not sell your personal information to third parties or provide it to other organisations for the purposes of their direct marketing.
Some of our service providers are located overseas (including the USA) and may not be subject to the Australian Privacy Act. We take reasonable steps to ensure they handle your information in a manner consistent with the Australian Privacy Principles.
8. How Do We Store and Protect Your Personal Information?
We are committed to protecting your personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure.
We store personal information using a combination of secure cloud-based platforms, including:
• Circle (learning management and course portal);
• Google Workspace (G Suite) (email and document management);
• Secure pathology platform portals (e.g. Nutripath);
• Secure payment processing systems (Shopify)
• Email marketing platform (Omnisend)
These platforms maintain their own encryption and security policies. We encourage you to review the privacy policies of these providers on their respective websites.
We will take reasonable steps to destroy or de-identify your personal information when it is no longer needed for the purpose for which it was collected, unless we are required by law to retain it. Health information is subject to minimum retention obligations under applicable law and will be retained accordingly.
We will never permanently store complete credit or debit card details.
If you communicate with us via email, Zoom, social media, or other electronic means, please be aware that these channels carry inherent transmission risks. By using these channels, you acknowledge that we cannot guarantee the security of information transmitted electronically.
9. Notifiable Data Breaches
We are subject to the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988 (Cth). In the event of an eligible data breach, one that is likely to result in serious harm to any individual whose information is involved, we will:
• Notify affected individuals as soon as practicable;
• Notify the Office of the Australian Information Commissioner (OAIC); and
• Take all reasonable steps to contain the breach and prevent further harm.
10. Cookies and Tracking Technologies
We may use cookies and similar tracking technologies on our website to improve functionality and your user experience. Cookies are small text files stored in your browser that help us understand how you use our website.
We use cookies to:
• Remember your preferences and settings;
• Analyse website traffic and user behaviour (including via Google Analytics);
• Deliver targeted advertising and marketing content based on your browsing behaviour (where you have consented).
You can disable cookies in your browser settings, but this may affect your ability to use certain features of our website. By continuing to use our website, you consent to our use of cookies in accordance with this policy.
11. Marketing Communications
We may use your contact details to send you promotional communications about our programs, events, and services. All marketing communications are sent in accordance with the Spam Act 2003 (Cth) and will include a clear unsubscribe option.
You may opt out of marketing communications at any time by:
• Clicking the unsubscribe link in any email we send you; or
• Contacting us directly at info@skincareacademy.com.au.
We do not share your personal information with third parties for the purpose of their direct marketing.
12. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites, which are governed by their own privacy policies. We encourage you to review the privacy policies of any third-party sites you visit through links on our website.
13. Accessing and Correcting Your Personal Information
You have the right to request access to the personal information we hold about you, and to request that we correct any inaccurate, out-of-date, or incomplete information.
To make an access or correction request, please contact us in writing at info@skincareacademy.com.au. We will respond to your request within 30 days. We may require you to verify your identity before releasing or amending information.
We will not charge a fee for making an access request, but we may charge a reasonable administrative fee to provide copies of your information.
In some circumstances, we may decline to provide access to certain information (for example, where doing so would affect the privacy of another individual or where an exception applies under the Privacy Act). Where we decline access, we will explain our reasons.
14. Children's Privacy
Our programs and services are intended for adults (18 years and over) who are qualified skin professionals. We do not knowingly collect personal information from individuals under the age of 18 without parental or guardian consent.
If we become aware that we have inadvertently collected information from a person under 18 without appropriate consent, we will take steps to delete that information promptly.
15. Privacy Complaints
We take privacy complaints seriously. If you believe we have mishandled your personal information or breached the Australian Privacy Principles, please contact us in writing at info@skincareacademy.com.au. We will acknowledge your complaint promptly and aim to resolve it within 30 days.
If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):
• Website: www.oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5218, Sydney NSW 2001
The OAIC generally requires that you give us an opportunity to respond before they will investigate.
16. Updates to This Policy
We may update this Privacy Policy from time to time to reflect changes in our business, services, or legal obligations. The current version will always be available on our website at www.skincareacademy.com.au/privacy-policy. We encourage you to review this policy periodically.
17. Contact Us
For any questions, concerns, or requests relating to this Privacy Policy or your personal information, please contact:
Skincare Academy Pty Ltd (ABN: 186 550 630 04)
Mooloolaba, Queensland, Australia, 4557
info@skincareacademy.com.au
PRIVACY COLLECTION STATEMENT
Your personal information is being collected by Skincare Academy Pty Ltd (ABN: 186 550 630 04) (we, us, our).
Under the Privacy Act 1988 (Cth), we are required to inform you that we collect personal information — which may include sensitive health information, for the purpose of providing online education programs for skin professionals and, where applicable, naturopathic clinical services under the Internal™ model (including functional pathology testing, individualised supplementation, and the 15-Minute Internal Case Review™).
If we cannot collect the information requested, we may not be able to provide our products or services to you.
We collect this information primarily through our direct communications and dealings with you, and in some circumstances from third parties (including referring Acne Specialists and pathology providers) as part of delivering our services.
We generally do not disclose your personal information to any person except as required in the course of providing our services, administering our business, or as otherwise permitted under the Privacy Act or other applicable law.
Our full Privacy Policy (above) contains details about:
• The types of personal information we collect and why;
• How and from whom we collect it;
• Who we may share it with;
• How you can access or correct your information;
• How to make a privacy complaint and how it will be handled.
To request access to or correction of your personal information, to opt out of marketing communications, or to make a privacy complaint, please contact us in writing:
Skincare Academy Pty Ltd (ABN: 186 550 630 04)
Mooloolaba, Queensland, Australia, 4557
© 2026 Skincare Academy Pty Ltd
