Privacy Policy

Skinspots is a fully owned subsidiary of MoleMap Limited.

‍MoleMap Commitment to Privacy

MoleMap Limited, a registered New Zealand company, MoleMap Australia Pty Limited ABN 99 116 131 929 and their respective subsidiaries andaffiliates in Australia and New Zealand , including SkinSpots Mt Maunganui NZ (collectively referred to as MoleMap) are committed to managing personal information in accordance with the New Zealand Privacy Act 2020 and the Australian Privacy Act 1988 (including the Australian Privacy Principles contained within that Act) (Privacy Acts), as well as other Australian State and Territory laws that regulate health information, such as the Health Records Act 2001 (Victoria), Health Records Information Privacy Act 2002 (New South Wales) and Health Records (Privacy and Access) Act 1997 (ACT) (Health Record Laws), to the extent that they are applicable.  

This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.

In this Privacy Policy, "we" and "us"refers to MoleMap and "you" refers to any individual about whom we collect personal information.

This policy does not limit or exclude any of your rights under the Privacy Acts and Health Record Laws. If you wish to seek further information on the Privacy Acts, see www.privacy.org.nz and www.oaic.gov.au (as applicable to your location).

What information does MoleMapcollect about you?

Customers and prospective customers

When you enquire about our services or when you become a patient of MoleMap or otherwise use our services, a record is made which includes your personal information.

The type of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:

• your full name
• your gender
• your contact details (including your residential address, phone number and email address)
• your date of birth
• your relevant health care or insurance agency related identifiers, such as your Australian Medicare number, your New Zealand National Health Index number or your private health insurance number to support payment or referral processes if this applies to your care
• sensitive health information (including detailsabout your health and clinical history, images of your skin and lesions, histology results of lesions you may have excised, referral details and prescribed medications)

Prospective employees/applicants

We collect personal information when recruiting personnel, such as your name, contact details, qualifications, and work and study history.  

Before offering you a position, we may collect additional details such as references from the referees you have provided us, your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions (for example, working with vulnerable patients or working with confidential personal information).

Business contacts

We collect personal information when we do business with you, such as if you are a doctor who is referring a patient to MoleMap, or if you are a supplier that provides goods or services to us. The personal information that we generally collect may include:

• full name
• organisation, title and position
• contact details (including your business address, phone number and email address) and other information necessary to conduct business with you.

How does MoleMap collect your personal information?

MoleMap collects personal information in several ways, mainly directly from you when you:

• Register or book an appointment with us
• Subscribe to our emails
• Complete an online survey or quiz
• Visit one of our clinics
• Take part in a phone, video, or online chat consultation
• Apply for a job with us

We may collect and update your information through phone, email, the internet, social media, or in person.

When you visit a MoleMap clinic, we use a dermoscopic imaging camera to take clinical images of your skin. These images become part of your medical record.

In some cases, we may receive your personal information from:

• Authorised representatives – such as a parent, guardian, or carer
• Doctors using our clinics – for your skin cancer treatment
• Other healthcare providers – e.g. your doctor may send us a referral or share histology results related to skin lesions removed after our diagnosis
• Public sources or networking sites – such as LinkedIn
• Your employer or health insurer – if you are using MoleMap services through a corporate wellness program

Third-Party healthcare providers and data handling

MoleMap provides data storage, data processing and diagnostic services to certain healthcare providers such as General Practitioners, skin clinics and registered nurses who provide MoleMap servicesunder a license. These providers collect patient information and images using our systems. They will share this information with us so we can diagnose and report on the images they share with us.

In these cases, we receive your personal information indirectly through these third parties rather than directly from you. When this happens, we handle your information according to this Privacy Policy. However, we recommend checking the privacy policy of any healthcare provider you share your information with, as we are not responsible for how they manage it.

For what purposes does MoleMapcollect, hold and use your personal information?

The purpose for which MoleMap usually collects, holds, uses and discloses personal information depends on the nature of your interaction withus.

For the provisioning of Clinical Services to our patients and employees of corporate clients we collect personal information to:

• Verify your identity.
• Provide services and products to you.
• Communicate with you (such as for the purpose of responding to a query you have submitted, to give you appointment reminders or to inform you about our health services and products that may be of interest to you).
• Fulfill administrative, management and operational functions associated with our services and products (such as administering billing and payments, quality improvement activities).
• Bill you for our services or deliver payment programs or services such as SuperGold, AfterPay and Laybuy.
• Respond to enquiries and complaints.
• Improve the quality and efficiency of ourservices through research and development. This may include training of artificial intelligence solutions.

For the recruitment and management of personnel we may collect personal information to:

• Communicate with, recruit, manage and pay staff.
• Communicate with, attract and manage volunteersand interns.

For the purchasing, use and management of third-party service providers we may collect personal information to:

• ‍Communicate with, contract and pay contractors.
• Communicate with, evaluate, contract and pay third-party providers for them to supply facilities, technical equipment, medical supplies, software or services.

Other reasons we collect personal information are:

• To enable us to respond to subpoenas and otherlegal orders and obligations.
• To protect or enforce our legal rights and interests (including defending any claim).

For what purposes may MoleMap share your personal information?

MoleMap may share your information with third parties in thefollowing situations:

• ‍At Your Request: If you authorise us to disclose information to someone, we will fulfil your request.‍
• Referrals for Ongoing Care: If we need to refer you to another healthcare provider, we will discuss it with you first and get your consent.‍
• Doctor Availability: If you previously saw a doctor at one of our clinics, and they are no longer available or you make an appointment with another doctor, we may share your record with other doctors at the same facility.‍
• Coordinating With Your Healthcare Providers: We may share relevant information (such as reports or lesion images) with your GP, specialist, or referring healthcare provider to support your ongoing treatment.‍
• Service Support: We work with contractors and service providers who help us with data processing, data management and storage, IT services, customer surveys, printing, archiving, and market research.‍
• Corporate Wellness Programs: If you visit us through a corporate wellness program, we may share limited identifying details (e.g., your name, date of birth, or email) with your employer or their wellness provider. However, we do not share your personal clinical or diagnosis information—only a general, non-identifiable summary of the program's overall results.‍
• Legal Requirements: If required or authorised by law or regulatory authorities, we may disclose your personal information.‍
• Insurance: We may disclose your personal information to our insurers or insurers of independent healthcare professionals or otherwise for the purpose of establishing, exercising or defending a claim.‍
• Research and Training: With your consent, we may occasionally share de-identified information with partners like universities and research organizations for training, research, and analysis.

We may also share your personal information for other purposes with your consent.

How MoleMap Uses AI to Improve Skin Cancer Detection

MoleMap uses non-identifiable images of your skin, along with diagnosis information, to train our Artificial Intelligence (AI) system. This helps us improve early skin cancer detection.

In designated clinics in New Zealand, our AI, developed and owned by MoleMap, provides our nurses with an instant second opinion during your skin check. It helps indicate whether a lesion is likely benign ormalignant, assisting the nurse in deciding if a dermatologist should review it. The AI system does not use any personal identifiable information.

If you prefer not to have your non-identifiable images used for AI training, you can opt out by contacting our customer service team or adjusting your research settings in the customer portal.

In our Skinspots clinic we use a similar AI system to help our clinicians recognise malignant lesions. This system is not owned by MoleMap and supplied by a third party. MoleMap images are not used to train this third party solution.

Other uses of AI systems

We also use AI tools from trusted third parties in our support office and some clinics to improve the quality and efficiency of services we provide our customers in the following areas:

• In our Customer Services team, we use AI to analyse past support interactions to help us make decisions on improving the accuracy and speed of replying to your questions.  The type of personal information used for this purpose is a transcript of questions you share with us via phone call, chat message or email and our answers to those questions. If your question involves a question specific to your record, the system may access part of your record like your most recent appointment details to ensure the answer isspecific to your situation.
• In our treatment clinics, the clinician may use AI to assist with transcription of clinical notes to improve the quality, conciseness and speed of clinical note taking.  This generally involves recording the conversation with your consent and then the clinician will select the relevant parts of the transcription to be included in the clinical notes.  Ensuring the accuracy of the medical record remains the responsibility of the relevant clinician.

What happens if your personal information is not provided to MoleMap?

You can always decline to give MoleMap any personal information we request, but that may mean we cannot provide you with the services you have requested. If you have any concerns about the personal information we have requested, please let us know using the contact information provided at the end of this policy.

If you register for our online patient portal (My.Molemap.co.nz for New Zealand or My.Molemap.net.au for Australia), you are also able to manage some of the permissions related to your data yourself; for example, whether your doctor can see your images and diagnoses online or whether MoleMap can use your de-identified (aka anonymous) data for research and training.

Can you deal with MoleMap anonymously?

MoleMap will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry).  Generally, it is not practicable for MoleMap to deal with individuals anonymously or pseudonymously on an ongoing basis.  If we do not collect personal information about you, you may be unable to utilise our services.  

Where Medicare or private insurance rebates are available for our services, we will need to record your Medicare card or insurance details as well as additional identifiable information to verify these Medicare or insurance details. As such you may be required to pay for consults in full without this rebate if you choose to deal with MoleMap anonymously.

How MoleMap protects your personal information

MoleMap takes reasonable steps to keep your personal information safe from misuse, interference, loss, and unauthorised access, modification or disclosure.

• ‍Secure Storage: We store your information in secure electronic databases, either in our own systems or with trusted third-party providers.‍
• Data Location: Clinical records for both NewZealand and Australian patients are securely stored in a New Zealand datacenter, following both countries’ privacy and security regulations. A portion of contact information for sales, customer support and marketing is managed by a service provider in the USA, however no personal health information is shared with that service provider.‍
• Paper Records: If we collect information on paper,we convert it into an electronic format for storage. The original paper copies are either securely stored or destroyed.‍
• Physical and Digital Security: We protect data with security measures including locked facilities, restricted access, firewalls, user passwords, and regular staff access audits.‍
• Website Security: Our websites use encryption and other security technologies to protect your information online. We encourage users to be cautious when sharing personal information over the internet.

Does MoleMap delete your information?

To comply with relevant privacy regulations in New Zealandand Australia, we take steps to delete information that we no longer require. In January 2023 we adopted a 10-year data retention policy for our patient information (except as outlined below in relation to patients who are under the age of 18 years).

This means that from 1 May 2023, if you have not visited one of our clinics for 10 years or more, your MoleMap clinical record will be deleted.  If at the time of your visit you were younger than 18 years of age, and you have not visited for 10 years, we will retain your record until you are 25 years of age.

If you don’t want to visit our clinic again but you still want to retain a copy of your MoleMap clinical record, you are able to request an electronic copy of your data. A small fee may apply for this service.

You are of course always welcome to return to our clinic after more than 10 years, and if you do, we will create a new clinical record for you.  

If you have given us your permission to use your data for research and training, we may keep some parts of your record for longer than 10 years. If that is the case, we will de-identify the record so it cannot be linked back to you personally.

How does MoleMap interact with you via the Internet?

Third Parties that Provide Content, Advertising or Functionality

MoleMap occasionally works with certain third parties that serve advertisements or track ad performance. These third parties may monitor which ads users see, how often they see them, and how they interact with them.

We may also allow you to share content from our websites and services through social media platforms like Facebook, Twitter, Google+, and LinkedIn.

Some third parties that provide content, ads, or features on our websites may collect data about your usage through cookies, beacons, and similar technologies. This information may be gathered over time and combined with data from other websites and online services. Some of these third parties participate in industry programs that give consumers options for managing targeted advertising.

Cookies, Beacons, and Similar Technologies

We, along with certain third parties, use cookies, beacons,and other technologies on our websites and services.

Cookies

Cookies are small files stored on your device that help recognize you across websites, services, and sessions. They serve various purposes, such as:

• Remembering your login details (e.g., My MoleMap account).
• Tracking popular pages and features to improve user experience.
• Preventing repetitive ads by tracking which ones you’ve seen.
• Delivering relevant content and advertisements.

You can manage cookie settings in your browser or device,but disabling them may limit access to some website features. To learn more or opt out of interest-based ads, visit www.aboutads.info/choices.

We and third parties may also use other local storage technologies like HTML5 local storage. These function similarly to cookies.

Beacons

Beacons (or "pixels") are used to send information from your device to a server. They can track when you view content, emails, orads and may be used with cookies to analyze website usage and provide morerelevant content.

By using our websites and services, you agree to the use of cookies, local storage, and beacons as described in this Privacy Policy.

Third-Party Links

Our websites may contain links to third-party sites, each with its own privacy policy. We encourage you to review their policies before sharing personal information. MoleMap is not responsible for the content or privacy practices of these external sites.

Does MoleMap use or disclose yourpersonal information for direct marketing?

MoleMap may use your personal information to inform you about our services, promotions, events, and other relevant opportunities if you have consented to receiving direct marketing from us. We may send promotional codes via SMS or email.

If you have previously consented to receiving these communications from us and prefer not to receive marketing messages going forward, you can opt out anytime by contacting our customer service team using the number on our website or by following the opt out information contained in the message you receive.

We comply with New Zealand's Unsolicited Electronic Messages Act 2007 and Australia's Spam Act 2003 when sending electronic communications.

If you opt out of receiving marketing messages from us, we may still contact you regarding your ongoing relationship with us, including for the purpose of appointment reminders and follow-ups.

Does MoleMap disclose yourpersonal information overseas?

MoleMap operates in both New Zealand and Australia. All patient information is securely stored in our New Zealand data centre. A data-sharing agreement between MoleMap Australia and MoleMap New Zealand ensures compliance with both countries' privacy laws.

In some cases, we may share your information with overseas recipients to provide our services. For example, if one of our dermatologists is traveling abroad, they may access patient records remotely to continue offering tele-dermatology services.

We will only share your personal information with overseas recipients if:

• You have given consent, or
• It is permitted under Privacy Acts or Health Record Laws, or

• We have taken reasonable steps to ensure they comply with privacy regulations.

How can you access or seek correction of your personal information?

You have the right to access your personal information held by MoleMap on request. To request access, please contact our Privacy Officer in writing using the details below.

There is no fee to request your information, but we may charge for the reasonable time and costs involved in compiling the information in response to your request.

We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up to date. If your personal details change or if you notice any errors or discrepancies in the information we hold, please let us know. If you believe any information we hold is incorrect, outdated, incomplete, or misleading, you can request a correction and we will take reasonable steps to update your information.

When making a request, please provide:

• Your full name, date of birth, and contact details; and
• Details of the information you want to access or correct.

We will take reasonable steps to notify you of a decision on the request within 30 days.

We may decline your request to access or correct your personal information in certain circumstances in accordance with the Privacy Acts and Health Record Laws. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

What should you do if you have a complaintabout the handling of your personal information?

We take complaints and concerns regarding privacy seriously.

If you have a privacy complaint, you can reach out toMoleMap’s Privacy Officer using the contact details provided below.

• New Zealand: phone +64 800 665 362, emailmolemap.privacy@molemap.co.nz
• Australia:phone +61 1800 665 362, email molemap.privacy@molemap.net.au

 We aim to respond to complaints within a week.

If a more detailed investigation is needed, we will acknowledge your complaint within a week and work to resolve it as soon as possible. We may ask for more details and review relevant information.

You can also contact:

• For New Zealand: New Zealand Privacy Commissioner (Call 0800 803 909 or email enquiries@privacy.org.nz); or
• For Australia: Office of the Australian Information Commissioner (Call 1300 363 992, email enquiries@oaic.gov.au, or write to GPO Box 5218, Sydney NSW 2001).

How are changes made to this Privacy Policy?

MoleMap may amend this Privacy Policy from time to time. The most up-to-date version of our Privacy Policy can be found on our websites at http://www.molemap.co.nz  and http://www.molemap.net.au

How can you contact MoleMap aboutmatters related to this policy?

If you have any questions or concerns related to your privacy, you can email or call our privacy officer using the contact details below.

• New Zealand: phone +64 800 665 362,email molemap.privacy@molemap.co.nz
• Australia: phone +61 1800 665 362,email molemap.privacy@molemap.net.au

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