Privacy policy
Focus on Intimacy (“we”, “us”, “our”) is an Australian business (ABN 33 698 903 678) supplying adaptive intimacy and wellness products. This Privacy Policy explains how we collect, hold, use and disclose personal information in connection with focusonintimacy.com.au (the “Site”) and our order fulfilment, invoicing and prescriber-referral processes.
We take privacy seriously, particularly given the personal and sometimes sensitive nature of the products we supply. This Policy is written to comply with the Privacy Act 1988 (Cth) and the 13 Australian Privacy Principles (APPs). Given the health-related and funding-scheme information involved in how orders are placed, we treat ourselves as bound by the Privacy Act and the APPs in full, regardless of annual turnover, rather than relying on the small business exemption that applies to some other small Australian businesses.
This Policy complements the privacy information provided by Shopify, the e-commerce platform that hosts our Site. Shopify's own privacy practices are described in the Shopify Consumer Privacy Policy, available at privacy.shopify.com. Nothing in this Policy limits or replaces Shopify's disclosures about its own processing — this Policy instead explains how Focus on Intimacy itself collects, uses and discloses your information.
1. Definitions
- “Prescriber” means a person who assists a consumer in selecting a suitable product, and who places or facilitates an order on a consumer's behalf. Prescribers may come from a range of professional backgrounds — for example, occupational therapy, nursing, physiotherapy, psychosexual therapy, case management, or other allied health and support roles. We do not require, collect or verify professional registration numbers.
- “Participant” means the person a product is ultimately intended for, where an order is placed by a prescriber on their behalf.
- “Funding body” means iCare, the NDIS, a CTP insurer, or another compensable scheme, plan manager or insurer that pays for an order in whole or in part.
- “Site” means focusonintimacy.com.au and the Focus on Intimacy online store.
2. The kinds of personal information we collect
Depending on how you interact with us, we may collect:
2.1 From prescribers and account holders
- Name, business name, email address, phone number and postal address.
- Details of the funding body under which an order is being placed, including any scheme reference or approval number relevant to invoicing.
2.2 About the participant
- Name and delivery address, and a contact phone number for delivery purposes, provided to us by the ordering prescriber or, where applicable, the participant themselves.
- We do not require or request a diagnosis, clinical notes, or details of a participant's health condition to process an order. If a prescriber includes this kind of information in a free-text field (for example, an order note), we will only use it to fulfil that specific order and will not retain it longer than necessary.
2.3 From direct/self-managed customers
- Name, delivery address, email, phone number and payment details (processed securely by Shopify's payment infrastructure — we do not store full card numbers).
2.4 Automatically, via the Site
- Standard technical and analytics information collected through Shopify and through Google Analytics, such as browser and device type, the pages you view, how you arrived at the Site, your approximate location at a city level, and cookies or similar identifiers. See Section 12.
Sensitive information: because our product range relates to intimacy, sexuality and disability, the fact that someone has placed an order can itself reveal something about their health, disability or personal circumstances. We treat all order information handled through Focus on Intimacy as sensitive information under APP 3, and apply a higher standard of care to its collection, storage and disclosure than we would to ordinary retail data.
3. How we collect personal information
- Directly from prescribers when they register an account, place an order, or contact us.
- Directly from customers using our direct purchase pathway.
- From a prescriber, where they are ordering on behalf of a participant.
- From a funding body, where they contact us about an invoice or approval.
- Automatically through the Site, via Shopify's standard analytics and cookies.
4. Why we collect, hold, use and disclose personal information
We collect and use personal information to:
- process, fulfil and deliver orders, including arranging for our suppliers to send products directly to the correct recipient;
- invoice the correct funding body, and provide the reference or approval information they require;
- provide customer service, including managing warranty claims and product issues;
- communicate with prescribers and customers about their orders, account, or (where consented to) new products and resources;
- maintain our own business records for accounting, tax and legal purposes; and
- comply with our legal obligations, including under the Privacy Act, the Australian Consumer Law, and the requirements of relevant funding schemes.
5. Disclosure of personal information
We disclose personal information only where necessary, and only to the following categories of recipients:
5.1 Suppliers
We hold a small amount of stock ourselves, and also work with wholesale suppliers who fulfil some orders directly on our behalf. Where a supplier is fulfilling your order, we pass on the minimum information needed for delivery — typically the recipient's name, delivery address, a contact phone number, and the product ordered. Suppliers are not given any clinical information, funding/scheme details, or the reason for the order.
5.2 Funding bodies
Where an order is being funded by iCare, the NDIS, a CTP insurer, or another compensable scheme, we disclose the information that scheme requires to process payment — which may include the participant's name, the order details and cost, the relevant approval or reference number, and the prescriber's details. We only disclose what the scheme requires for invoicing and do not disclose clinical notes or diagnostic information, as we do not collect these in the first place.
5.3 Service providers who help us run our business
We share limited personal information with providers who help us operate, including our website and e-commerce platform (Shopify), our payment processor, our delivery carriers, our accounting software, our website analytics provider (Google Analytics), and our IT and website development providers. These providers are only permitted to use personal information to provide services to us, and not for their own purposes.
5.4 What we do not do
- We do not sell or rent personal information to any third party.
- We do not disclose participant information to a supplier's marketing lists, or to any party for direct marketing purposes, without consent.
- We do not publish, or ask suppliers to publish, any identifying information about a participant or the nature of their order.
6. Overseas disclosure of personal information
Some of the products in our range are sourced from suppliers or manufacturers located overseas. Where this applies to a product you order, limited delivery information (as described in Section 5.1) may be disclosed to that overseas supplier so they can fulfil the order, or the order may be fulfilled via an Australian-based distributor on the overseas supplier's behalf wherever that arrangement is available.
Before disclosing personal information to an overseas recipient, we take reasonable steps to ensure it will be handled consistently with the Australian Privacy Principles — for example, by limiting what is disclosed to the minimum needed for delivery, and by preferring suppliers who agree to appropriate privacy and confidentiality terms. However, an overseas recipient may not be subject to the Privacy Act 1988 (Cth) or the same privacy protections that apply in Australia, and we cannot always guarantee equivalent protection once information leaves Australia.
By placing an order for a product that we disclose is sourced or fulfilled overseas, you consent to this disclosure occurring on the basis described in this Section. If you would prefer not to proceed on this basis, please contact us before placing the order and we will let you know what Australian-fulfilled alternatives may be available.
We also use Google Analytics to understand how the Site is used, as described in Section 12. Information collected by Google Analytics is processed by Google on servers that may be located outside Australia, and Google may not be subject to the Privacy Act 1988 (Cth). We have configured Google Analytics so that it is not sent any information about what has been ordered, who it is for, or any funding or scheme details.
Separately, the Site is hosted on Shopify's global infrastructure, which may involve your information being processed outside Australia as part of Shopify's own service delivery. This is described in the Shopify Consumer Privacy Policy.
7. Storage and security of personal information
We store personal information using secure, access-controlled systems, and take reasonable technical and organisational steps to protect it from misuse, interference, loss, unauthorised access, modification or disclosure, including restricting access to staff who need it to do their job. No method of electronic storage or transmission is completely secure, and while we take reasonable steps to protect personal information, we cannot guarantee its absolute security.
8. How long we keep personal information
We retain personal information for as long as we need it to fulfil the purposes described in this Policy, including to meet our record-keeping obligations under tax, corporations and funding-scheme requirements, and then take reasonable steps to destroy or de-identify it.
9. Direct marketing
We will only send marketing communications (such as information about new products or resources) to prescribers or customers who have opted in, or where we reasonably believe they would expect to receive this information given our existing relationship.
You can unsubscribe or opt out of marketing communications at any time by using the unsubscribe link in any email we send, or simply by emailing welcome@focusonintimacy.com.au and letting us know. The same email address is also the right place to send us any feedback, questions or concerns about how we handle your information.
10. Access to and correction of personal information
You may ask us for access to the personal information we hold about you, or ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. We will respond within a reasonable period. In some circumstances we may not be able to provide access — for example, if this would unreasonably impact the privacy of another person — and if so we will explain why.
11. Notifiable data breaches
If we experience a data breach that is likely to result in serious harm to an individual whose personal information we hold, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme under the Privacy Act.
12. Cookies and website analytics
Our Site, hosted on Shopify, uses cookies and similar technologies to operate the online store, remember your cart, and understand how visitors use the Site. Further detail about Shopify’s own use of cookies is available in the Shopify Consumer Privacy Policy.
Google Analytics. We use Google Analytics 4, a service provided by Google, to understand how people find and use the Site so that we can improve it. Google Analytics places cookies or similar identifiers in your browser and collects information such as the pages you view, how long you spend on them, how you arrived at the Site, the type of device and browser you are using, and an approximate location worked out from your internet connection at a city level. Google Analytics 4 does not store your full IP address.
What we deliberately do not send to Google. Because of the nature of what we supply, we treat order information as sensitive information under APP 3, as explained in Section 2. We have set up Google Analytics so that it is not sent the names of products viewed or purchased, order contents, participant or prescriber details, or any funding or scheme information. Google can see that the Site is being used. It is not told what anyone has bought or who they are.
Where this information goes. Google processes this information on its own servers, which may be located outside Australia. See Section 6.
How to opt out. You can control or disable cookies through your browser settings, though some parts of the Site may not function properly if you do. You can also opt out of Google Analytics entirely, on any website, by installing the Google Analytics Opt-out Browser Add-on from tools.google.com/dlpage/gaoptout.
13. How to contact us or make a complaint
If you have a question about this Policy, want to access or correct your information, or wish to make a complaint about how we have handled personal information, please contact us using the details at the end of this Policy. We will acknowledge your complaint and aim to respond within 30 days. If you are not satisfied with our response, you may lodge a complaint with the OAIC at www.oaic.gov.au or by calling 1300 363 992.
14. Australian Consumer Law
This Privacy Policy deals with personal information handling. It does not limit or affect any consumer guarantee, refund, repair, replacement or other right you have under the Australian Consumer Law (Schedule 2 to the Competition and Consumer Act 2010 (Cth)). Our separate Return and Refund Policy and Terms of Service set out how those rights apply to purchases made through the Site.
15. Changes to this Policy
We may update this Policy from time to time to reflect changes in our practices or the law. The current version will always be available on the Site.