Last updated: January 2025
1.1 GLENO HOLDINGS PRIVATE LIMITED (ACN [691 755 389] ("we", "our", or "us") is committed to maintaining the security of personal information ("Personal Information") provided to us and providing a compliant and transparent approach to data protection.
1.2 When you share Personal Information with us, we treat it with care and take our responsibility to protect it seriously.
1.3 We adhere to the Australian Privacy Principles in the Privacy Act 1988 (Cth) ("Privacy Act"), the Privacy Amendment (Notifiable Data Breaches) Act 2017 (NDB), and applicable State and Territory laws pertaining to health service providers and the handling of personal information and health records.
1.4 Please read this Privacy Policy carefully as it explains how GLENO HOLDINGS PRIVATE LIMITED collects, stores, and uses your Personal Data in accordance with the EU General Data Protection Regulation (GDPR), where applicable.
1.5 For the purposes of this Privacy Policy, any reference to "GLENO HOLDINGS PRIVATE LIMITED", "we", "our", or "us" refers to the legal entity responsible for providing Gleno.
2.1 Gleno is a software-as-a-service (SaaS) product for dental practice management, developed and provided by GLENO HOLDINGS PRIVATE LIMITED. Our Services include:
(collectively, our "Services")
2.2 GLENO HOLDINGS PRIVATE LIMITED is committed to maintaining high standards of data security. We comply with the applicable standards and obligations set out under the Privacy Act and the GDPR.
2.3 By using Gleno and our website at [insert email], you consent to the collection, processing, and management of Personal Information as described in this Privacy Policy.
3.1 "Personal Information" is information or an opinion that can reasonably identify an individual.
3.2 We collect Personal Information for the primary purpose of supplying our Services, providing information to our Customers, and marketing (with consent).
3.3 GLENO HOLDINGS PRIVATE LIMITED collects the following types of Personal Information:
(a) Customer Personal Information: name, title, dental clinic or business name, practitioner registration details, address, phone number, email address, payment details (e.g., credit/debit card), and any other information necessary to provide our Services.
(b) Marketing Personal Information: so we can market our Services or those of third parties in accordance with your preferences. We will obtain explicit consent before sharing Personal Information with any third party for marketing. You can unsubscribe at any time via an opt-out link.
3.4 We may also collect Personal Information when you:
3.5 GLENO HOLDINGS PRIVATE LIMITED may also collect other Personal Information you provide while interacting with Gleno or our website.
3.6 Some Gleno features utilize OAuth2 to securely send emails via O365 or Google Mail. Only the sender's email address and the refresh token required for OAuth2 are stored locally, encrypted, and not shared. Users can delete their sender email at any time.
4.1 As part of our Services, we process patient data uploaded by our Customers, which may include health information, racial or ethnic origin, and genetic data ("Sensitive Data").
4.2 Sensitive Data may include: name, contact information, date of birth, treatment notes, health insurance details, Medicare numbers, accounting details, images, and other health information submitted by Customers.
4.3 Sensitive Data is used only to provide Gleno's Services or where required by law.
4.4 Customers are responsible for obtaining explicit consent from patients, including minors, when uploading their Personal Information and Sensitive Data.
4.5 We use high-level encryption and document protection for all Sensitive Data.
5.1 GLENO HOLDINGS PRIVATE LIMITED collects Personal Information when you interact with us electronically, access our website, or use Gleno.
5.2 We may also receive Personal Information from third parties, which we will protect in accordance with this Privacy Policy.
6.1 We use your Personal Information to:
(a) Provide and improve Gleno's Services
(b) Administer our business
(c) Process transactions
(d) Conduct research and data analytics
(e) Communicate with you via phone, email, SMS, or mail
(f) Meet legal, regulatory, and compliance obligations
(g) Investigate complaints
6.2 If you choose to withhold your Personal Information, it may not be possible to provide Gleno's Services or respond to your inquiries.
7.1 We share Personal Information only for the purposes described in this Privacy Policy.
7.2 We may disclose Personal Information to employees, agents, suppliers, subcontractors, or government bodies as required.
7.3 Third-party service providers may assist us with Gleno's Services or payment processing.
7.4 All third parties must use Personal Information confidentially and only for the specified purpose.
7.5 In the event of a business sale or transfer, Personal Information may be transferred to the new owner, where legally permissible.
8.1 Personal Data refers to information relating to an identifiable natural person.
8.2 The legal basis for processing depends on the purpose:
(a) Contractual: to fulfill a contract with you
(b) Consent: where you provide explicit consent
(c) Legitimate interest: for improving Services or responding to inquiries
(d) Legal obligation: where required by law
8.3 We retain Personal Data only as long as necessary for the purpose collected.
8.4 Third-party processors are required to comply with GDPR and follow our instructions.
9.1 Data may be stored or processed outside Australia, including countries with adequate data protection laws.
9.2 For EU users, we use approved safeguards for international transfers (Standard Contractual Clauses or Privacy Shield-certified entities).
9.3 If safeguards do not apply, we will obtain explicit consent for data transfer.
10.1 We implement physical, electronic, and managerial safeguards to protect data.
10.2 A "Data Breach" is any incident compromising the integrity of Personal Information likely to cause serious harm.
10.3 We have procedures and personnel to respond to breaches and will notify affected users and regulators as required.
10.4 Please report suspected breaches via the Contact Us section on our website.
11.1 Keep your Personal Data accurate and up to date.
11.2 You have the right to:
(a) Access your data
(b) Correct inaccuracies
(c) Request deletion ("right to be forgotten")
(d) Restrict processing
(e) Data portability
(f) Object to processing
(g) Object to automated decision-making
11.3 Contact us to exercise these rights. Verification of identity may be required.
11.4 Requests will be processed within 1 month and provided digitally, free of charge.
12.1 We collect anonymous data from website and social media interactions, including IP address, browser type, device info, and language.
12.2 We use cookies, pixels, tags, and Google Analytics to improve the website and Services.
13.1 You may request details of Personal Information we hold.
13.2 Contact us to correct, update, or request a copy of your data.
If you have complaints, contact us and we will respond promptly.
We may modify this Privacy Policy at any time; changes are effective immediately upon posting on our website.
16.1 Contact us via:
(a) Website: https://www.glenodental.com/
16.2 Our Data Protection Officer: [insert email]
© 2025 GLENO HOLDINGS PRIVATE LIMITED. ALL RIGHTS RESERVED.