• the Site; and
• our products and services.

By accessing or using the Site or any of our products or services, you indicate that:

• you have read and understood this policy; and
• you agree that your access to, or use of, the Site or any of our products or services indicates your consent to the policy.

If you have any questions about this policy, you can contact us using the details below.

WHAT IS PERSONAL INFORMATION AND WHY DO WE COLLECT IT?

Personal Information is information or an opinion about an identified individual or an individual who is reasonably identifiable, whether or not the information is true or recorded in a material form. We collect and use Personal Information from customers, authorised users and visitors of the Site, purchasers of our products or services, and any other individual who interacts with us.

Examples of Personal Information we collect include:

• your name, address, email address, phone and facsimile numbers;
• information about the products or services you purchase or enquire about, including how the products or services are used;
• your financial information (such as credit card and bank account details), method of payment and any additional information required for user authentication processes; and
• any other information relating to you that is provided to us, including information you provide by email or telephone, through registering an account on the Site or through surveys, at special events and other promotional activities.

SENSITIVE INFORMATION

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

We will only collect and use Sensitive Information, such as your professional association number (eg APHRA), pharmacy registration number or other professional membership information:

• for the primary purpose for which it was obtained, such as to provide our products and services to you;
• for a secondary purpose that is directly related to the primary purpose;
• with your consent; or
• where required or authorised by law.

METHODS OF COLLECTION

We collect your Personal Information in many ways including:

• interviews, correspondence, by telephone and facsimile, by email;
• through your use or purchases of our products or services;
• when you visit the Site or submit information through the Site;
• when you participate in our surveys, competitions, promotions, questionnaires or other promotional activities;
• from your website, from media and publications, from other publicly available sources;
• from cookies and from third parties.

The Personal Information we collect will track and enhance your use of the Site or our products or services, and assist us in providing a better service to you.

COLLECTION FROM YOU

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

COLLECTION FROM THIRD PARTIES

WHERE REASONABLE AND PRACTICABLE TO DO SO, WE WILL COLLECT YOUR PERSONAL INFORMATION ONLY FROM YOU. HOWEVER, IN SOME CIRCUMSTANCES WE MAY BE PROVIDED WITH INFORMATION BY THIRD PARTIES. IN SUCH A CASE WE WILL TAKE REASONABLE STEPS TO ENSURE THAT YOU ARE MADE AWARE OF THE INFORMATION PROVIDED TO US BY THE THIRD PARTY.

If you provide us with Personal Information about another individual, we rely on you to:

• inform the individual that you are providing their Personal Information to us; and
• advise the individual that they can contact us for further information.

You must take reasonable steps to ensure the individual is aware of, and consents to, the matters outlined in this policy, including that their Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual’s right to access that information, and who we are and how to contact us.

You must also assist us with any requests by the individual to access or update the Personal Information you have collected from them and provided to us.

USE AND PURPOSE OF COLLECTION

We collect your Personal Information for the primary purpose of:

• providing our products, services and Site to you;
• providing information to you;
• improving, developing and managing our products, services and Site; and
• marketing, including notifying you of new products or services or other opportunities we think you might be interested in.

We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. Examples include:

• to charge and bill you for our products and services;
• to verify your identify;
• to conduct fraud, risk reduction and creditworthiness checks for delivery of the products or services;
• to perform research and analysis about our products, services and Site;
• to comply with regulatory or other legal requirements;
• for any other purpose to which you have consented; and
• for any other purpose notified to you at the time of collection.

In the event of a merger, acquisition or sale of the whole or part of our business or assets, we reserve the right to transfer your Personal Information as part of the transaction, without your consent or notice to you.

You may unsubscribe from our mailing list at any time by contacting us using the details below.

DISCLOSURE OF PERSONAL INFORMATION

Your Personal Information may be disclosed in a number of circumstances including the following:

• to our employees, related entities, contractors, suppliers and agents for the purpose of providing our products, services and Site;
• to our third party service providers for the purpose of performing business functions on our behalf (including marketing companies, financial and credit card institutions, credit reporting and verification companies, external business advisors such as auditors and lawyers and our insurer);
• to third parties where you consent to the use or disclosure; and
• where required or authorised by law, regulation, standard, industry code or a government request.

When we disclose your Personal Information to any of these third parties, we will ensure that they undertake to protect your privacy. These third parties are not permitted to use the information for any purpose other than the purpose for which they have been given access.

These third parties may also provide us with Personal Information they collect from you. If you disclose Personal Information to them, we rely on you to provide them with consent for us to collect, store, use and disclose your Personal Information.

This policy only covers the use and disclosure of Personal Information we collect from you. The use of your Personal Information by any third party is governed by their privacy policies and is not within our control.

SECURITY OF PERSONAL INFORMATION

Protecting your Personal Information

We take reasonable steps in the circumstances to keep your Personal Information safe and to protect it from misuse, loss and unauthorised access, modification or disclosure. We use a combination of technical, administrative, and physical controls to protect and maintain the security of your Personal Information.

Wherever possible, we procure that our authorised third parties who have access to your Personal Information take reasonable steps to:

• protect and maintain the security of your Personal Information; and
• comply with the relevant APPs when your accessing and using your Personal Information.

No guarantee

The transmission of information via the internet is not completely secure. While we do our best to protect your Personal Information, we cannot guarantee the security of any Personal Information transmitted through the Site. You provide your Personal Information to us at your own risk and we are not responsible for any unauthorised access to, and disclosure of, your Personal Information.

Destruction of Personal Information

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information, unless we are required or authorised by law to retain it. Most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Suspected data breach

We have a comprehensive data breach notification policy and response plan, which outlines the steps we will take in the event of a suspected data breach. This allows us to identify and deal with a data breach quickly to mitigate any harm that may result.

As part of the response plan, we will notify you as soon as practicable if we:

• discover or suspect that your Personal Information has been lost or accessed by, or disclosed to, any unauthorised person or in any unauthorised manner;
• believe that you are likely to suffer serious harm as a result; and
• are unable to prevent the likely risk of harm.

If you would like more information about our response plan, please contact us using the details below.

DIRECT MARKETING

We may use your Personal Information to send you information, including about our product and service offerings, where you have expressly or impliedly provided your consent for us to do so or we are permitted to do so by law.

We may send this information to you via the communication channels specified at the time you provide your consent. These communication channels may include mail, email, SMS, social media or by customising online content and displaying advertising on our Site. These communications may continue even after you stop using our products or services.

You can unsubscribe from our mailing list by:

• contacting us using the details below; or
• using the unsubscribe function in the email or SMS.

LINKS TO OTHER SITES FROM OUR SITE

Our Site may contain hyperlinks or banner advertising to or from third party websites. We do not endorse any of these third parties, their products or services, or the content on these websites.

These websites are not subject to our privacy standards, policies and procedures. Therefore, we recommend that you make your own enquiries about their privacy practices. We are in no way responsible for the privacy practices or content of these third party websites.

COOKIES

We may collect information when you access and use our Site by utilising features and technologies of your internet browser, including cookies and similar technologies. A cookie is a piece of data that enables us to track and target your preferences.

The type of information we collect may include statistical information, details of your operating system, location, your internet protocol (IP) address, the date and time of your visit, the pages you have accessed, the links which you have clicked and the type of browser that you were using.

We may use cookies and similar technologies to:

• allow us to identify you as a return user and personalise and enhance your experience and use of our Site; and
• help us improve our service to you when you access our Site and ensure that our Site remains easy to use and navigate.

Most browsers are initially set up to accept cookies but you can reset your browser to refuse all cookies or warn you before accepting cookies. If you reject our cookies or similar technologies, you can still use the Site but may only have limited functionality.

We may also use your IP address to analyse trends, administer the Site and other websites we operate, track traffic patterns and gather demographic information. Your IP address and other personal information may be used for credit fraud protection and risk reduction.

ACCESS TO YOUR PERSONAL INFORMATION

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions provided by law. If you wish to access your Personal Information, please contact us in writing using the details below.

If we do not provide you with access to any part of your Personal Information, we will tell you why in writing. We will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

MAINTAINING THE QUALITY OF YOUR PERSONAL INFORMATION

IT IS IMPORTANT TO US THAT YOUR PERSONAL INFORMATION IS UP TO DATE. WE WILL TAKE REASONABLE STEPS TO MAKE SURE THAT YOUR PERSONAL INFORMATION IS ACCURATE, COMPLETE AND UP-TO-DATE. IF YOU FIND THAT THE INFORMATION WE HAVE IS NOT UP TO DATE OR IS INACCURATE, PLEASE ADVISE US AS SOON AS PRACTICABLE SO WE CAN UPDATE OUR RECORDS AND ENSURE WE CAN CONTINUE TO PROVIDE QUALITY SERVICES TO YOU.

POLICY UPDATES

We may change this Policy from time to time at our sole discretion. Any revised policy will be posted on our Site and effective from the time of posting. Your continued use of our products, services or Site following the posting of any revised policy indicates your acceptance of the changes to the policy. You should regularly check and read the policy.

COMPLAINTS

If you have any questions or concerns about this policy or the way we handle your Personal Information, please contact us using the details below and provide full details of your complaint and any supporting documentation.

Privacy complaints will:

• be treated seriously;
• be dealt with promptly;
• be dealt with in a confidential manner; and
• not affect your existing obligations or commercial arrangements with us.

Our Privacy Officer will endeavour to:

• respond to you within 10 business days; and
• investigate and attempt to resolve your concern within 30 business days or any longer period necessary and notified to you by our Privacy Officer.

CONTACT DETAILS

Level 1, 1 Queens Rd, Melbourne, Victoria, 3004

Last updated: 17 May 2019