We value your privacy and we work hard to protect the information you provide to us.
Cannatrek Limited (ACN 056 175 369) (Cannatrek) supplies medicinal cannabis goods and services. Cannatrek is bound by the Australia Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act).
1 CONSENT TO COLLECT AND USE YOUR PERSONAL INFORMATION
If we need to use your information for anything else, we will seek additional consent from you to do this.
2 HOW WE COLLECT YOUR PERSONAL INFORMATION
We may collect the personal information you directly give us through some of the following means:
- By completing one of our contact us forms or through an internet portal;
- Through email in relation to enquiries from you or responses to emails sent to you or phone calls, texts or other forms of communications with any of our representatives;
- In response to product queries or engagement with our representatives; through your access and use of our websites (including the Site) and social media channels;
- By review of your medical records including clinic letters or test results from other health care providers; and
- In connection with clinical trials, patient or doctor surveys, questionnaires or other trials or testing activities.
Generally, we endeavour to collect your personal information directly from you unless it is unreasonable or impracticable to do so. In addition, we may also collect personal information from other sources including:
- Agents and service providers such as customer relationship management service providers and third-party service providers;
- Information provided on your behalf with your consent or through direct contact with your guardian, other family members or your doctor/healthcare provider;
- From third party bodies such as your health fund, hospitals or other community health services, law enforcement agencies and other government entities, including Medicare and Department of Veterans Affairs; and
- Publicly available sources including directories, listings and the internet.
We may also collect personal information from publicly available sources and third parties, such as suppliers, contractors, our clients and business partners. If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.
3 TYPES OF PERSONAL INFORMATION WE COLLECT
The type of personal information we may collect could include (but is not limited to):
- Your name, email, address and telephone number;
- Your age or date of birth;
- Your gender;
- Your AHPRA number (if you are a healthcare practitioner);
- Your profession, occupation or job title;
- Your social media identities and interests;
- If you transact or deal with us, your financial information, including credit card details;
- Your medical history and any medical conditions, or the medical history or medical conditions of your children or children in respect of which you are a guardian; including medications (past and current), allergies, adverse events (side effects), immunisations, social history, family history, risk factors, and test results; and
- Any additional information relating to you that you provide to us directly through our representatives, medical or allied health professionals.
Where you do not wish to provide us with your personal information, we may not be able to provide you with any requested goods or services.
4 USE AND DISCLOSURE OF PERSONAL INFORMATION
We may collect, hold, use and disclose your personal information for any of the following purposes:
- to offer and provide you with our goods and services including healthcare and educational services;
- to manage and administer therapeutic goods and services, including account keeping procedures;
- to communicate with you about, including (but not limited to), the goods and services you have sought, email you tax invoices, dispatch and track information, returns and exchange authorisations;
- to send you marketing or promotional information in relation to Cannatrek or any of Cannatrek’s business partners that might be of interest to you (including via SMS, email and personalised Site experiences);
- improve Cannatrek’s products and services, including research and development;
- to consider your application for employment (if applicable);
- for administrative and billing purposes;
- to update your contact details;
- to process and respond to any compliment or complaint made by you;
- to share with legal and regulatory bodies, including to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country, including any accreditation agencies;
- to use within Cannatrek to understand our adverse events (side effects) and treatment effects of medical cannabis and develop and improve current and future products;
- for data research and analysis for the purposes of (a) searching for trends within information received from yourself and patients (including third party data) between products and conditions or illnesses; (b) improving Cannatrek’s products; and (c) identifying new or alternative Cannatrek products that may be beneficial to you, and sending you direct communications in connection with such products or related services;
- to answer enquiries and provide information, offers and advice to you about both existing and new products, services or opportunities that might be of interest to you and in relation to all matters relevant to the products and services we provide to you;
- to administer conferences, symposia, expert panels, seminars or other similar programs organised by us, which you agree to participate in or be involved with;
- to advise you in connection with and administer any clinical trials, surveys or other
- matters in which you have expressed an interest or have participated in;
- to discuss with and disclose to your health practitioner(s) and dispensing pharmacies;
- to conduct business processing functions including providing personal information to our related bodies corporate and affiliates, contractors, service providers or other third parties;
- for the administrative, marketing (including direct communications), planning, product or service development, quality control and research purposes of Cannatrek and its related bodies corporate;
- to facilitate the performance of any services or functions we provide to you using third parties, including contractors;
- to disclose to any body corporate or any entity which controls or holds a significant shareholding in Cannatrek or its related bodies corporate for the purpose of carrying out any of the services, functions, activities or tasks permitted to be carried out by Cannatrek under this Policy;
- for the supply to third parties on a de-identified basis to assist product improvement and enhancement of global understanding of cannabis treatments;
- in connection with the unlikely event of a bankruptcy or insolvency; and
- to meet obligations of notification to our medical defence organisations or insurers
Cannatrek and/or external parties may also require access to, and disclosure of, your personal information in the following circumstances:
- Where it is necessary to provide health care;
- Where it is necessary to facilitate the running of Cannatrek’s business; or
- Where we are legally obligated to do so in order to co-operate with a law enforcement authority or court order.
5 PROTECTION OF PERSONAL INFORMATION
We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers, which may be located overseas.
We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of personal information. This also applies to disposal of personal information.
We further protect personal information by restricting access to personal information to only those who need access to the personal information do their job. Physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your personal information.
We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.
6 DIRECT MARKETING
Like most businesses, marketing is important to our continued success. We believe we have a unique range of products and services that we provide to customers at a high standard. We therefore like to stay in touch with customers and let them know about new opportunities. We may provide you with information about new products, services and promotions either from us, or from third parties which may be of interest to you.
We will not disclose your personal information to third parties for marketing purposes without your consent.
You may opt out at any time if you no longer wish to receive commercial messages from us. You can make this request by unsubscribing from all future marketing messages by following unsubscribe links included in each marketing email or by contacting our Privacy Officer.
8 ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
You have the right to request access to, and correction of, your personal information.
Cannatrek will take reasonable steps to correct your personal information where the information is not accurate or up to date. From time to time, we may ask you to verify that your personal information held by Cannatrek is correct and current. You may also request that we correct or update your information, and you should make such requests in writing to email@example.com
We will respond to all requests for access to or correction of personal information within a reasonable time.
9 OVERSEAS TRANSFERS OF PERSONAL INFORMATION
We will not share your personal information with anyone outside of Australia (unless under exceptional circumstances that are permitted by law) without your consent. We do not currently transfer information overseas directly, but we may engage with cloud service providers who store information overseas.
10 RESOLVING PERSONAL INFORMATION CONCERNS
ATT: The Privacy Officer
PO Box 21
Balaclava VIC 3183,
We take all complaints seriously, and will respond to your complaint within a reasonable period.
If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Telephone: 0491 205 199
Whilst research into the efficacy and effects of plant-based medicines, including medicinal cannabis, for certain treatments is increasing, it is currently in it’s early days. Patients should always talk to a health professional for advice on their unique requirements before making any decisions about their treatment options. For the latest and accurate information on medicinal cannabis, please head to the TGA website https://www.tga.gov.au/medicinal-cannabis-guidance-documents