Privacy Policy

This Privacy Policy applies to Mark Bellgrove (Carrara) Pty Ltd ACN 140 483 727 atf Carrara Pharmacy Trust and Matthew Bellgrove Pharmacy Pty Ltd ACN 140 521 866 atf Gooding Drive Pharmacy Trust trading as National Custom Compounding and our Associated entities having the meaning set out in section 50AAA of the Corporations Act 2001 (Cwth) ( “NCC”, “we”, “us” ). We are committed to safeguarding personal privacy and recognise that you have a right to control how your personal information is collected and used. Unless you give us consent to do otherwise, we will only collect and use personal information as set out below. This Privacy Policy complies with Australian privacy legislation, in particular the Privacy Amendment (Enhancing Privacy Protection) Act 2012 which amends the Privacy Law 1988 and the Australian Privacy Principles (the Privacy Law).

1. Types of Information Collected

The types of information we collect from you depend on the circumstances in which the information is collected. We may collect contact details including your name, occupation, address, email address, phone and fax numbers and your date of birth. We may also collect answers you provide to questions we ask and other information in relation to your dealings with NCC. If you purchase products or services from us, we may also collect certain transactional information such as your credit card details, debit account and other financial details to process the transaction. We may collect contact details including your name, occupation, address, email address, phone and fax numbers and your date of birth. We may also collect answers you provide to questions we ask and other information in relation to your dealings with NCC. If you purchase products or services from us, we may also collect certain transactional information such as your credit card details, debit account and other financial details to process the transaction. If you are a contractor to NCC we may collect information relevant to your engagement with us including qualifications, resume, reference information from your nominated referees, tax file number, bank account details and training records. If we are providing you with, or assisting your heath service provider or treating health professional (such as a doctor, pharmacist or hospital) to provide you with a heath related service, we may collect your health information and, in such circumstances, you consent to us collecting that information and to us using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Privacy Law, applicable health records legislation and other relevant laws. In certain circumstances we are required to collect government identifiers such as tax file numbers, Medicare numbers, health service provider numbers, pension numbers and Veteren’s Affairs numbers. You consent to us collecting that information for the purpose for which you disclosed it to us. We only collect, use and disclose such information as permitted or required by law. Generally, you have no obligation to provide any personal information requested by us. However, if you choose to withhold requested personal information we may not be able to provide you with the products and services that depend on the collection of that information.

2. How do we collect information?

We collect personal information from you in a number of ways such as: • directly from you when you provide it to us, our agents or contractors; • via our website when you deal with us online; • from publicly available sources; • from credit reporting agencies; • from our Associated entities; and • from third parties e.g. your health service provider or treating health professional (such as a doctor, pharmacist or hospital) in connection with providing a health-related service to you. In addition to the above methods of collection, NCC may collect personal information as otherwise permitted or required by law.

3. Purpose of collection, use and disclosure of personal information

The purposes for which we use and disclose your personal information will depend on the circumstances in which we collect it. Whenever practical we endeavour to inform you why we are collecting your personal information, how we intend to use that information and to whom we intend to disclose it at the time we collect your personal information. We may use or disclose your personal information for the purposes for which we have collected, for purposes to which you have consent or as otherwise authorised or required by law. Unless otherwise required or permitted by law, we will only collect health information about you with your consent and we will only use that information for the primary purpose for which it was collected. In some circumstances, we may collect your health information through third parties (e.g. from health care professionals, such as pharmacists, who are treating you). We will only do this if you have consented or where otherwise permitted or required by law. Some of the specific purposes for which we collect, use and disclose personal information are: • to respond to you if you have requested information (including via our websites or via an email or other correspondence you send to us); • to provide goods or services to you, to assist a health professional or service provider to provide you with certain services (e.g. health services) or to receive goods or services from you; • to administer and manage services, including charging, billing and collecting debts; • to enable you to participate in any loyalty programs that we conduct; • to improve our products and services and keep you up to date on such improvements; • to understand our customer base and help tailor our products and services; • to contact you (directly or through our service providers) to obtain your feedback, to find out your level of satisfaction with our products and services and for other market research activities; • to verify your identity; • to address any issues or complaints that we or you have regarding our relationship; and • to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone, by fax or in any other lawful manner.

4. Who do we disclose your information to?

NCC recognises the trust with which you provide personal information, and such information will not be used or disclosed to third parties except for purposes set out above. This may include disclosing your personal information to the following types of third parties: • our Associated entities; • health service providers or treating health professionals (such as your doctor, pharmacist or hospital), in connection with providing health-related goods or services to you or as otherwise required or authorised by law; • our contractors and other third parties that provide goods and services to us (including suppliers, marketing agencies, data analysis specialists, data processing organisations, billing and debt recovery providers, website and data hosting providers, loyalty program administrators and other IT suppliers); • our accountants, insurers, lawyers, auditors and other professional advisers; • government and regulatory authorities, courts, tribunals and other bodies as required or authorised by law; • in an emergency, to medical and health service providers; • any third parties to whom you have directed or permitted us to disclose your personal information; • in the event that we or our assets may be acquired or considered for acquisition by a third party, that third party and its advisors; • carefully selected third parties with whom we have data sharing arrangements; • third parties that require the information for law enforcement or to prevent a serious threat to public safety; and • otherwise as permitted or required by law. Where we disclose your personal information to third parties we will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose we disclosed it to them and in a manner consistent with the Privacy Principles under the Privacy Law and relevant health records legislation, e.g. by (where commercially practical) including suitable privacy and confidentiality clauses in our agreement with a third party service provider to which we disclose your personal information. We do not disclose the personal information that we collect from you outside of Australia.

5. Use of websites and applications

Our websites may contain links to other sites. This Privacy Policy applies to our websites and not any linked sites which are not operated or controlled by us. You should read the privacy policy of each website that collects your personal information. We use “cookies” and similar technology on its websites and in other technology applications. The use of such technologies is an industry standard, and helps us monitor the effectiveness of our advertising and how visitors use our websites/applications. We use such technologies to generate statistics, measure your activity, improve the usefulness of our websites/applications and to enhance your experience. If you prefer not to receive cookies you can adjust your browser to refuse cookies or to warn you when cookies are being used. However, our websites may not function properly or optimally if cookies have been turned off.

6. Data Security

We will take all reasonable steps to store and hold your personal information securely through physical and electronic means. Please notify us immediately if you become aware of any breach of security. Our employees and data processors are obliged to respect the confidentiality of any personal information held by us. However, security of communications over the internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. To the extent permitted by law, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information. Nothing in this Privacy Policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).

7. Access & Correction

We aim to ensure that the personal information we hold is accurate, complete and up-to-date. To assist us with this, please contact us as soon as possible if you are aware of any changes required to your personal information. We rely on the accuracy of personal information as provided to us both directly (from you) and indirectly. You have a right to access the personal information that we hold about you by contacting us at the contact details mentioned at paragraph 9 below. We will provide access to information in accordance with the Privacy Laws and health records legislation, subject to certain exemptions which may apply. We may require that the person requesting access provide suitable identification and where permitted by law, we may charge an administration fee for granting access to your personal information.

8. Complaints

We place high priority on effectively dealing with any complaints you might have about breach of your privacy. We prefer that complaints about breaches of the Privacy Law are made or confirmed in writing so that we can be sure about the details of the complaint. Generally, we will only accept complaints from an individual who believes an act or practice of the NCC has interfered with their privacy and may have breached one of the Privacy Laws. A complaint should identify whether it is about: • the collection, use or disclosure of personal information; • the security or storage of personal information; • the accuracy of personal information; • a refusal to give access to, change or delete personal information. Our Privacy Officer will normally deal with privacy complaints. If the Privacy Officer is involved in the conduct the complaint is about, the complaint will be dealt with by an alternative officer appointed by us who was not involved in the complaint. We will attempt to confirm with the complainant: • their understanding of the conduct relevant to the complaint; • their understanding of the Privacy Law relevant to the conduct; • what they expect as an outcome. We will inform the person making the complaint: • whether we will conduct an investigation; • the name, title and contact details of the investigating officer. After we have completed our enquiries, we will contact the complainant, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If a response is received, we will assess it and advise if we have changed our view. If the complainant is unsatisfied with the outcome, we will advise further options including, if appropriate, review by the Privacy Commissioner within the Office of the Australian Information Commissioner.

9. Contact us

Please contact us if: • you have any queries in relation to the privacy policy of the NCC; or • you would like to know what personal information we hold about you and how you can gain access to it; or • you believe that your privacy has been breached and you wish to make a complaint. You may contact us by writing to: The Privacy Officer National Custom Compounding Suite 5/166 Gooding Drive, Merrimac, QLD 4226 Email: [email protected] Phone: 1300 731 755 Any requests to access, update or correct your health information should be made in writing.  
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