At Habi Pharma Pty Ltd (ABN 44 615 586 215) trading as Little Green Pharma (LGP) we recognise the importance of protecting the privacy and the rights of individuals. This Privacy Policy has been published to provide a clear outline of how and when personal information and other data is collected, disclosed, used, stored and otherwise handled by LGP and its related companies. The Policy relates to personal information and other data collected by any means and by any technology and assumes that you are an Australian resident.

By using LGP’s websites, products or services, you consent to LGP using your personal information and other data as set out in this Privacy Policy.  If you are under the age of 18, please provide this Privacy Policy to your parent or guardian before providing us with your personal information.

We respect your rights to privacy and have a legal obligation to abide by the provisions of the Privacy Act 1988 (Cth) (the Act). Our objective is to handle information responsibly and provide you with some control over the way information about you is handled.

Personal information

When used in this privacy policy, the term “personal information” has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation.  Information which cannot be reasonably linked to your identity (e.g. IP address, browser information, favourite websites or the number of users of a website) does not constitute personal information and is not regulated by the Privacy Act 1988 (Cth).  If the information we collect personally identifies you, the information will be considered personal information. Our privacy policy covers all people who use our services or otherwise provide their personal information to us.

For the purposes of this privacy policy, no distinction has been made between the handling of personal information and sensitive information (as that term is defined in the Act); therefore all information will be referred to as “personal information” throughout this document.

Collection of Personal Information and other data

The nature of personal information collected by LGP may comprise information such as:

  • your name, email, address and telephone number;
  • your age or date of birth;
  • your gender
  • your AHPRA number;
  • your profession, occupation or job title;
  • any additional information relating to you that you provide to us directly through our representatives, medical or allied health professionals.

We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.

We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect it in ways including:

  • by you completing one of our contact us forms;
  • through your access and use of our website and social media channels.

We may also collect personal information from third parties including:

  • information provided on your behalf with your consent;
  • from third party bodies such as law enforcement agencies and other government entities.
Use & Disclosure of Personal Information and other data

The purposes for collecting such personal information include to arrange and conduct and LGP’s business activities and functions (including but not limited to production, and manufacturing of medicinal cannabis), understand our audiences and provide you with requested products and services.

We collect, hold, use and disclose your personal information for the following purposes:

  • for administrative and billing purposes;
  • to update your contact details;
  • to process and respond to any complaint made by you;
  • 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;
  • for the purposes of data research and analysis including conducting clinical trials and proactive screenings and for the purpose of sending you direct marketing communications in relation to these;
  • to answer enquiries and provide information or advice about existing and new products or services and all matters relevant to the services we provide to you;
  • to conduct business processing functions including providing personal information to our related bodies corporate, 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 LGP, its contractors or service providers; and
  • to meet obligations of notification to our medical defence organisations or insurers.

Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy or as permitted under the Act.

On some occasions, your personal information and other data may be transferred to or processed by service providers in overseas countries including but not limited to the US, or even in ‘the cloud’ (which may involve processing in more than one country) in order for such service providers to perform services on our behalf.

Like most business organisations, LGP performs some of its functions under licence and also contracts out some functions and relies on third party suppliers to conduct specialised activities such as website management, IT systems administrators, share registry services, mail out services, couriers, call centre services, data analysis and processing services, electronic network administrators, insurance broking, supply of equipment, engineering services, security services, financial services, credit reporting services, and professional advisors such as accountants, solicitors, business advisors and consultants. Personal information may be provided to these licensors (where contractually required) and to these suppliers to enable them to perform the agreed tasks.

Some companies that LGP is affiliated with have their own privacy policies and where they collect personal information from you for their own business, your personal information will be handled in accordance with their Privacy Policy.

Direct communications

We may send you educational communications and information about our products and services that we consider may be of interest to you, if you have advised you wish to receive them. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with all applicable marketing laws, such as the Spam Act 2003 (Cth). If, in your dealings with us, you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving communications from us by contacting us or by using opt-out facilities provided in the communications and we will then ensure that your name is removed from our mailing list.

Access and correct your personal information

LGP’s objective is to ensure that all personal information collected is accurate, complete and up-to-date. To assist LGP in achieving its objective, please contact the Privacy Officer if any of your details change. Further, if you believe that the information LGP holds is not accurate, complete or up-to-date, please contact the Privacy Officer on info@lgpharma.com.au in order to have the information corrected.

You may request access to any personal information we hold about you at any time by contacting us. Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you and, if so, the fees will be as advised from time to time. We will not charge for simply making the request and will not charge for making any corrections to your personal information.

There may be instances where we cannot grant you access to the personal information we hold; however, we will only do so in accordance with our rights and obligations under the Act. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

Personal Information Security

LGP take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. Your personal information and other data may be stored in hard copy documents, but is generally stored electronically on our software or systems or on those of our third-party service providers. Personal information is destroyed or de-identified when no longer needed.

As our website is linked to the internet, and the internet is essentially insecure, LGP cannot provide any assurance regarding the security of transmission of information you communicate to us online. LGP also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Additionally, you acknowledge that the collection and use of your personal information by third-parties may be subject to separate privacy policies and/or the laws of other jurisdictions.

Complaints process

If you believe that your privacy has been breached, please contact us in accordance with the arrangements set out below and provide details of the incident so that we can investigate it.

We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.

All complaints should initially be in writing and directed to the Privacy Officer.

Privacy Officer’s Contact Details

Please address all written correspondence to:

Privacy Officer
Little Green Pharma
PO Box 3475
Crawley, WA 6009

Email: info@lgpharma.com.au

External Links

Our website may contain links to other websites operated by third parties. LGP make no representations or warranties in relation to the privacy practices of any third-party website and are not responsible for the privacy policies or the content of any third-party website. Third party websites are responsible for informing you about their own privacy practices.

Changes to this policy

We may change this privacy policy from time to time. Any updated versions of this privacy policy will be posted on our website. We ask that you visit our website periodically in order to remain up to date with such changes.

This privacy policy was last updated on 10 August 2017.