Vert Biotech: Privacy Policy
This Privacy Policy describes how Vert Bio Tech Pty Ltd ("Vert Biotech", "we," "us," or "our") manages personal information when you visit or use the website located at www.vertbiotech.com (the "Site").
We are committed to managing personal information in an open and transparent way in accordance with the Australian Privacy Principles (APPs) contained within the Privacy Act 1988 (Cth), where applicable.
1. Management of Personal Information
We are committed to managing personal information in a secure and transparent way. We have policies, procedures, and systems in place to ensure compliance with the APPs.
This policy outlines:
- The types of personal information we collect and hold.
- How we collect and hold personal information.
- The purposes for which we collect, hold, use, and disclose personal information.
- How an individual may access their personal information and seek correction.
- How an individual may complain about a breach of the APPs and how we will deal with such a complaint.
- Whether we are likely to disclose personal information to overseas recipients (see Section 4).
2. Information We Collect and How We Collect It
We collect and process personal information that is reasonably necessary for one or more of our business functions or activities.
A. Types of Personal Information
- Contact & Identity Data: Name, clinic name, email address, and telephone number.
- Usage & Technical Data: IP address, browser type, operating system, and data about your interaction with our Site (collected via cookies and analytics).
- Sensitive Information: Given the nature of our services, we may collect sensitive information, including health information. We only collect this with your explicit consent, or when legally required.
B. Method of Collection
- Directly from you: When you fill out a contact form, subscribe to a newsletter, or communicate with us via email or phone.
- Integrated Forms: We use embedded forms provided by our CRM processor, HighLevel (GoHighLevel). Information you enter into these forms is securely transmitted directly to our HighLevel account for processing.
- Automatically: Via tracking technologies (cookies) when you navigate the Site.
- Unsolicited Information: If we receive personal information we did not ask for, we will determine within a reasonable period whether we could have collected it under APP 3. If not, we will destroy or de-identify the information as soon as practicable, provided it is lawful to do so.
C. Notification at Collection
At or before the time we collect personal information from you, or as soon as practicable afterwards, we take reasonable steps to notify you of:
- Our identity and contact details.
- The fact and circumstances of the collection.
- The purposes for which the information is collected (as described in Section 3).
- The consequences if the information is not collected.
- The main consequences of not collecting the information (e.g., we cannot respond to your enquiry).
- Any third parties we usually disclose the information to.
- The likelihood of disclosure to overseas recipients (see Section 4).
- Your right to access and correction, and the complaint process.
3. Use and Disclosure of Personal Information
We use and disclose your Personal Information for the primary purpose for which it was collected, or a secondary purpose where:
- You have consented to the use or disclosure; or
- You would reasonably expect us to use or disclose the information for that secondary purpose (if it is directly related to the primary purpose); or
- The use or disclosure is required or authorised by Australian Law or a court/tribunal order.
A. Direct Marketing
We will not use or disclose your personal information for the purpose of direct marketing unless:
- We collected the information directly from you; and
- You would reasonably expect us to use the information for that purpose; and
- We provide a simple means by which you can easily opt-out of receiving direct marketing communications.
4. Cross-Border Disclosure
We may disclose your personal information to overseas recipients. This occurs because we use service providers located outside of Australia for website hosting and customer management. Our website is hosted in Canada. The European Commission recognises Canada as providing an adequate level of data protection for commercial organisations, so additional safeguards are generally not required for this transfer. We process form submissions, manage customer data, and automate communications on our CRM platform in the United States. Other potential recipient countries include: the European Union.
Before disclosing personal information to an overseas recipient, we take reasonable steps to ensure the data is protected. For data transferred to the United States and other non-adequate countries, we rely on Standard Contractual Clauses (SCCs) adopted by the European Commission, which are contractual mechanisms designed to ensure the recipient adheres to GDPR data protection standards. We also ensure our recipients are legally bound not to breach the Australian Privacy Principles (APPs).
5. Anonymity and Pseudonymity
Where it is lawful and practicable, we will give you the option of not identifying yourself or of using a pseudonym when dealing with us (e.g., for general website browsing or submitting a preliminary enquiry). However, for specific services (like processing an order or responding to a detailed R&D request), it may not be practicable to deal with you anonymously.
6. Access and Correction
You have a right to request access to the personal information we hold about you and to seek the correction of any information we hold that is inaccurate, out-of-date, incomplete, irrelevant, or misleading.
A. Additional Rights for EEA/UK Users
For users in the European Economic Area (EEA) and the UK, the following additional rights under the GDPR apply: the Right to Erasure ('Right to be Forgotten'), which allows you to request the deletion of your personal data; the Right to Data Portability, which enables you to receive your data in a structured, machine-readable format; and the Right to Object, which allows you to object to our processing of your personal data. We will respond to all requests for access, correction, or erasure within a reasonable timeframe.
7. Complaints
If you believe we have breached the APPs, you may lodge a complaint by contacting us in writing using the details in Section 8. We will acknowledge your complaint in writing and endeavour to resolve it within 30 days. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC):
- Online: oaic.gov.au
- Phone: 1300 363 992
8. Contact Us
If you have any questions about this Privacy Policy, please contact our Privacy Officer:
- By Email: legal@vertbiotech.com
- By Post: 3/2 Harold Street, West End, QLD 4810, Australia
- Attention: The Privacy Officer