Polln Privacy Policy

Summary

This brief summary outlines the key points from Polln’s Privacy Policy. This policy describes how Polln handles your personal information. Our full Privacy Policy can be accessed below.

What is personal information?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.

What personal information do we collect?

We may collect the following personal information:

• your name, email, address and telephone number
• your age or date of birth
• your gender
• your medical and health information. 

If you are using Polln to seek a consultation with a doctor or other practitioner or are using the Polln client platform, we will ask for details about your medical history, medical conditions, symptoms, use of complementary medicines and medicinal cannabis and we will record other information about the treatment received through Polln’s platform. 

How do we collect personal information?

We aim to collect personal information directly from you. We will only collect sensitive information, including health information, with your consent. 

We may collect information from other sources including:

• agents and service providers;
• your guardian, family members or your doctor or health practitioner;
• third parties including (but not limited to) your health fund, hospitals or other community health services, and government agencies; and
• publicly available sources.

How do we use your personal information?

We will use your personal information for the following purposes:

• to provide you with our services;
• administrative purposes;
• business purposes;
• research; and
• product improvement.

If you have applied for a job with Polln, we will use your information to assess your suitability for the role.

When do we disclose your personal information?

We may disclose your personal information for the following purposes:

• to provide any of our services. This may include providing your information to related bodies or third parties;
• to provide information to your health practitioner(s) and dispensing pharmacy(ies);
• if another entity is buying our assets or the entity that controls us is changing. We may disclose your information to that entity. We will only do so if the entity agrees to maintain confidentiality and comply with our Privacy Policy; and
• to meet our legal, insurance and regulatory obligations.

We may also disclose your information to third parties in a form where you cannot be identified. For example, for research purposes. 

Direct communications

We may send you information that we consider may be of interest to you. This may include information about medical conditions, clinical trials, research, events, products and services.

You can opt-out of receiving communications from us at any time. You can do this by contacting us or using opt-out facilities provided in the communications. 

How can you request access to or correction of your personal information?

You have a right to request access to or correction of your personal information. If you wish to request access or correction of your personal information, please contact the Privacy Officer.

How do we hold and protect your personal information?

We take reasonable steps to protect your personal information. Your personal information will generally be held in electronic form. All data stored electronically by Polln is encrypted. Some information may be held in hard copy. 

Complaints

If you have a complaint or a concern regarding how we have dealt with your personal information, please contact the Privacy Officer in writing.

Website privacy

Our website may contain links to websites operated by third parties. We are not responsible for the privacy policies or the content of third-party websites. 

We may collect information when you interact with us online. We use various tools such as cookies to collect this information. 

Contact us

Please address all correspondence to:

Polln Pty Ltd

Attn: Privacy Officer

PO BOX 123

Montmorency VIC 3094

Email: hello@polln.com

For more information please see the full privacy policy below.

Introduction

At Polln Pty Ltd (Polln) we respect your right to privacy and are committed to protecting your personal information. We are required to handle your personal information in accordance with the Australian Privacy Principles (the APPs) contained within the Privacy Act 1988 (Cth) (the Act) and other applicable privacy and health records laws (for example, Health Records Act 2001 (Vic)). 

This Privacy Policy applies to personal information (as defined by the Act). It describes how Polln and its related bodies corporate (together, the Group) will collect, use, disclose and store your personal information. 

What is personal information?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and

whether the information or opinion is recorded in a material form or not.  Examples include your name, address, telephone number, email address and profession or occupation. 

Sensitive information is a subset of personal information and includes a person’s health information.

Unless otherwise specified, a reference to “personal information” in this policy means both personal information and sensitive information.

What personal information do we collect?

The purposes for collecting personal information include to arrange and conduct our business, understand our audiences and provide you with requested services.

General public

We may collect the following personal information:

• your name, email, address and telephone number
• your age or date of birth
• your gender.

If you are using Polln to seek a consultation with a doctor or other practitioner or are using the Polln client platform, we may also collect information about your medical history and medical conditions (if any). This may include: medications (past and current), allergies,  your use of complementary medicines and medicinal cannabis, any side effects or adverse events, immunisations, social history, family history, risk factors, and test results.

Healthcare professionals

We may collect the name, contact details and AHPRA number of health professionals.

How do we collect personal information?

We will try to collect your personal information directly from you, unless it is unreasonable or impracticable to do so. 

We will only collect sensitive information (including health information) with your consent.  

We collect personal information through:

• our contact us forms or internet portals (including Polln’s Platform)
• email or phone contact;
• your access and use of our websites and social media channels;
• review of your medical records; and
• clinical trials, patient or doctor surveys, questionnaires or other trials or testing activities.

We may collect personal information from other sources including:

• agents and service providers, including third party service providers;
• your guardian, family members or your doctor/healthcare provider;
• from third party bodies such as your health fund, hospitals or other community health services; and
• publicly available sources including directories, listings and the internet.

How do we use your personal information?

We will primarily use your information to provide you with our services and functions. 

We may use your personal information for the following other purposes.

Administrative and business purposes

• administrative and billing purposes;
• to update your contact details;
• to process and respond to your complaints and enquiries;
• to meet our legal and regulatory requirements and respond to requests for information from those bodies; 
• for direct marketing;
• to provide information, offers and advice to you about both existing and new products and services; and
• to conduct business processing functions.

Research and service improvement

• to help understand adverse events ,side effects, and treatment effects of therapies including medicinal cannabis and other complementary therapies;
• for data research and analysis ;
• for service improvement and development;
• to administer conferences, symposia, expert panels, seminars or other similar programs ; and
• to administer or advise you about clinical trials, surveys or other matters, with your consent.

These activities may be conducted by Polln or by a third party.

Assessing job applicants

• If you submit personal information when applying for a position with Polln, the information will only be used to consider and/or act upon your application. 
• We may retain your personal information for the purpose of considering your application for current or future available positions. 
• This information may be shared with third party service providers retained by us to collect, maintain and analyse job applications.

When do we disclose your personal information?

Where we disclose personal information to third parties, including contractors, we endeavour to require that these third parties respect your right to privacy and comply with the Act. We may disclose your personal information to:

• facilitate the provision of any services we provide to you using third parties, including contractors, health practitioners and dispensing pharmacies; 
• any Related Body Corporate or any entity which controls or holds a significant shareholding in a Group member to enable us to carry out our services and functions, as outlined in the How do we use your personal information? section;
• potential acquirers, in relation to an acquisition of Polln’s or a Group member’s assets. We will only do so where the potential acquirer agrees to comply with confidentiality restrictions and our Privacy Policy;
• facilitate a change in the entity that controls Polln, including any bona-fide due diligence process. We will only disclose personal information where the entity agrees to comply with confidentiality restrictions and our Privacy Policy;
• provide aggregated or de-identified information to third parties, for example, we may disclose information for research, evaluation and development purposes; 
• comply with our legal and regulatory obligations; and
• meet obligations of notification to our insurer.

Overseas disclosure

While we will take reasonable steps to ensure that overseas recipients of personal information do not breach the APPs; we also acknowledge that we cannot control those events.  Therefore, your acceptance of these terms indicates your express consent to the disclosure of your information for the purposes identified in this Privacy Policy to overseas recipients and your understanding that Polln is not responsible for ensuring the actions of those third party recipients comply with the APPs. We will not be liable to you for any breach of the Act or this Privacy Policy by these overseas third parties and on this basis you consent to such disclosure.

Direct communications

We may send you communications and information about medical conditions, clinical trials, research, events, products and services that we consider may be of interest to you. 

These communications may be sent in various forms, including mail, SMS and email.

If you indicate a preference for a method of communication, we will endeavour to use your preferred method.

You may opt-out of receiving communications from us at any time. You can do this by contacting us or using opt-out facilities provided in the communications. We will then ensure that your name is removed from our mailing list.

How can you access and correct your personal information?

We aim to ensure that all personal information collected is accurate, complete and up to date. To help us achieve this objective, please contact the Privacy Officer if any of your details change. 

You have a right to request the correction of your personal information held by Polln. If you believe that the information Polln holds is not accurate, complete or up-to-date, please contact the Privacy Officer on hello@polln.com in order to have the information corrected. You will not be charged a fee for the correction of your information.

You have a right to request access to any personal information we hold about you. You can request access at any time by contacting the Privacy Officer. Where we grant access, we will try to provide you with suitable means of accessing the information (for example, via mail or email). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge a fee making the request.

We may refuse your request for access where authorised or required by law. For example, we must refuse access where granting access would unreasonably interfere with the privacy of others. We will provide written reasons for any refusal of an access request.

How do we hold and protect your personal information?

We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. Your personal information is generally stored electronically on our software or systems or on those of our third-party service providers. Your information will be stored on servers in Australia. All electronically stored data is encrypted. Passwords are transmitted but never stored. Some personal information may also be stored in hard copy documents

Staff will deal with personal information in accordance with this policy and will take steps to keep it secure. Access to your personal information will be limited to staff who need to access it for carrying out our services and functions, as described under the How do we use your personal information? section. 

Complaints process

If you have a complaint or concern regarding how we have handled your information, please contact the Privacy Officer in writing (contact details are at the end of the policy). Please provide details of your complaint or concern.

Our representative will contact you within a reasonable time after receipt of your complaint. We will 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.

If you are not satisfied with how we have handled your complaint, you can contact the Office of the Australian Information Commissioner. See www.oaic.gov.au.  

Website privacy

External Links

Our website may contain links to other websites operated by third parties. We are not responsible for the privacy policies or the content of third-party websites. 

IP addresses, cookies and web beacons

We may collect information when you interact with us online. This could be via our websites or through emails or other forms of online communication. We may collect your information using web server logs, IP addresses, cookies and web beacons.

Web server logs/IP addresses

We may collect web server logs and IP addresses (the unique address of your device) to conduct system administration and report aggregate information to affiliates, business partners and/or vendors to conduct site analysis and website performance reviews.

Cookies

A cookie is a piece of information that is placed on your computer when you access certain websites. The cookie uniquely identifies your browser to the server. Cookies allow us to store information on the server to help make the web experience better for you and to conduct website analysis and web site performance review. Most web browsers are set up to accept cookies.  You can choose whether to allow cookies through your browser settings. Some parts of our websites may not work properly if you refuse cookies.

Web beacons

Some of our webpages or emails may use a web beacon (also known as an action tag or clear GIF technology). Web beacons help analyse the effectiveness of websites by measuring, for example, the number of visitors to a site or how many visitors clicked on key elements of a site.
We may also collect information from your browser or device when you visit our websites, including

• device ID and type; 
• your browser type and language; 
• access times;
• your mobile device’s geographic location; and
• referring website address (if any).

Changes to this Policy

This Privacy Policy may be amended 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 to remain up to date with such changes.

This Privacy Policy was last updated in November 2020.

Contact us

Please address all correspondence to:

Polln Pty Ltd

Attn: Privacy Officer

6 Luton Lane

Hawthorn VIC 3122

Email: hello@polln.com

‍