Privacy Policy

PRIVACY POLICY HONAHLEE AU PTY LTD

1. Introduction

Honahlee AU Pty Ltd (ABN 456 371 087 24) is an organisation that provides cannabis education to the Australian community. References to “honahlee”, “we”, “us”, and “our” in this Privacy Policy refer to Honahlee AU Pty Ltd.

In this Privacy Policy:

  • “You” means an individual or company who accesses the Catalyst website, including a verified account holder.
  • Digital products – means any information viewed or accessed on catalyst (catalyst.honahlee.com.au and subfolders).
  • Find a prescriber feature – is a digital tool found at https://honahlee.com.au/cannabis-doctors-australia/ and any subfolders of that URL.
  • Product suppliers – cannabis companies who hold a TGA or ODC license to manufacture or distribute medicinal cannabis products in Australia.

2. General

honahlee is bound by the Privacy Act 1988 (Cth) (Privacy Act) as amended, including the Australian Privacy Principles (APPs). The APPs are designed to protect the confidentiality of information and the privacy of individuals by regulating the way personal information is collected, used, disclosed and managed. Personal information is, generally speaking, information or an opinion relating to an identified or reasonably identifiable individual, whether the information is true or not and whether the information is recorded in a material form or not.

This policy explains the types of personal information that we may collect and hold, how that information is used and with whom the information is shared. It also sets out how you can contact us if you have any queries or concerns about our collection, use or disclosure of personal information, or if you believe we have not complied with this Privacy Policy or the Privacy Act.

3. Your Consent

By using this website, honahlee.com.au or catalyst.honahlee.com.au, and/or the site that references this Privacy Policy, or otherwise providing us directly, or through others, with your personal information, you agree with the terms of this Privacy Policy and consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy, the Privacy Act and other applicable privacy laws.

4. Why we collect personal information

We collect personal information for various purposes connected with our activities and operations, including to develop, provide and improve our digital products and services, for verification of our visitors and customers, to understand and meet the needs and requests of individuals we engage with and to meet our legal obligations.

5. The information we collect

The type of personal information we collect may include

  • Contact information such as:
    • name, email address, postal address, company information;
  • User preferences and profile information:
    • login details, marketing preferences, comments, feedback and user data (see Analytics and Cookies )

6. How we collect information

We collect personal information in a number of ways, including:

  • Directly from you when you provide it to us via the website or email or when you:
    • Create an account with us
    • Purchase a product
    • Participate in a survey
    • Apply for employment, 
    • Provide a service to us
    • Use our website or otherwise engage with honahlee
  • By gathering publicly available information available from:
    • Other websites on the internet
    • Social media channels (including company pages or posts from users of private social media groups that honahlee team members are members of)

Personal information may be collected by way of emails, phone conversations (which may be recorded for quality control purposes in accordance with applicable laws), forms filled out by individuals (including via online forms), feedback, enquires, support requests, surveys, competitions, online user-generated content, market research, video conferencing, face-to-face meetings, social media posts and comments and interviews.

We may supplement the information we receive from you with information from third-party sources such as our partners, social media channels and other websites. You may, in some circumstances, have the option of not identifying yourself or using a pseudonym when you deal with us. However, if you choose not to provide the information we need to fulfil your request for a specific product or service, we may not be able to provide you with the requested product or service, or we may not be able to allow you to participate in activities or to purchase our products and services.

Currently, we do not collect any sensitive information.

7. Billing information

honahlee does not collect billing information such as payment card details. Instead, third-party Payment Gateway providers are used for online payment card or banking transactions made via the honahlee website and for payment of invoices online or by phone.

When purchasing a product or service from the honahlee website or when paying a honahlee issued invoice online or by phone:

  • Customers will be directed to a payment gateway provider (Stripe).
  • Payment card details are submitted to the payment gateway provider and cannot be viewed by honahlee.

honahlee will receive certain information about Customers from the payment gateway provider (including payment card details in a hashed format and the Customer’s name and IP address) to enable honahlee to provide products and services ordered by Customers.

8. Analytics and cookies

honahlee also collects data and statistical information about visitors to our website and digital products using web analytics and session recording technology provided by third-party service providers such as Google Analytics, Google Search Console, and Heap Analytics. These services use Cookies to assist us in understanding how visitors access and utilise our website and digital products. Occasionally, we use this information to identify particular individuals. In some circumstances, the statistical information may include a visitor’s internet protocol (IP) address, which could be linked to an individual. In some cases, your internet protocol (IP) addresses may be collected directly by a third-party service provider.

honahlee uses Heap Identify to consolidate information on each unique visitor to their interactions with our site and digital products. This consolidated information provides a more accurate picture of visitor journeys and use of our digital products and website. Heap Identify assigns a unique identifier to each visitor and uses this identifier to link all activity associated with that particular visitor. We also link an email address to that unique identifier so we can better understand certain high-value customers. 

To improve your experience on our site, we use ‘cookies’. Cookies are an industry standard, and most major websites use them. A cookie is a small text file that our site may place on your computer as a tool to remember your preferences. You may refuse the use of cookies by selecting the appropriate settings on your browser. Cookies do not store any sensitive or personal information. We may share the information captured from cookies with others.  

You can find out more information on how Google uses data when you use honahlee’s site or digital products at www.google.com/policies/privacy/partners/.

You can find out more information on how Heap Analytics uses data when you use honahlee’s site or digital products at https://heap.io/privacy

9. How honahlee might use and disclose your personal information

honahlee may use and disclose your personal information for the purposes described in this Privacy Policy, or for related purposes which would reasonably be expected by you, or for purposes to which you have consented, and in other circumstances authorised by the Privacy Act or otherwise required or authorised by law.

Generally, honahlee may use and disclose your personal information for a range of purposes. For individuals who have signed up for our newsletter only, we will not disclose any of your personal information.  

For individuals who have created an account on our digital products or are paying customers of our digital products (and who are not a part of our Find a prescriber), we will only share your personal information with a third party when you have explicitly consented to the sharing of that information. We may disclose your personal information to other members of the honahlee team in order to:

  • respond to your queries or feedback or provide customer service support;
  • analyse and improve all aspects of our business;
  • authenticate users to enable access to honahlee digital products;
  • facilitate your participation in forums, social events and educational events
  • facilitate participation in our governance forums and activities; and
  • consider employment or other engagement applications.

Your personal information may also be used so we can:

  • provide you with any communications in which we think you might be interested; and
  • let you know about developments in the global cannabis market, developments in our procedures, products, services, activities and programs that might be useful to you,
  • by way of direct mail or telemarketing and (where you have opted in) by email, SMS or MMS (recipients who no longer wish to receive such communications can request to be removed from the distribution list by following the unsubscribe instructions in the relevant email, SMS or MMS).

10. Disclosure of personal information to other parties

honahlee may disclose your personal information to third parties.

For healthcare professionals who are a part of the Find a prescriber feature, we may disclose your personal information to the website or digital product visitors in order to:

  • Help patients find a prescriber who can help with their medical condition.
  • Help other healthcare professionals find like-minded practitioners.

For individuals who have signed up for the honahlee newsletter only, we will not provide your information to any third party other than the third party tool (https://www.campaignmonitor.com/) used to manage and maintain our email database. You can view the Campaign Monitor privacy policy here: ​​https://www.campaignmonitor.com/policies/#privacy-policy

For customers of our digital products, we will only provide your personal information to third parties with your consent. 

We do not sell or license your personal information to third parties.

We also note that we may have access and correction obligations pursuant to the Consumer Data Right provisions of the Competition and Consumer Act 2010.

11. Sending information overseas

All personal information held by honahlee is held in Australia. There may be times when personal information is sent overseas, including instances when a customer of our digital product requests to speak with a product supplier. honahlee complies with the APPs when sending personal information overseas. honahlee will not send your personal information to a recipient outside Australia without obtaining your consent or otherwise complying with the APPs.

Product suppliers may be located around the world.

12. Security and management of personal information

honahlee takes reasonable steps to protect the personal information we hold from misuse and loss and from unauthorised access, modification or disclosure. The ways we do this include:

  • Limited access to the information we collect about you (for example, for anyone not listed in the Find a prescriber, we limit access to your information to you and members of the honahlee team who need your information to carry out our business activities).
  • limiting access to the information we collect about you (using a payment gateway for secure handling of your billing information);
  • requiring any third-party providers to have acceptable security measures to keep personal information secure; and
  • putting in place electronic and procedural safeguards.
  • If we no longer require your personal information and are not legally required to retain it, honahlee will take reasonable steps to destroy or permanently de-identify the personal information.
    • For example, for past customers of our digital products who have cancelled their subscription, we will delete all personal information for those who have not used the digital products within 6 months. Prior to deleting personal information, we’ll attempt to reach out to the past customer 2x (over 30 days via email) to let them know their account will be deleted unless they tell us otherwise. 

13. Data breaches

We will take all reasonable steps to ensure that your personal information is not hacked, unlawfully or improperly accessed, interfered with or attacked by third parties. In the unlikely event that this occurs, we will notify you of the unauthorised breach and the steps we are taking in response to the breach.

The steps we will take are as recommended by the OAIC are as follows:

  1. Report to OAIC first
  2. Report to individuals affected (and we will also report to all users of the tools)

When notifying the OAIC and users of honahlee.com.au, we will include:

  • your organisation or agency’s name and contact details
  • a description of the data breach
  • the kinds of information involved
  • recommendations about the steps individuals should take in response to the data breach

14. Links from our website to other websites

Our site may, from time to time, have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement, or approval of these websites. Please be aware that honahlee is not responsible for the privacy practises of other such websites.

We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personally identifiable information.

15. Requests to stop facilitating direct marketing

If you request that we stop facilitating direct marketing, we will comply with that request.

16. Find a prescriber

You may decide to book an appointment with a doctor using our Find a prescriber feature (https://honahlee.com.au/cannabis-doctors-australia/). The Find a prescriber has two types of listings – standard healthcare provider listings (free) and a premium healthcare provider listings. These listings help you connect and book a healthcare provider of your choosing in one of two ways:

  • Standard healthcare provider listing. This method one is where honahlee only provides a URL for the healthcare provider’s website and a phone number for you to contact the healthcare provider at your leisure.
  • Premium healthcare provider listing. This method allows you to select a prescribing healthcare provider using an embedded tool located on the honahlee website or will give you instructions as to how to book a prescriber through honahlee. Please be advised that honahlee may receive a monthly subscription fee from the healthcare professionals or their clinics who have a premium healthcare provider listing. These practitioners will also get enhanced visibility in location-based searches. However, honahlee will not use the search tool to promote physicians who have paid a subscription fee. Patient requirements will always be the priority in any search.
  • Any physician who has a premium healthcare provider listing will offer patients a 10% discount on the price of an initial consultation.
  • However, in cases where the tool contains a third party embed and is used for booking purposes, that part of the tool is not owned or operated by honahlee. The embedded tools are provided by the healthcare provider and are owned and operated by the host of the booking tool and may be from one of the following providers:
    • acuityscheduling.com/
    • calendly.com/
    • healthengine.com.au/
    • hotdoc.com.au/
    • medirecords.com/
    • Custom tool built by the healthcare providers technical team
  • Any data which you choose to enter and which is collected by the use of this tool is not under the control of honahlee. honahlee has no affiliation with the host of the tools and does not capture or have access to the data you submit through the tool. honahlee disclaims any responsibility or liability for the use made of any data submitted to any of the providers of booking tools listed above, whether by the provider or any other entity or individual to whom the provider transmits the data.

17. Accessing the information we hold about you

Under the APPs, you may be able to obtain a copy of the personal information that we hold about you. The APPs provide some exceptions to your rights in this regard.

For individuals who are customers of one of our digital products, you will have access to all of your personal information in the My Account section of our digital products. For Catalyst customers, please email [email protected] subject: Catalyst Personal Information Request, with your request. Please email us from the email address used to create the account and provide your full name, postcode and medical registration number. 

For anyone else, make a request to access this information by contacting us in writing at [email protected] subject: Accessing my personal information. We will require you to verify your identity and specify what information you require. 

18. Updating your personal information

We endeavour to ensure that the personal information we hold about you is accurate, complete and up-to-date. 

For individuals who are customers of one of our digital products, you will have access to all of your personal information and the ability to update it in the My Account section of our digital products. For Catalyst customers, please email [email protected] Subject: Update Catalyst Personal Information Request, with your request. Please email us from the email address used to create the account and provide your full name, postcode and medical registration number. 

For everyone else, please contact honahlee at [email protected] subject: Updating My Personal Information, if you believe that the information we hold about you requires correction or is out-of-date.

19. Updates to this Policy

Our Privacy policy is available by email, online or by post on request for a fee of $10.

This Privacy Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. The current version of this Privacy Policy is available at: https://honahlee.com.au/privacy-policy/

20. Complaints

If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may bring a complaint internally through our complaints process or you may decide to make a formal complaint with the Office of the Australian Information Commissioner (www.oaic.gov.au) (which is the regulator responsible for privacy in Australia).

We will deal with complaints as follows:

Step 1: Let us know

A complaint must be made in writing to honahlee as required by s 40(1A)
(to [email protected] Subject: Breach of Privacy Policy Initiation)

Step 2: Investigation of complaint

Your complaint will be investigated by our Privacy Officer. A response to your complaint will be provided in writing within a reasonable period (30 days)

If the complainant and honahlee can find a resolution or are in the process of finding one, the complaint should go no further.

If the complainant and honahlee agree there is no immediate resolution, the complaint may then be taken to the OAIC.

Step 3: Contact OAIC

We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also contact the Office of the Australian Information Commissioner as follows:

Office of the Australian Information Commissioner (OAIC)

Complaints must be made in writing.
Phone: 1300 363 992
Director of Compliance
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
www.oaic.gov.au

21. Contact us

Any complaints or correspondence in relation to this Privacy Policy should be sent to our Privacy Officer at:
Honahlee AU Pty Ltd
Email: [email protected]
We will endeavour to respond to all complaints and correspondence promptly.