Privacy Policy
Effective as at: June 6, 2020
CANOPY GROWTH CORPORATION AND ITS SUBSIDIARIES ARE COMMITTED TO MAINTAINING THE ACCURACY, CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION GIVEN ITS HIGH LEVEL OF SENSITIVITY.
Canopy Growth Australia Pty Ltd (Canopy) a company registered in Victoria, Australia, is bound by the Australian Privacy Act 1988 (Cth) and, to the extent that Canopy’s conduct takes place in New Zealand, the New Zealand Privacy Act 1993 (together Applicable Privacy Law), and will only collect, use and disclose personal information in accordance with the Applicable Privacy Law and this policy.
This privacy policy outlines how we manage your privacy and any personal information we collect.
WHAT IS PERSONAL INFORMATION?
Under the Australian Privacy Act, personal information is information from which that person can be identified. Under the New Zealand Privacy Act, personal information is information about an identifiable individual.
WHAT PERSONAL INFORMATION CANOPY MAY COLLECT ABOUT YOU?
Canopy only collects personal information about you for the purpose of providing a service or where the collection of that information necessary to one of our business functions or activities. Examples of personal information we may collect include:
- Your name, contact details and date of birth
- Your business details
- Your medical specialty and areas of interest
- Your medical professional registration number
- Information about your patients and their experience with Canopy products
If you do not provide this information you may not be able to access our information portal or otherwise receive information in relation our products and services.
You may unsubscribe from our mailing lists at any time by contacting us in writing or using the unsubscribe link in our emails to you.
Children under the age of 18: We do not knowingly collect personal information from children who are 18 or younger. The parent or guardian can contact us on medinfo.au@canopygrowth.com if a child has provided us with personal information.
WHY DOES CANOPY COLLECT YOUR PERSONAL INFORMATION?
Canopy collects personal information to enable us to manage, maintain, and develop our operations, including for example:
- to register you as an authorised healthcare professional to gain access to our information portal
- to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested
- to administer our business and this website
- to enable you to participate in any Canopy activities such as clinical trials, patient support programs, and educational programs
- to provide educational materials and product information relevant to Canopy products to authorised healthcare professionals only
- to conduct market research
- to maintain a record of enquiries, complaints and adverse events as per company policies, Therapeutic Goods Act 1989 (Cth) and applicable regulations (Australia) and the Medicines Act 1981 (New Zealand)
- to receive applications for employment
- to protect Canopy against error, fraud, theft and damage to our goods and property
- to enable Canopy to comply with applicable law or regulatory process (e.g. product recall) or reporting requirements
- to fulfil any of your reasonable requests
- any other reasonable purpose to which you consent or which we are required to undertake in order to fulfil our legal obligations to you or third parties
HOW IS PERSONAL INFORMATION COLLECTED?
We collect your personal information in many ways including:
- when you create an account on this website
- from contact forms you complete on this website
- corresponding with us by post, telephone, email or otherwise, including emails to medinfo.au@canopygrowth.com
- in person such as at educational events
- interviews
- via our website www.spectrumtherapeutics.com
- from your website
- from media and publications
- from other publicly available sources
- from cookies as described under the heading Cookies
- from third parties such as data list providers
THIRD PARTY LINKS
Canopy’s website may contain links to other websites that may contain different privacy policies and terms of use. To the maximum extent permitted by law, we cannot and do not assume any responsibility for the privacy practices, policies or actions of the third parties that operate those websites and we do not endorse, sponsor or approve of the content on, those third party websites. Canopy is not responsible for how third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with your personal information.
COOKIES
We may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page within our website that is viewed by that IP address and what country you are from. We use this information to monitor our website's performance (such as number of visits, average time spent, page views) and for business purposes such as working to continually upgrade our website.
We may place a "cookie" on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the website so that we can better understand your use of our website and so we can customize and tailor the website to better meet your needs.
If you wish to disable cookies, go to your web browser’s settings to either: (i) have your browser notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (ii) automatically prevent the placing of a cookie on your hard drive. Please note that should you refuse the cookies, you might not be able to access a number of web pages found on the website.
SENSITIVE INFORMATION
Sensitive information is defined in the Australian Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information. The New Zealand Privacy Act does not have a similarly defined concept of sensitive information. Canopy does not solicit any sensitive information. If you or your healthcare professional discloses any sensitive information to us it will be processed in accordance with this privacy policy and the Applicable Privacy Law. If you submit sensitive information to us, you warrant and represent to us that you consent, have obtained all necessary consents or are otherwise permitted to disclose the sensitive information under the Applicable Privacy Law. Where sensitive information relates to an adverse reaction to our products we may be required by applicable law to disclose your sensitive or personal information to the Therapeutic Goods Administration (Australia) or Medsafe (New Zealand).
CANOPY DISCLOSURE OF PERSONAL INFORMATION
It is generally our policy not to share your personal information with external organisations. However, we may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with our compliance with applicable laws or managing our relationship with you, including third parties that provide services to us or on our behalf. Examples of the types of organisations that we may need to disclose your personal information to are:
- Canopy Growth Corporation, our corporate organisation or other affiliates worldwide
- regulatory and legal agencies
- Canopy distributors
- other organisations as required by law
- our professional advisors
- any other service provider in Australia, New Zealand or overseas who is contracted to provide a service on our behalf
- third parties for any other purpose for which you have provided your consent
DISCLOSURE OF PERSONAL INFORMATION OVERSEAS
Canopy may disclose your personal information to Canopy Growth Corporation, other affiliates worldwide and other overseas organisations when necessary for our business operations. Other than Australia and New Zealand, the country where your personal information will most likely be disclosed to is Canada.
SECURITY OF PERSONAL INFORMATION
We aim to store your personal information in a manner that protects it from misuse and loss and from unauthorized access, modification or disclosure. Canopy has adopted physical measures aimed to protect your personal information, such as secure premises, technical measures, such as technological safeguards and administrative measures such as policies and procedures designed to reflect the sensitivity of the personal information in question.
When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. If required under applicable law the personal information may be kept by us or on our behalf for a minimum of 7 years.
ACCESS TO YOUR PERSONAL INFORMATION
Under Applicable Privacy Law, you may access the personal information we hold about you and update and/or correct it, subject to certain exceptions. If you wish to access your personal information, please contact our Privacy Officer in writing as set out under the heading Privacy Policy Complaints and Enquires below.
Canopy will not charge any fee for your access request except, for complex requests, where we may charge an administrative fee for providing a copy of your personal information.
In order to protect your personal information, we may require identification from you before releasing the requested information.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why in writing, subject to any legal or regulatory restrictions. In some circumstances, we may not agree with your request to change your personal information and will instead append an alternative text to the record in question or a statement of the correction sought but not made. We will also inform you about mechanisms to make complaints about the refusal.
MAINTAINING THE QUALITY OF YOUR PERSONAL INFORMATION
It is important to us that your personal information is up to date. We will take reasonable steps to make sure that your personal information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
Policy Updates
This Policy may change from time to time and is available on our website.
Privacy Policy Complaints and Enquiries
If you have any queries or complaints about our privacy policy, please contact our Privacy Officer at:
PO Box 598,
MOUNT WAVERLEY VIC 3149,
AUSTRALIA
medinfo.au@canopygrowth.com
If calling from Australia: 1800 223 842
If calling from overseas: +61 1800 223 842