Privacy Policy

1. Trajan Scientific Australia Pty Ltd ACN 161 314 969 (us, we and our) provides the ‘MonitorYou’ remote collection and sampling kits (Products), analytical biomarker assessment and monitoring services (Services) and related services.
2. We are committed to protecting your privacy and personal information in accordance with our obligations under the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act) and any other applicable health records legislation.
3. This Privacy Policy (Policy) sets out the type of personal information we collect, how we handle and protect it, and how you can contact us if you need further information or would like to make a request. This Policy applies specifically to our handling of personal information in connection with the supply of the Products and Services described above. We also comply with our general Privacy Policy available at: https://www.trajanscimed.com/pages/privacy-and-security.
4. All references to ‘you’ and ‘your’ in this Policy are references to:
   1. individuals who purchase or use any of our Products or Services (Consumers);
   2. representatives of our business customers or their third party customers who re-supply or re-sell our Products and Services to Consumers (Business Customers); and
   3. our contractors and suppliers, potential employees, and any other individuals we might deal with in the course of operating our business, including individuals who use our website at monitoryou.com (Website).

1. To operate our business, we need to collect ‘Personal Information’, which is information or an opinion about an individual that is reasonably capable of identifying that individual (and that might also include their health or other sensitive information).
2. We may collect and hold your Personal Information for reasons, including to:
   1. allow us to identify you to provide you with our Products or Services, including through our Website;
   2. communicate or transact with you in the ordinary course of business, including to send you statements and invoices and collect payments from you,
   3. improve our businesses or improve the customer experience; and
   4. comply with our legal obligations

1. If you are a Consumer:
   1. Personal Information we collect about you may be received from you directly (for example, when you order our Products and Services, send us your samples, communicate with us over the Website or the telephone or send us correspondence, or subscribe electronically to our publications), or from a person that has the authority to act on your behalf, such as your legal guardian.
   2. We may also collect your Personal Information from a third party where it is unreasonable or impractical to collect the information directly from you, such as from a person or organisation procuring our Products or Services on your behalf (for example, one of our Business Customers), an organisation with whom you have dealt with or that maintains a public record, or a credit reporting agency.
   3. The types of Personal Information we may collect include, depending on the circumstances:
      1. general information such as your name, date of birth, gender, contact information (including your email address, contact and delivery addresses and phone numbers), your registration or customer account details on the Website, your preferences as to the recipients (including third-party recipients, if any) of your Services results, communications or related information;
      2. Website information such as details of your transactions carried out over the Website and of your use of, or access to, the Website, and your preferences and feedback for the purpose of subscribing to Website services and marketing material;
      3. health information such as your samples and any information in the accompanying Service Request Form or other forms, information in and about your Services results and reports, or other information that falls within the scope of ‘health information’ as that term is defined in the Privacy Act; and
      4. other Personal Information provided to us by you or your representative, including information you provide when using the Website or our Products or Services and records of any communications between us and you.
   4. We will not collect financial information such as your credit card, bank account or other payment details used to transact with us, but this information may be held by our third party payment facility provider where you make payments via our Website.
   5. We will only collect health information about you if we have your consent to do so, or if the collection is otherwise permitted or required by applicable privacy laws.
2. If you are a representative of a Business Customer, a contractor or supplier, potential employee or another individual we deal with in operating our business:
   1. Personal Information we collect about you will typically be received from you directly, however in some circumstances it may also be collected from third parties such as our business partners (including other contractors, employees, service providers or suppliers), if relevant.
   2. The types of Personal Information we might collect about you may include, depending on the circumstances:
      1. general information such as your name and contact details, your role, professional qualifications or skills; and
      2. other Personal Information provided to us by you, including records of any communications between us and you.

In addition to the above, if you use or access our Website, we may collect statistical information using cookies or analytical services (although you can adjust your browser’s setting to accept or reject cookies). Cookies enable us to tell when you use the Website, to identify which pages are being used, to help customise your website experience and for statistical analysis purposes, which helps us improve our Website and improve your user experience.

1. The primary purposes for which we collect your Personal Information are to provide you with our Products and Services (including as part of programs offered by our Business Customers where relevant), enable your use of the Website (including to receive our Services) and to support the operation of our business.
2. If you are a Consumer:
   1. we will use your Personal Information (including your health information) for the primary purposes for which it was collected (for example, to communicate and transact with you to provide you with Products and associated Services, to set up your personal account on the Website and provide Service-related results to you);
   2. we will only use this Personal Information for secondary purposes if you have provided your consent for us to do so, or if the particular secondary use is otherwise required or authorised by law;
   3. we may use your Personal Information to produce deidentified and aggregated datasets or statistical information for research or statistical assessments, however this will occur on a strictly anonymised basis only;
   4. we maintain all Personal Information (especially health information) in strict confidence, and will only disclose it to third parties where:
      1. you have consented to us doing so;
      2. it is reasonably necessary to enable us to provide you with our Products and Services and use of our Website, and to enable us (and our Business Customers where relevant) to keep up-to-date records and communicate with you; or
      3. we are otherwise authorised or required to do so under relevant laws;
   5. the types of third parties that we may disclose your Personal Information to include:
      1. our service providers who enable us to provide our Products and Services and run our business, or to undertake functions or activities on our behalf, such as:
         1. any external analytical laboratory that we use to process samples taken using the Products and to undertake associated Services;
         2. our information technology, network, software and cloud-storage providers;
         3. our payment facility providers;
         4. research and database providers; or
         5. our external professional advisers, business partners, joint venturers, partners or agents;
      2. a Business Customer who is purchasing our Products or Services for supply to you; and
      3. your Authorised Recipients (as defined in section 5.5); and
   6. if we share or disclose your Personal Information as described in section 5.2(e), we will first consider whether we can reasonably de-identify or anonymise that information.;
   7. without limiting clause 5.2(e) above, if you are receiving our Products or Services as part of a program offered by a Business Customer, you consent to the disclosure of your Personal Information (such as your name) to our Business Customer, provided however that we will not disclose any Service-related results to the Business Customer unless you have specifically consented to that disclosure.
3. If you are a representative of a Business Customer, contractor or supplier, or another individual we deal with in operating our business:
   1. we will only use or disclose any Personal Information that we collect for the purpose for which it was collected, or for any secondary purposes that are authorised or required by relevant laws (such as where you might reasonably expect us to do so); and
   2. the primary purpose of our collection can generally be determined by the circumstances in which the information was collected.
4. Direct marketing involves the use and/or disclosure of Personal Information to communicate directly with an individual to promote goods and services. If we use or disclose your Personal Information (other than health information) for the purpose of direct marketing, we will always allow you to ‘opt out’ and request not to receive direct marketing communications, including by contacting us using the details provided in section 10 or, where applicable, unsubscribing from the relevant mailing list. If we use or disclose your health information for the purpose of direct marketing, we will only do so with your consent.
5. If you provide us with the Personal Information of a third party for the purpose of that party receiving our Products, Services, results, communications or related information from us on your behalf (Authorised Recipient), we will collect, use or disclose such third-party Personal Information in accordance with your instructions, this Policy and our applicable Terms and Conditions.

1. We will take all reasonable steps to protect your Personal Information from unauthorised access or disclosure, or misuse or loss and to ensure the information is secure. This includes appropriately securing our physical facilities and electronic networks, such as using standard industry encryption methods of all data that is stored by us or transferred to our service providers and imposing limitations and controls that manage who can access information, including within our organisation.
2. Your information is stored in Australia in a secure and encrypted electronic format. We will not disclose your Personal Information to any entity or person outside of Australia, unless that entity or person is in a jurisdiction with a similar privacy regime to Australia, or is subject to contractual controls that safeguard Personal Information to the same extent as the Australian Privacy Principles or we otherwise have your express consent.
3. We will only retain your Personal Information for as long as necessary to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law and will otherwise de-identify or destroy such information.

1. If you would like to make a request to access or correct your Personal Information that is held by us, you can:
   1. if you have a personal account on the Website, access or update some of your Personal Information via that account; or
   2. otherwise make a request by contacting us using the details provided in section 10.
2. We may charge you a reasonable fee for our costs incurred in fulfilling any of your requests to correct or access the Personal Information we hold about you.
3. We will aim to comply with all reasonable requests, however if we deny you access or refuse your request to correct your Personal Information then we will provide you with our reasons for this.

1. If you have a query or complaint about our handling of your Personal Information, please contact us in writing using the details provided in section 10. We will aim to resolve the issue with you directly.
2. If you are not satisfied with our response to your complaint, you can also lodge a complaint with the Office of the Australian Information Commissioner by phone on 1300 363 992 or online at www.oaic.gov.au.

1. From time to time, we may need to change this Policy. If we do so, we will post the updated Policy on the Website
2. We encourage you to refer back to this Policy from time to time to review any changes, as any revised Policy will apply to all Personal Information (including health and other sensitive information) that is collected, used or disclosed by us after the Policy is published.

1. If you have any questions about this Policy, would like to request access or a correction to your Personal Information or would like to lodge a complaint, please contact our customer service team on:
   

   Trajan Scientific Australia Pty Ltd

   7 Argent Pl

   Ringwood VIC 3134

   (02) 6145 2147

   info@monitoryou.com

   
   

   If your query relates to the handling of your Personal Information, it will be referred to our Privacy Officer on request or where otherwise appropriate.