SAGED/Alternaleaf, a subsidiary of Montu Group Pty Ltd (“SAGED”) is not promoting the use of regulated or unregulated therapeutic goods. Plant alternatives in Australia are regulated by the Therapeutic Goods Administration and details about plant medicine as a scheduled drug can be found on their website.  

The content presented on this website is intended solely to provide educational materials solely for qualified medical practitioners in Australia. It's important to note that this website and the information it contains are subject to ongoing updates and modifications. While we make every effort to ensure the accuracy and timeliness of the content, we cannot guarantee its absolute currency or accuracy, as occasional delays, errors, and omissions may occur.

To the fullest extent permitted by applicable law, SAGED disclaims any responsibility for any loss or damage incurred by you or anyone else in connection with the use of this website or its content. This disclaimer encompasses various factors, including but not limited to the potential transmission of computer viruses and any resulting consequential losses. We strongly recommend conducting a virus check before downloading any files, photos, or articles from this site.

For your convenience, SAGED provides links to other websites; however, we cannot vouch for the accuracy or currency of the information found on those external sites.

Please be aware that SAGED authorises the printing of website content exclusively for personal use. Any other forms of use, copying, or commercial reproduction of this website or its components are prohibited, except where permitted by law.

Please carefully review these terms and conditions before using our website.

SAGED.com.au is an online platform operated by Alternaleaf Pty Ltd, a wholly owned subsidiary of Montu Group Pty Ltd, located at Level 18/1 Nicholson St, East Melbourne VIC 3002 ("we," "us," or "our").

Definitions

"Conflict" refers to any inconsistency or contradiction between these specific terms for Membership in the online courses and the Standard Terms and Conditions.

"Content" refers to the educational content provided on the SAGED platform, including but not limited to course materials, text, images, videos, presentations, and any other materials.

“Key Contact” means the authorised representative of an Organisation who places an Order and acts on behalf of all Members linked to that Organisation.

“Order” means a hard copy or online (including via our Website) order particularising the Services and the Fees which is accepted by you.

"Organisation" refers to the entity (clinic, pharmacy, or similar) that purchases Team Memberships on behalf of its employees or affiliates.

"SAGED platform" or “SAGED” refers to the online platform provided by us through which members access the online courses and related services.

“Services” refers to the features and functionalities available through our website, including registration, purchases, and participation in medical cannabis education activities designed for healthcare professionals.

"Standard Terms and Conditions" refer to the general terms and conditions that apply to the use of our website and other services provided by SAGED, available here [link], which are separate from and in addition to the terms specific to Membership in our online courses.

"Member" refers to an individual who has signed up for a Membership to access the online courses offered by us through the SAGED platform.

"Membership" refers to the status granted to users who have completed the registration process and agreed to these terms and conditions to access our course materials.

"Team Access Code" refers to a unique code provided to an Organisation to allow individual users to self-register for a Membership under a Team Membership.

"Team Membership" has the meaning given to it in Schedule 1.

“Terms and Conditions” means these terms and conditions, as amended by us from time to time.

“User” refers to any individual who accesses, browses, registers for, or participates in the services provided on our website.

“User Contributions” refers to any content, including but not limited to comments, feedback, questions, reviews, or other materials, that users submit, post, or share on our website or related platforms.

"Website" refers to the online platform owned and operated by us accessible at https://saged.com.au, through which users can access the SAGED platform, together with information about the Content and other services provided.

1. Membership

1.1 To access our Content, you must become a Member by either (a) completing the registration process as an individual, or (b) registering using a valid Team Access Code provided to you by an Organisation that has purchased a Team Membership. In both cases, you must provide accurate information and agree to these terms and conditions.

1.2 Membership is personal to you and is non-transferable. You are responsible for maintaining the confidentiality of your account and password. If we discover that you have shared or transferred details of your account and/or password we may immediately terminate your Membership.

1.3 Account Security: If you receive a user identification code, password, or any other confidential information as part of our security procedures, maintain its confidentiality and do not share it with third parties. We reserve the right to disable any user identification code or password, at our discretion, if you fail to comply with these terms or if we suspect any misuse. If you suspect unauthorised access to your account, promptly notify us at hello@saged.com.au.

1.4 Team Membership Access: If your access to the SAGED platform is through a Team Membership, you must still register individually and agree to these Terms and Conditions. Your Membership remains personal to you, and subject to all provisions herein.

2. Team Memberships

If you are purchasing a Team Membership on behalf of an Organisation, then Schedule 1 to these Terms and Conditions apply to your purchase and our provision of services.

3. Eligibility

3.1 Our website is intended for users who are at least 18 years old and are located in and using the site within Australia. We do not represent that our Content is applicable to or available in other locations. If you access our website from outside Australia, you do so at your own risk and are responsible for complying with local laws.

3.2 To become a member and access our Services, you must hold a valid and active Australian Health Practitioner Regulation Agency (AHPRA) license. If you are registering via a Team Membership, you are still required to meet this eligibility requirement individually.

3.3 You undertake to provide and maintain your AHPRA license for the duration of your Membership with SAGED. If you cease holding a valid and active AHPRA license number, your Membership is deemed automatically cancelled, and you must notify us of this change and cease using SAGED.

4. Content

4.1 SAGED provides educational Content related to medical cannabis. The information provided is for educational purposes only and should not be construed as medical advice.

4.2 We strive to provide accurate and up-to-date information; however, we do not guarantee the accuracy, completeness, or usefulness of any Content. You acknowledge that information may become outdated or inaccurate over time.

4.3 External Links: Our website may contain links to third-party sites and resources, including banner advertisements and sponsored links. These links are provided for information only, and we do not endorse the linked websites or their content. We have no control over these sites and resources, and accessing them is at your own risk, subject to their terms and conditions.

4.4 Our website may include content uploaded by other users, including comments and User Contributions. Such content is not verified or approved by us, and the views expressed by users do not represent our views. We may remove any user-generated content at our discretion.

4.5 User Contributions and interactions through social media features must comply with applicable laws and regulations. User Contributions must not contain offensive, infringing, illegal, deceptive, or harmful material. We reserve the right to remove any content that violates these standards.

5. Learning Credits

5.1 Users must sign up for a SAGED membership plan to purchase learning credits. Membership plans are available in three tiers: Free, Standard and Premium.

5.2 Credit Allocation on a Standard Membership: Users on the Standard plan will receive 1 learning credit per month.

5.3 Credit Allocation on a Premium Membership: Users on the Premium plan will receive unlimited learning credits per month.

5.4 Purchasing and Using Learning Credits: Users can purchase additional learning credits as add-ons. Learning credits function as a currency to purchase, redeem, or enrol in Content on the SAGED platform.

5.5 Expiry of Add-on Learning Credits: These credits expire 12 months from the date of purchase if not used prior.

5.6 Expiry of Monthly Learning Credits: Credits included as part of a limited-credit membership plan expire within 90 days of issue if not used prior.

5.7 Refunds and Exchanges of Learning Credits: All transactions involving learning credits are non-refundable, except as required under Australian Consumer Law (ACL). If you believe you are entitled to a refund or exchange under ACL, please contact our support team at hello@saged.com.au.

6. Selected Membership Duration

6.1 All paid Membership plans are subject to an initial 12-month minimum term commitment, after which cancellation or downgrade of your Membership may occur.

6.2 When signing up for a Membership, you may have the option to select a duration for your Membership, such as monthly or annually. This selection determines how you are billed but does not alter the 12-month initial term commitment.

6.3 If you select a specific payment schedule for your Membership, your Membership will automatically renew at the end of each period unless you cancel it in accordance with Section 7 of these terms and conditions.

6.4 The selected payment schedule may affect the Membership fees applicable to your Membership. Please refer to our pricing and Membership options on our website for more information on the fees associated with different payment schedules.

6.5 Prior to the end of each Membership duration, we will notify you of any changes to the Membership fees or terms and conditions that may apply to the renewal.

6.6 If you wish to make any changes to your Membership, such as upgrading or downgrading your Membership plan, you may do so on our website, or contact us at hello@saged.com.au to discuss your options.

6.7 If you wish to terminate your Membership before the end of the selected duration, please refer to Section 7 of these terms and conditions for information on how to cancel your Membership and any applicable obligations.

6.8 Team Memberships are billed annually to the purchasing Organisation and are subject to the agreed contractual terms. Individual users registering under a Team Membership will retain access for the duration of the Organisation’s subscription term, unless otherwise notified.

7. Cancellation of Membership

7.1 Except in the case of Team Memberships, you may cancel your Membership at any time on the website, or by providing written notice to hello@saged.com.au; however, your cancellation will take effect only after the completion of the 12-month initial term. If you cancel before the end of the 12-month term, you remain responsible for any outstanding Membership fees for the remainder of the term.

7.2 Membership fees are non-refundable, and cancellation does not entitle you to a refund of any fees already paid.

8. Payment

8.1 Membership fees are payable in advance and (to the extent permitted by law) are non-refundable, even if your Membership is cancelled under sections 6 or 7 of these terms and conditions. By signing up for a Membership, you authorise us to charge your chosen payment method for the Membership fees.

8.2 All paid Membership plans are subject to a minimum 12-month initial term commitment. You may choose to pay for your Membership on a monthly or annual basis, but this does not alter the 12-month initial commitment period.

8.3 If you select a monthly payment option, payments must be made in full each month for the duration of the initial 12-month term.

8.4 If you select an annual payment option, your Membership fee for the entire 12-month period must be paid upfront.

8.5 For Team Memberships, all payments are made in advance by the Organisation on an annual basis. Individual users registering under a Team Membership are not required to make individual payments.

9. Intellectual Property

9.1 All Content, including but not limited to text, images, videos, and presentations, are the intellectual property of SAGED and are protected by copyright laws. You may not reproduce, distribute, or create derivative works based on our Content without our prior written consent.

10. Privacy

10.1 We value your privacy and we work hard to protect the information you provide to us. Our Privacy Policy is incorporated into the Terms, and sets out how we will collect, use, store, disclose and dispose of your personal information and can be found at https://saged.com.au/pages/t-cs.

10.2 If you register using a Team Access Code, your personal information will be managed in accordance with our Privacy Policy.

11. Limitation of Liability

11.1 Other than as expressly set out in these Terms or as required by law, we make no express or implied warranties in relation to the SAGED Platform. You expressly agree that use of the SAGED Platform is at your sole risk. We do not warrant that the SAGED Platform will be uninterrupted or error-free. We do not warrant any outcomes from your use of the SAGED Platform, or information or content provided through the SAGED Platform.

11.2 We do not warrant that the SAGED Platform will be available at any time. You acknowledge that the SAGED Platform may be unavailable for a number of reasons, including due to matters beyond our control, and you must not hold us accountable in respect of the SAGED Platform not being available at any time. We do not warrant that Your use of the SAGED Platform will meet any particular performance criteria.

11.3 We do not warrant or make any representations concerning the completeness, timeliness, suitability or accuracy of any material on or linked to the SAGED Platform, or that access to the Platform will be uninterrupted, timely or secure.

11.4 To the extent permitted by law, you agree that we are not liable for any loss or claim by you (whether arising in contract, tort, under statute or otherwise) for any direct, indirect, special, incidental, consequential loss, damages or injury including loss of profits, revenue or data arising out of or in connection with your Membership or the use of the SAGED Platform, or the completeness, timeliness, suitability or accuracy of any material or information on the SAGED Platform.

11.5 By using our website, you acknowledge your acceptance of these terms of use and agree to comply with them. If you do not agree with these terms, please refrain from using our website or accessing our Services.

11.6 While we strive to maintain a secure website, we do not guarantee freedom from bugs, viruses, or malicious code. You are responsible for configuring your technology and using antivirus software.

11.7 You may link to our home page in a fair and legal manner, but not in a way that implies endorsement or association with us. Do not frame or mirror our site or link to parts other than the home page. We may withdraw linking permission without notice.

12. Termination

12.1 We reserve the right to suspend or terminate your Membership at any time if you breach these terms and conditions or engage in conduct that we deem inappropriate.

13. Changes to Terms

13.1 We reserve the right to modify these Terms and Conditions at any time. Users will be notified of material changes. Continued use of the platform following any modifications signifies acceptance of the new terms.

14. Governing Law

14.1 These terms are governed by the laws of Victoria, Australia. Any disputes will be subject to the exclusive jurisdiction of the courts in Victoria.

15. Additional Terms

15.1 These terms and conditions are in addition to any standard terms and conditions that apply to our website and other services. In the event of any conflict between these terms and any standard terms and conditions, these terms specific to Membership shall prevail for members of the SAGED platform.

16. Discount Offers

16.1 From time to time, SAGED may offer discounts on Membership fees or Learning Credits ("Discount Offers"). These Discount Offers may be subject to specific terms and conditions, which will be communicated at the time of the offer.

16.2 To be eligible for a Discount Offer, you may be required to meet certain criteria, such as being a new member, purchasing a specific Membership plan, or entering a promotional code at the time of purchase.

16.3 The terms and duration of Discount Offers may vary, and SAGED reserves the right to modify or terminate any Discount Offer at any time without prior notice.

16.4 If you are eligible for a Discount Offer, you may redeem the offer by following the instructions provided at the time of the offer. Failure to comply with the specified instructions may result in the offer not being applied to your purchase.

15.5 Discount Offers may not be combined with any other offers or promotions unless explicitly stated otherwise. Only one Discount Offer may be applied per transaction unless otherwise permitted by SAGED.

16.6 Each Discount Offer will have an expiration date or validity period, after which the offer will no longer be valid. Expired Discount Offers cannot be redeemed or applied to future purchases.

16.7 SAGED reserves the right to verify the eligibility of users for Discount Offers and to revoke or refuse to honour any Discount Offer if it determines, in its sole discretion, that the offer has been obtained or used in violation of these terms and conditions.

17. Contact Information

17.1 For any queries or concerns regarding these Terms and Conditions, please contact our support team at hello@saged.com.au.

18. Declaration

18.1 By signing up for a Membership, whether as an individual or through a Team Access Code provided by an Organisation, you acknowledge that you have read, understood, and agree to these terms and conditions, and any updates published from time to time in accordance with section 13.

Thank you for using our website and Services. Your compliance with these terms ensures a safe and valuable experience for all users.

An Organisation may purchase Memberships in bulk for use by employees or affiliates (together, a “Team Membership”). This Schedule 1 details the additional Terms and Conditions that apply to the Organisation. 

1. Team Membership Setup and Activation

1.1 A Team Membership is only activated when all onboarding steps are complete and a Team Access Code is issued by SAGED.

1.2 Upon receipt of payment, SAGED will issue a multi-use Team Access Code valid for activation of the total number of Memberships purchased..

1.3 Payments are non-refundable, including in cases where allocated Memberships are not used or are terminated in accordance with these Terms and Conditions, except as required by law.

1.4 Where complimentary Memberships are granted, no invoice is issued. The Team Access Code will be provided following written confirmation from the Organisation.

2. Seat Allocation and Use

2.1 The Team Access Code may be used up to the total number of Memberships included in the Team Membership.

2.2 Once a Membership is activated by an individual, it is non-transferable and assigned to that individual for the full membership term.

2.3 The Organisation must ensure that Team Access Code is only used to activate Memberships for eligible healthcare professionals employed or engaged by the Organisation and must use all reasonable endeavours to ensure that any such Memberships are used appropriately and in accordance with these Terms and Conditions.

2.4 All individuals accessing SAGED through a Team Membership are subject to the Terms and Conditions.

2.5 SAGED may revoke platform access for any Member in breach of the Terms and Conditions. That Member’s Membership cannot be re-activated by or transferred to another user within the Organisation.

3. Team Access Code Validity

3.1 The Team Access Code is valid for twelve (12) months from the date of issue unless otherwise specified in writing.

3.2 Unused Memberships do not roll over after the expiry date and are non-refundable.

4. Membership Inclusions

4.1 All Team Memberships are provisioned under the SAGED Premium Plan as defined on the Website.

4.2 At this stage, Organisations purchasing Team Memberships do not have access to individual learning records, usage data, or identifiable user information. We will notify users if this changes in the future.

5. Term and Renewal

5.1 Team Memberships are valid for twelve (12) months from Team Access Code issuance date, unless otherwise agreed.

5.2 SAGED will notify the Key Contact prior to the end of the term with renewal options.

5.3 Renewals are subject to then-current terms and pricing.

6. Special Offers and Discretionary Seats

6.1 SAGED may offer discounted or complimentary Seats at its discretion or as part of promotions or loyalty programs.

6.2 All discounted or complimentary Memberships remain subject to these Terms and Conditions.

7. Organisation Obligations

7.1 The Organisation must designate a Key Contact authorised to act on its behalf.

7.2 The Organisation must ensure all Members accessing SAGED via their Team Access Code comply with these Terms and Conditions.

7.3 By submitting the Team Membership request, the Key Contact confirms they have authority to act on behalf of the Organisation and its users.

8. Termination

8.1 SAGED may terminate the Team Membership immediately if any of these Terms and Conditions are breached.

8.2 In the event of termination of a Team Membership, all relevant Memberships within the Team Membership may also be terminated (at SAGED’s sole discretion), unused Memberships are forfeited, and no refunds will be provided.

9. Liability

9.1 To the extent permitted by law, SAGED disclaims liability for indirect or consequential loss arising from the Team Membership or use of the platform.

10. Amendments

10.1 SAGED may update these Terms and Conditions from time to time. Material changes to Schedule 1 will be communicated to the Key Contact.

10.2 Continued use of the platform after changes take effect constitutes acceptance of the updated Terms and Conditions.

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Introduction

Welcome to the Montu Group of companies and businesses.

Montu includes Montu Group Pty Ltd (ABN 35 634 198 360) and its wholly owned subsidiaries Alternaleaf Pty Ltd, uMeds Australia Pty Ltd and Leafio Pty Ltd, as well as all its businesses including SAGED (Montu, we, us, our) and applies to all business conducted by Montu in Australia.

Montu is committed to respecting and protecting the privacy of the information provided by you when you engage with us. We conduct our business in accordance with the Australian Privacy Principles (APPs) in the Privacy Act. The APPs govern the way in which we collect, use, process, store, share, transfer and dispose of your Personal Information. The APPs can be found on the website of the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au/.

Application of this Policy

This Policy applies to everyone that uses our Services or browses, accesses, or provides information to us including on or through our Platforms (collectively and individually referred to as you or your within this Policy).

In this Policy:

Health Information means Personal Information about a person’s health, health services provided to them, information collected in providing health services to them and other information within the meaning of that term in the Privacy Act
Medicine means medicine prescribed by a prescribing practitioner.
Personal Information means information or an opinion about an identified individual, and other information within the meaning of that term in the Privacy Act including Health Information.
Platform means any one or more of the websites, digital media, and service platforms we use to provide the Services.
Policy means this privacy policy as updated from time to time.
Privacy Act means the Privacy Act 1988 (Cth).
Services means the services each of us provide as described in the Terms.
Staff means people employed by us or contracted to us to provide the Services.
Terms means the terms of service with each of us and any one of us, our Policy, and any other agreement with us that you accept.

Further information about the Services provided by our Australian businesses is set out in the Terms for those businesses on our Platforms, which currently include:

• Alternaleaf - telehealth clinic
• uMeds - service platform to facilitate the purchase and delivery of Medicine from pharmacies
• Leafio - medicine distributor for healthcare professionals
• Saged - medicine education platform for healthcare professionals 
• Montu Brands and Montu Medical - product information for healthcare professionals

1. Information We Collect 

We collect your Personal Information when you use our Services including the Platforms. 

1.1 Information we collect directly from you:

We may collect Personal Information you give us directly:

• when you use a Platform
• when you make an inquiry or order in relation to our Services including through a Platform 
• when you contact us by telephone or in correspondence, including when you complete a form or communicate with us through a Platform, interact with our chatbot, or write to us by email
• while participating in customer satisfaction and market research surveys, 
• when we provide you with any of our Services, and
• if you are a healthcare professional or staff member of a health organisation, when you provide us with information such as your name, AHPRA registration number, and details of the health organisation you work at (including name, address, and ABN), to enable us to provide support, fulfil orders, otherwise deliver our Services to you.

Recording of Consultations and Customer or Support Calls

To help us maintain and improve the quality of our Services, we may record interactions you have with our Staff. This includes:

• telehealth consultations with healthcare practitioners
• participation in patient experience activities such as service evaluations or user feedback sessions, and
• sales calls made by our account managers and inbound and outbound customer support calls from pharmacies regarding orders and service inquiries.
  

These recordings may be used for quality assurance, training, and service improvement purposes. Where recordings are made, and notice or consent is required by law, you will be informed prior to the interaction. By continuing, you provide your consent to the recording. 

Recordings of telehealth consultation are stored for 14 days in accordance with this Policy, but transcriptions of these recordings may be kept for a longer period as described in section 5.1 of this Policy. Customer or support call recordings are stored securely and retained only for as long as necessary to fulfil their intended purpose, in line with applicable legal and operational requirements. Recordings made as part of patient experience or user research activities are handled securely, and in line with the User Experience Research section of this Policy.

1.2 Information we collect directly from third parties:

We may collect Personal Information from third parties including:

• prescriptions issued to you by third parties
• health records relating to you created or held by third parties
• other information created, held, or known by third parties relevant to the provision of our Services to you, and
• other information created, held, or known by third parties relevant to Medicine prescribed to you. 

1.3 Information we collect indirectly 

We and our third-party business partners, including analytics and advertising partners, may automatically collect Personal Information including through cookies or similar technologies when you use our Platform. This includes your browser type, operating system, pages viewed, interactions, links clicked, IP address, visit duration, referring URL, and search terms. Our partners may also track your online activities over time and across different websites and services. See section 4 (Cookies and Tracking Tools).

1.4 Information we collect from other sources 

We and our third-party business partners may collect Personal Information about you from other sources, such as third parties, public databases, and social media platforms that are relevant to our Services. Examples include databases containing Personal Information about:

• your contact or financial details 
• If you are a healthcare professional, your licensing and registration status, such as verifying your AHPRA registration number against the AHPRA public register
• your prescriptions for Medicine issued by third parties such as state health Safe Script databases, and
• your past and current healthcare, symptoms, diagnoses, and treatment plans.

If you are a patient of Alternaleaf, we may also collect your Personal Information from your My Health Record in line with legal requirements, to support your care. You can control Alternaleaf’s access to your My Health Record directly when logging into My Health Record.

2. How we use your information

We may use your Personal Information in the following ways:

2.1 To provide Services to you

We use your Personal Information to:

• conduct our business
• provide our Services to you
• provide customer service to you and respond to enquiries
• communicate with you
• customise our marketing programs and campaigns, and
• send you alerts, announcements, invitations, and other information about products, brands, services, and health topics

2.2 To connect you with third parties 

We may connect you with third parties to provide our Services. If you use this function, your use will be governed by the third party's privacy policy and terms. We recommend carefully reviewing the privacy policies and terms of these third parties.
Third parties may include:

• Pharmacies, 
• Partner delivery services, and
• Suppliers or sponsors of Medicine.

2.3 To validate your ability to access services and information

Certain products, services, and information we provide may be tailored for and accessible to individuals who meet specific eligibility criteria. In such instances, we may verify your eligibility to access these offerings. 

Examples include:

• certain information intended solely for registered healthcare professionals. We may use information gathered directly from you and external sources to confirm your eligibility to access this information.
• eligibility to utilise our patient services. We may use details such as Medicare card details and Individual Healthcare Identifier (IHI) to identify an individual for health care purposes.

2.4 To improve our Services 

We aim to continuously improve our Services while ensuring compliance with legal and regulatory requirements. This means that we may use your Personal Information to practice effective risk management and quality control through auditing and compliance monitoring.

We use Personal Information for data analysis, understanding impact of product or Services, tracking, and addressing concerns, fraud prevention, quality assurance, training, the improvement, and efficient delivery of our Services to you, product development and patient advocacy. We may also use your Personal Information to practice effective risk management and quality control through auditing and compliance monitoring.

We use Personal Information to meet regulatory monitoring and reporting obligations, including while protecting against adverse events, responding to product or service complaints, and promotion to patient safety.

2.5 To conduct clinical research to inform future clinical practice

As part of the Alternaleaf clinic, your Personal Information will be collected, used, and stored for the purposes of clinical research related to your Medicine. Your medical data will be included in a Medical Cannabis clinical research patient registry (Registry), which is designed to gather information on individuals with specific conditions or diagnoses. This Registry helps healthcare professionals improve patient outcomes, enhance treatment strategies, and provide valuable data for future research, including the development and testing of new treatments.

The data collected within the Registry will initially be deidentified but re-identifiable to allow for future medical treatment. For research purposes, however, the data will be de-identified [so that it is not re-identifiable], ensuring that such data cannot be personally identified when it is shared with third-party research institutes. Research conducted with registry data will adhere to the Privacy Act and the Australian National Health and Medical Research Code for the Responsible Conduct of Research (available at NHMRC Research Code) to ensure that research is conducted ethically and with integrity.

Third-party research institutes may access the data to conduct approved research in accordance with the Code, and all research data will be handled confidentially and used in a de-identified format.

Please note that once your data has been entered into the Registry, it cannot be removed retrospectively if it has already been deidentified and used in research. However, you have the right to withdraw your consent for any further collection or addition of your identifiable data from the Registry at any time. Should you wish to do so, please contact us using the details provided below, and your identifiable data will be removed upon request.

2.6 For marketing purposes

We may use your Personal Information to communicate updates about new features, events, Services, or products that may interest you, based on your interactions on the Platforms and with your consent for using cookies. You may unsubscribe from our marketing lists at any time by contacting us in writing. 

2.7 User experience research

We may occasionally invite users, including patients and pharmacies, to participate in user experience research, user texting, or service evaluations to help us improve our offerings. This may involve collecting Personal Information that you provide directly or that is generated through your interactions with our Services. With your consent, these sessions may be recorded to ensure accurate feedback. 

Any information collected during these activities will be handled securely and used solely for improving our products and Services. Personal Information will be kept confidential and separated from the feedback provided, and results will be anonymised wherever possible.

Participation is completely voluntary, and you can choose to opt out at any time without affecting your access to our Services. Where possible, personal data collected for these purposes will be anonymised or de-identified to further protect your privacy.

If you have questions or concerns about how your information is used in user testing or service improvement activities, please contact us using the details provided below.

2.8 In aggregated and de-identified form

We may aggregate and de-identify Personal Information collected through the use of our Services. By aggregating data, we consolidate information we obtain to gain insights into trends and patterns that can inform our business decisions and improve user experiences.

When we de-identify data that was originally based on Personal Information, we ensure that any identifiable details are removed so that individuals cannot be identified or reidentified. This data allows us to analyse broader trends and behaviours without compromising individual privacy. It is our commitment to maintain the de-identified status of this data.

3. How we disclose your information

Examples of how we disclose your Personal Information are below. This list is not intended to be exhaustive. There may be other third parties to which we give your Personal Information (for example, professional advisors or insurers) where required or permitted by law. In some circumstances, the entities with which we share information with may also share your Personal Information with other entities with which they do business. 

3.1 Within our family of companies 

Montu may share your Personal Information within the Montu group of companies for the purposes outlined in this Policy.

3.2 With Providers 

We may engage other companies and individuals to perform Services on our behalf, and we may collaborate with others for specific products or services (collectively and individually, Providers). Providers may have access to Personal Information, which may include through the use of cookies, and similar technologies, to carry out their responsibilities. When we share your Personal Information with Providers, we require that they adhere to appropriate privacy and security standards.

Examples of Providers include: 

• credit card processors - to securely process your payments
• sale platform providers (such as Shopify) - to manage and fulfil your online orders
• customer support providers - to help respond to your questions or concerns
• email and SMS service providers - to send you order updates or other communications
• web hosting and development companies - to keep our Platforms running smoothly
• data warehouse providers - to help us store and analyse information securely
• Medicine suppliers, sponsors, and distributors - to supply products to healthcare professionals
• pharmacies - to help dispense your Medicine
• technology integration partners (such as PharmX) - to support and enable service integrations and delivery of products
• delivery partners - to get your order to you safely and on time.

3.3 To comply with laws and protect individuals

We may disclose your Personal Information to a third party if authorised under the Privacy Act, including if we are required or authorised by or under law, for example, if we are required to respond to a subpoena, court order, or to comply with a regulatory requirement.

We may disclose your Personal Information if we consider it necessary to ensure the safety of an individual or other members of the public, for example where Staff identify serious concerns for the immediate safety or welfare of any person, we may report this to emergency services.

3.4 Aggregate/De-identified Data

We may share aggregated or de-identified data, which does not personally identify individuals, with third parties for purposes permitted by applicable law.

3.5 Overseas disclosure of Personal Information

We may use and disclose your Personal Information to our Providers for services such as software and system development, communication networks and data storage located outside Australia. The data protection laws in that country may be of a lower standard than those in Australia. We will take all reasonable steps to ensure this information is handled in compliance with the APPs.

3.6 Use of AI Function

We may use artificial intelligence (AI) technologies to improve our services by:

• enhancing functionality and performance
• personalising user experiences
• automating routine tasks
• analysing user behaviour to better understand needs

AI tools may process Personal Information you provide directly or that is generated through your interactions with our Services. We handle all such information in accordance with this Policy. We also regularly review AI tools to ensure they meet our privacy and ethical standards.

Personal Information collected through AI tools is only disclosed where permitted under this Policy - for example, to trusted service providers or where required by law.

Where AI is used in clinical settings, it supports but does not replace the judgement of qualified healthcare professionals, who retain full responsibility for all medical decisions.

If you have any questions about our use of AI, please contact us using the details provided below.

4. Cookies and tracking tools

We use cookies, web beacons, and similar tracking technologies (collectively and separately, cookies) to enhance our understanding, customise and improve user experiences on our Platforms and use of our Services, and to manage our advertising and analytics initiatives. 

Cookies may fall within the following categories:

• Essential Cookies: These cookies are necessary for the Platforms to function properly. They enable basic functions like page navigation and access to secure areas of the website.
• Performance and Analytics Cookies: These cookies help us understand how visitors interact with our Platforms by collecting information anonymously. This data helps us improve the performance of our website.
• Functionality Cookies: These cookies allow the Platforms to remember choices you make and provide enhanced, more personalised features.
• Advertising Cookies: These cookies are used to deliver advertisements that are more relevant to you and your interests. They may also be used to limit the number of times you see an advertisement and measure the effectiveness of advertising campaigns.

4.1 Managing your cookie preferences

You can manage your cookie preferences through your web browser settings. Most browsers allow you to control cookies through their settings, which may include the ability to delete cookies or block certain types of cookies. However, please note that blocking cookies may affect your experience on the Platform and limit its functionality.

4.2 Third-party cookies

We may also use cookies provided by third-party for analytics, advertising, and other purposes. These cookies are subject to the respective privacy policies of these third parties. We do not guarantee links or policy of third parties.

5. How we hold and secure your information

5.1 Holding your information

We hold your Personal Information in information management systems which may be on-premises or cloud-based servers, data warehouses, data lakes, and in hard copy files. These systems are managed in a number of ways. They may be managed or administered directly by us or by a Provider internally by us, or they could be managed by a third-party with whom we may have a contractual relationship. Where practicable possible, we ensure data is stored in Australia–particularly for medical Personal Information. Some third-party tools may store or process other types of Personal Information (such as non-medical identifiers) in offshore data centres, including locations like the US, though we make every reasonable effort to ensure our service providers store data locally. Regardless of where your data is stored or accessed, we take reasonable steps to safeguard it in line with this Policy and applicable Australian privacy laws.

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 it. However, most of the Personal Information contained in a patient’s medical record is or will be stored in patient files, which will be retained for a minimum of 7 years to comply with health record legislative requirements around record retention.

5.2 Securing your information

Your Personal Information is stored in a manner that reasonably protects it from misuse, loss, and unauthorised access, modification, or disclosure. We use a combination of administrative, physical, and technical safeguards to do this. These include secure system access controls, encryption of sensitive data, secure transfer methods, and regular reviews of our information handling practices. We also assess the security measures of third-party service providers where they are involved in storing or processing your Personal Information, to ensure they meet appropriate standards.

These measures are designed to align with industry standards and evolve as threats and technologies change.

6. Changes to this Policy 

We reserve the right to change the terms of this Policy from time to time, and we will inform you of any material changes. An up-to-date copy of our Policy is available on our Platforms, and we encourage you to check the Platforms you use periodically to make sure you are aware of the current terms of the Policy. 

7. Your privacy rights

7.1 Consent to collect, use, and share your information

We are required to obtain your consent to collect, use and share your Personal Information. You provide this consent by using, and continuing to use, our Services and Platforms. 

We want to ensure that you fully understand the consequences of giving or not giving your consent. Consent is voluntary, meaning you are not being forced to provide consent, and it should be current and specific at the time it is given.

Providing consent to your Personal Information, including your Health Information, comes with both benefits and risks. The primary benefit of providing consent is that it is often a necessary step for us to provide our Services and/or products to you.

However, there may be risks associated with giving consent. In the event of a data breach, there could be unintended misuse, interference, loss, or unauthorised access, modification, or disclosure of your Personal Information. We take these risks seriously and have implemented a range of measures to minimise the chances of such incidents occurring.

7.2 How to access or correct your information

You have the right to request access to the Personal Information that we hold about you and to request that we correct any Personal Information that is incorrect or incomplete. To make a request, please send us an email or a written request using the contact details provided below. Once received, we will aim to respond to your request within 30 days.

You will be required to show that you are authorised to make a request if acting on behalf of someone else, or otherwise have legal authority to request this information (such as a warrant, subpoena, order, or notice).

In most cases, there is no charge for requesting access to or correcting your Personal Information. In certain circumstances we may require you to meet our reasonable costs of providing you with access to your information.

Please be aware that there are some circumstances in which we may not be able to provide access to or correct your Personal Information. For example, if we are conducting a sensitive investigation, or if any of the exceptions in the Privacy Act apply, we may deny your request. If we refuse your request, we will provide you with a written statement which sets out the reasons for the refusal and the avenues available to you to make an appeal or complaint.

7.3 Right to withdraw consent

You have the right to withdraw your consent for us to collect, use or disclose your Personal Information at any time. If you choose to withdraw consent, we will stop collecting, using, and disclosing your data for the specific purposes for which consent was given, from the time of withdrawal

Please be aware that withdrawing consent may mean we are unable to continue to provide our Services to you. 

To withdraw consent, please contact us using the details below. 

7.4 How to make a privacy complaint

If you think we have not handled your Personal Information correctly or in accordance with the law, you can lodge a complaint with our Privacy Officer or the Office of the Australian Information Commissioner (OAIC). We recommend you contact us first so that we can try to resolve your complaint to the best of our ability. The OAIC will usually refer you back to us if you have not already complained directly to us.

When our Privacy Officer receives a complaint, they will contact you to acknowledge your complaint. You will have the opportunity to explain why you are unhappy with how we have handled your Personal Information and provide further detail. Our Privacy Officer will review your concerns, taking into account all relevant information, including relevant privacy requirements, and work with you to try to resolve your complaint. If you are not satisfied with the outcome of your complaint, you can take your complaint to the OAIC.

8. Contact information

8.1 Contact us

Please contact the Privacy Officer in writing if you wish to make an access or correction request, make a complaint, have questions about this Policy or would like a free copy of this Policy:

Level 18/1 Nicholson St, East Melbourne VIC 3002

By email: Privacy@montu.com.au

8.2 Office of the Australian Information Commissioner (OAIC)

Complaints to the OAIC must be made in writing and cannot be made over the phone. Please refer to the 'Lodge a privacy complaint with us' page on the OAIC website to access the relevant forms. For general inquiries about the processes for making a complaint to the OAIC or for other privacy advice, you can call the OAIC on 1300 363 992.