Pharmako Biotechnologies Pty Ltd (ABN 43605139688) and its related entities ("we", "us", “our” or the "Company") is committed to privacy protection. We understand the importance of keeping personal information private and secure. This privacy policy ("Privacy Policy") describes generally how we manage personal information you provide to us, including via http://pharmako.com.au ("this site"). By submitting personal information to us, you agree to our use of your personal information as described herein. This Privacy Policy forms part of and is subject to the provisions of our Website Terms (http://pharmako.com.au /website terms). If you would like more information, please don't hesitate to contact us.

We care about your privacy:

We will never rent, trade or sell your email address to anyone.
We will never publicly display your email address or other personal details that identify you without your consent.

Privacy Law Obligations

We will treat all personal information in accordance with our obligations pursuant to the Privacy Act 1988 (Cth) (“Privacy Act”) and other international legislation regarding data protection and privacy where applicable. The Privacy Act lays down 13 key principles in relation to the collection and treatment of personal information, which are called the “Australian Privacy Principles”.

What is "personal information"?

Personal information has the meaning given to it in the Privacy Act and may include your:
• name and date of birth;
• residential and business postal addresses, telephone/mobile/fax numbers and email addresses;

• your computer and connection information; and

• any information which includes information or an opinion about an identified individual or an individual who is reasonably identifiable from the information or opinion.

How we may collect your personal information

Pharmako only collect personal information that is necessary for us to conduct our business. We are an Australian company specialising in innovative, premium ingredients and excipients for the nutraceutical, pharmaceutical, functional food and cosmeceutical industries. We manufacture materials created through scientific research and innovative product development.

We may collect personal information when you:
• use this site, including (without limitation) when you complete an online contact form to contact us; provide information to us by telephone or in person;
• send us an email or other communication;
• in relation to employment or engagement by us;
• become our customer or supplier;
IP addresses

This site may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. The Company collects and manages IP addresses as part of the service of providing internet session management. The Company may also collect and use web log, computer and connection information for security purposes and to help prevent and detect any misuse of, or fraudulent activities involving, this site.

Cookies

This site may use "cookies" to help personalise your online experience. A cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer. There are two types of cookies that may be used at this site: a persistent cookie and a session cookie. A persistent cookie is entered by your web browser into the "Cookies" folder on your computer and remains in that folder after you close your browser and may be used by your browser on subsequent visits to this site. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer. In some cases, cookies may collect and store personal information about

you. The Company extends the same privacy protection to your personal information, whether gathered via cookies or from other sources.
You can configure your internet browser to reject all cookies or notify you when a cookie is sent. Please refer to your internet browser’s instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer.

Why we use cookies

This site may use cookies in order to:
• remember your preferences for using this site;
• remember details of data that you choose to submit to us (eg, through online contact forms).
Many of these cookies are removed or cleared when you log out, but some may remain so that your preferences are remembered for future sessions.

Third party cookies

In some cases, third parties may place cookies through this site. For example:
• Google Analytics, one of the most widespread and trusted website analytics solutions, may use cookies de- identified data about how long users spend on this site and the pages that they visit;

How we may use your personal information

We use information we collect from and about you for the primary purpose of providing our goods to you and for our legitimate business interests. Your personal information may be used in order to:

• verify your identity;
• respond to any queries or feedback that you may have;

• conduct appropriate checks for credit-worthiness and for fraud;
• perform a contract with you;
• prevent and detect any misuse of, or fraudulent activities involving, this site;
• conduct research and development in respect of our products and/or services;
• gain an understanding of your information and communication needs or obtain your feedback or views about our products and/or services in order for us to improve them; and/or
• maintain and develop our business systems and infrastructure, including testing and upgrading of these systems,
and for any other purpose reasonably considered necessary by the Company in relation to the operation of our business.

Direct Marketing
We may send you direct marketing communications, news, alerts and information about our products or those of selected partners that we consider might be of interest to you and may continue to do so after you cease acquiring products from us. In accordance with applicable marketing laws, such as the Spam Act 2003 (CTH) you consent to receiving direct marketing communications and information from us. You can opt out from receiving such communications at any time if you chose by contacting the email address below or by using any opt out facilities provided in the communications.

When we may disclose your personal information

For the purposes set out above, the Company may disclose your personal information to organisations outside the Company and the Company takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information. In addition, we may disclose your personal information to:

• your authorised representatives or legal advisers (when requested by you to do so);
• credit-reporting and fraud-checking agencies, credit providers (for credit-related purposes such as creditworthiness, credit rating, credit provision and financing);
• our professional advisers, including our accountants, auditors and lawyers;
• government and regulatory authorities and other organisations, as required or authorised by law;
• organisations who manage our business strategies, including those involved in a transfer/sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our business risk and funding functions; and
• the police or other appropriate persons where your communication suggests possible illegal activity or harm to others.

Access to your personal information

In most cases, you may have access to personal information that we hold about you. We will handle requests for access to your personal information in accordance with the Australian Privacy Principles unless you are in the EU or UK please see section on GDPR below. All requests for access to your personal information must be directed to the Privacy Officer by email using the email address provided above or by writing to us at our postal address. We will deal with all requests for access to personal information as quickly as possible. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may charge you a fee for access if a substantial cost is incurred by us in order to retrieve your information, but in no case will we charge you a fee for your application for access.
In some cases, we may refuse to give you access to personal information that we hold about you. This may include circumstances where giving you access would:

• be unlawful;

• have an unreasonable impact on another person’s privacy; or
• prejudice an investigation of unlawful activity.
We may also refuse access where the personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discovery in those proceedings.
If we refuse to give you access, we will provide you with reasons for our refusal.

Correcting your personal information

We will amend any personal information about you that is held by us that is inaccurate, incomplete or out of date if you request us to do so. If we disagree with your view about the accuracy, completeness or currency of a record of your personal information that is held by us, and you ask us to associate with that record a statement that you have a contrary view, we will take reasonable steps to do so.

Storage and security of your personal information

We will take all reasonable precautions to protect your personal information from unauthorised use, loss, theft or modification. In our business, personal information may be stored both electronically (on our computer systems and with our website hosting provider) and in hard-copy form. We take all reasonable administrative measures to ensure the security of hard-copy information.

We also have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of the breach where we are legally required to do so, if you are based in the
UK or EU notification will be made within 72 hours of the breach.

Unfortunately, the transmission of information via the internet is inherently insecure. Although we will do our best to protect your personal information we cannot provide any assurance regarding the security of transmission of information you communicate to us online.

Do we disclose your personal information to anyone outside Australia?

We may disclose information to our business partners, customers, service providers, suppliers located overseas for some of the purposes listed above. Some of these entities may be located in USA, Europe, and you consent to having any personal information accessible or transmitted outside Australia. Cross border disclosure of personal information by us or our business partners or third-party suppliers is addressed by our contractual arrangements and the privacy policies and procedures of those persons.

Third party websites

You may click-through to third party websites from this site, in which case we recommend that you refer to the privacy statement of the websites you visit. This Privacy Policy applies to this site only and the Company assumes no responsibility for the content of any third-party websites.

GDPR

If you are in the European Union or the United Kingdom, the Controller of your personal data is Pharmako Biotechnologies Pty Ltd (ABN 43605139688). The Company welcomes the General Data Protection Regulation (“GDPR”) of the European Union (“EU”) as an important step forward in streamlining data protection globally. We intend to comply with the data handling regime laid out in the GDPR in respect of any personal information of data subjects in the EU that we may obtain.

GDPR rights

The requirements of the GDRP are broadly similar to those set out in the Privacy Act and include the following rights:
• you are entitled to request details of the information that we hold about you and how we process it. For EU residents, we will provide this information for no fee;

• you may also have a right to:
– have that information rectified or deleted;
– restrict our processing of that information;
– stop unauthorised transfers of your personal information to a third party;
– in some circumstances, have that information transferred to another organisation; and
– lodge a complaint in relation to our processing of your personal information with a local supervisory authority; and
• where we rely upon your consent as our legal basis for collecting and processing your data, you may withdraw that consent at any time.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal
obligations. However, please be aware that:
• such objection or withdrawal of consent could mean that we are unable to provide our services to you, and could unduly prevent us from legitimately providing our services to other customers/clients subject to appropriate confidentiality protections; and
• even after you have chosen to withdraw your consent, we may be able to continue to keep and process your personal information to the extent required or otherwise permitted by law, in particular:
– to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and which does not materially impact on your rights, freedoms or interests; and
– in exercising and defending our legal rights and meeting our legal and regulatory obligations.

Storage and processing by third parties

Data that we collect about you may be stored or otherwise processed by third party services with data centres based outside the EU, such as Google Analytics, Microsoft Azure, Amazon Web Services, Apple, etc and online relationship management tools. We consider that the collection and processing of this information is necessary to pursue our legitimate interests in a way that might reasonably be expected (eg, to analyse how our customers/clients use our services, develop our services and grow our business) and which does not materially impact your rights, freedom or interests.

We require that all third parties that act as “data processors” for us provide sufficient guarantees and implement appropriate technical and organisational measures to secure your data, only process personal data for specified purposes and have committed themselves to confidentiality.

Duration of retention of your data

We will only keep your data for as long as is necessary for the purpose for which it was collected, subject to satisfying any legal, accounting or reporting requirements. At the end of any retention period, your data will either be deleted completely or anonymised (for example, by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning). In some circumstances, you can ask us to delete your data.

Keeping your information up to date

To ensure that your personal information is accurate and up to date, please promptly advise us of any changes to your information by contacting our data protection officer at eric@pharmako.com.au or by post to our address.

Changes to this Privacy Policy

From time to time, it may be necessary for us to revise this Privacy Policy and all personal information and data held by us will be governed by the most recent version of our Privacy Policy. Any updated versions of this Privacy Policy will be posted on this site.

Contacting us about privacy

If you would like more information about the way we manage personal information that we hold about you or are concerned that we may have breached your privacy, please contact us by email to enquiries@pharmako.com.au or by post.

If you require any further information about the Privacy Act and the Australian Privacy Principles, you can visit the Australian Information Commissioner’s website (see www.oaic.gov.au).