Tissue Repair Ltd (ABN 20 158 411 566) (Sydney, NSW, Australia), TR Therapeutics, Inc. (Reston, VA, USA) and their related entities (together, we, us or our) operate a biopharmaceutical business developing, marketing and supplying advanced wound healing and tissue repair products targeting therapeutic applications for chronic and acute wounds and cosmetic / aesthetic applications.
This Privacy Policy explains what personal information we collect about you and how we collect, use, disclose and manage your personal information.
We are bound by, and committed to protecting the privacy of your personal information in accordance with, the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) under that Act (together, Privacy Act) and this Privacy Policy.
By interacting with us – for example, when you visit our website or any related social media sites that we operate, when you contact us, when you engage in business or collaborate with us, when you use our services, or where you otherwise provide any personal information to us – you consent to the collection, storage, use and disclosure of your personal information, including your sensitive information, in accordance with and as set out in this Privacy Policy.
There is no obligation for you to provide us with any of your personal information but, if you choose not to, we may be unable to effectively interact with you, or provide information or our products or services to you.
HOW WE COLLECT YOUR PERSONAL INFORMATION (AND WHAT WE COLLECT)
General
We may collect personal information from you when you:
- use our website or any related social media sites that we operate;
- make enquiries, request information from us or tell us your experience, through the ‘Contact Us’ form on our website, or by calling us or emailing us;
- engage in business with us, for example as a customer or supplier or service provider;
- collaborate with us, assist us or are otherwise involved in our research or development activities;
- invest in our business or purchase or acquire any products or services we may offer from time to time; or
- otherwise provide us with your personal information.
Where possible, we will collect your personal information directly from you, unless it is unreasonable or impracticable for us to do so. If we collect your personal information from another person and it is unclear that you have consented to the disclosure of that information to us or that information is otherwise not permitted to be disclosed to us, we will, where reasonably possible, make you aware that we have done this and the reasons for doing so.
The kinds of personal information that we commonly collect and hold from you or about you include:
- your name;
- your address, phone number or email address;
- your position or title;
- the name of the business you work for or represent; and
- any other information that may be used to identify you.
Clinical trial participants
As a business engaged in active research and development, we conduct various clinical trials in relation to our wound healing, tissue repair and/or cosmetic products. We approve or appoint third party clinical trial investigators or research organisations (Third Party Researchers) to manage and conduct those trials on our behalf.
If you are a subject of or participant in any of those clinical trials, personal information (including sensitive information and health information) is collected about you in the course of the trials being conducted.
However, pursuant to our arrangements with the Third Party Researchers who conduct the clinical trials with our approval and/or on our behalf, any and all personal information about you (including your sensitive information and health information) may be collected by those Third Party Researchers, not by us. If so, they are responsible for collecting and using such information in accordance with their own privacy policies and the consents which you provide in connection with your participation in the clinical trial. They may disclose some of your personal information to us, and it may be accessible to us.
If you have any questions or concerns regarding the collection, use, holding and/or sharing of your personal information (including sensitive information and health information) by the Third Party Researchers who conduct any clinical trial in which you are a subject or participant, please contact them directly.
HOW YOUR PERSONAL INFORMATION IS USED
General
We may use your personal information for the primary purpose for which it was collected, or for related purposes, including the following purposes:
- providing you with information about our business and the products and services that we offer;
- communicating with you, including to respond to your enquiries, feedback or complaints about our business, products or services when you contact us;
- engaging in business with you;
- where you are a shareholder or investor in our business, communicating with you and administering your shareholding or investment;
- for certain marketing communications (see ‘Marketing Communications’ section below);
- complying with our legal and regulatory obligations; and
- for other purposes as required or permitted by law or regulation.
Clinical trial information
As noted above, as a result of the clinical trials conducted for us by Third Party Researchers in relation to our wound healing, tissue repair and/or cosmetic products, we may obtain information in respect of the subjects/participants in those trials (Clinical Trial Information). We analyse and use this Clinical Trial Information to establish and/or better understand the safety, efficacy and quality of our products, to support applicable regulatory approvals for those products, to improve those products, and to develop new products.
HOW YOUR PERSONAL INFORMATION IS SHARED
General
We may disclose personal information we collect from you to:
- our affiliates, organisations we collaborate or partner with, and our third party service providers who assist us in connection with our business, for the primary purpose(s) for which it was collected;
- our external service providers and professional consultants, including our accountants, auditors and lawyers; or
- Federal and state or territory regulatory authorities.
We may also disclose your personal information if:
- it is required or authorised by law;
- if it is necessary in the interests of public health and safety; or
- if it is otherwise permitted under the Privacy Act.
We will take all reasonable steps to protect your personal information from being dealt with in any way that is inconsistent with the Privacy Act.
Our third party service providers are located in Australia and the United States and may store your personal information outside of Australia.
Clinical trial information
We may disclose Clinical Trial Information to:
- third party service providers who assist us to analyse and use that information for the purposes for which we collect it (as described above); and
- regulators and other government authorities (in Australia and elsewhere) for the purpose of obtaining or supporting applicable regulatory approvals for our products,
or as otherwise permitted or required by law. We may also publish or authorise third parties to publish Clinical Trial Information, for example in scientific publications.
MARKETING COMMUNICATIONS
If, in an earlier interaction with us, you indicated a preference for a method of communication, we will endeavour to use that method to communicate with you whenever practicable to do so.
We may use certain limited information about you (such as your name, email and mobile phone number) to contact you:
- to promote our research and development activities or our business generally;
- to promote and offer you opportunities to invest in our business;
- to promote our cosmetic / aesthetic products;
- if you are a health practitioner, if and as permitted by law, to provide you with details of therapeutic products or services we supply that we think may be of interest to you or your patients/clients
If at any time you decide you no longer wish to receive marketing communications from us, you may use the opt-out/unsubscribe facility option in our email or SMS communications or make a request to not receive marketing communications from us by contacting us using the details noted in the Contact Information section below.
SECURITY OF YOUR PERSONAL INFORMATION
We take reasonable steps to protect your personal information from loss, misuse and interference and from unauthorised access, modification or disclosure.
However, our data protection measures are not a guarantee of the security of your personal information, and no data transmission over the internet can be guaranteed to be 100% secure.
You must also take care to protect your personal information. Please notify us as soon as possible if you become aware of any security or data breaches.
UPDATING AND/OR ACCESSING YOUR PERSONAL INFORMATION
We take reasonable steps to ensure that your personal information that we hold is accurate, complete and up to date. However, the accuracy of that information depends to a large extent on the information you provide to us. To assist us, please:
- ensure you provide us with correct information;
- let us know if there are any errors in your personal information; and
- inform us whenever your personal information changes (such as changes to your name, address, mobile phone number or email address.
You have the right to request access to your personal information at any time by contacting us, including for the purpose of asking us to correct or update that information. If you wish to access, update or correct your personal information that we may hold about you, please contact us using the details noted in the Contact Information section below.
We will respond to any requests regarding the correction of your personal information so that it is accurate, complete and up to date, within a reasonable period after a request is made.
If we refuse to correct your personal information following a request by you to do so, then we will provide you with a written notice of the reason(s) for such refusal and the procedure to complain about our refusal.
We will not charge you for making a request to access or correct your information. However, we may recover from you our reasonable costs of responding to your request and supplying you with access to and/or correcting your personal information.
COOKIES
Information may be collected through the use of “cookies” on our website. Cookies are small text files that a website can use in order to recognise visitors who revisit a website so as to facilitate their ongoing access to and use of the site. They enable usage behaviour to be tracked and aggregate data to be compiled that would facilitate more targeted advertising and improved content. Typically, cookies involve the assigning of a unique number to the visitor. You can prevent the use of cookies by setting up your web browser to block them.
LINKS ON OUR WEBSITE
Our website may contain links to other websites which are owned or operated by other parties. These linked sites are not under our control, and we are not responsible for the information on such websites or the privacy practices (or other conduct) of the entities that operate them. You should make your own enquiries as to the privacy policies and terms and conditions of those operators/websites.
DATA BREACH
If we suspect that a data breach has occurred, we will undertake an assessment into the circumstances of the suspected breach within a reasonable period after the suspected breach has occurred. Where it is ascertained that a breach has actually occurred and where required by law, we will notify the Office of the Australian Information Commissioner (OAIC) and affected customers as soon as practicable after becoming aware that a data breach has occurred.
IF YOU HAVE A PRIVACY COMPLAINT
We are committed to maintaining and protecting your privacy. If you wish to make a complaint about an alleged breach by us of this Privacy Policy or the Privacy Act, please contact us using the contact information in the Contact Information section below.
Please provide us with sufficient detail regarding your complaint and any supporting evidence. We will investigate the issue and determine the steps to be taken to resolve the complaint. We will notify you in writing if we require any additional information or otherwise of the outcome of our investigation of the complaint.
If we do not satisfactorily resolve your complaint, you may refer your complaint to the OAIC at www.oaic.gov/about-us/contact-us.
CONTACT INFORMATION
Any queries about this Privacy Policy, correction or access requests or privacy complaints should be addressed to:
Darryl Reed
Chief Operating Officer
Tissue Repair Ltd
Address: Tower A, Level 9, The Zenith, 821 Pacific Highway, Chatswood NSW 2067, Australia
Email: Darryl.reed@trtherapeutics.com
CHANGES TO THIS PRIVACY POLICY
We reserve the right to update or change our Privacy Policy at any time. Please ensure you review it periodically for changes. You can find the date of the most recent review of this policy at the end of the document.
If we make any material changes, we will notify you by way of a prominent notice on our website announcing such changes.
Your continued use of our website, or the provision by you of further personal information to us, after this Privacy Policy has been amended will be deemed to be your acceptance of and consent to the revised Privacy Policy.
This Privacy Policy was last revised on 7 October 2021.