PRIVACY POLICY
Pro Pharmaceuticals Group Pty Ltd

1. INTRODUCTION
   Pro Pharmaceuticals Group Pty Ltd ("Pro Pharma", "we", "us", "our") is committed to protecting personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. This Privacy Policy explains how we collect, use, disclose, store, and protect personal information across our pharmaceutical supply operations, digital platforms, portals, and data systems.

2. SCOPE
   This Policy applies to personal information collected through supply and distribution activities, customer and supplier relationships, regulatory and pharmacovigilance processes, websites, portals and digital platforms, and operational data systems including analytics and AI-assisted tools.

3. PERSONAL INFORMATION WE COLLECT
   We may collect and process personal information including identity and contact information such as name, role, organisation, email, phone and address, professional and regulatory details including healthcare practitioner or institutional information, supplier and commercial information, order, transaction, payment and delivery data, communications and correspondence, regulatory and pharmacovigilance information, and technical and digital data including IP address, device type, browser and system interaction data. We collect only information necessary for legitimate business, regulatory and safety purposes.

4. HOW WE COLLECT PERSONAL INFORMATION
   We collect information directly when you submit enquiries, quotations or orders, communicate with us, use our website or systems, or provide regulatory or safety information. We may also collect information from healthcare institutions, suppliers, logistics providers, regulators and authorised third parties where permitted by law.

5. PURPOSE OF COLLECTION AND USE
   We collect and use personal information for supplying pharmaceutical products and services, processing procurement, orders, payments and logistics, regulatory compliance and pharmacovigilance, managing customer and supplier relationships, operating digital platforms and systems, system performance and analytics, and fulfilling legal and public health obligations. We do not sell personal information.

6. OPERATIONAL, REGULATORY AND PLATFORM DATA PROCESSING
   Pro Pharma operates digital systems and platforms to support lawful pharmaceutical supply, regulatory compliance, pharmacovigilance, safety monitoring and operational management. Information processed within these systems may include operational, regulatory, commercial and limited healthcare-related data necessary for supply chain management, compliance obligations, product safety monitoring, customer and supplier administration, system functionality, auditability and security. Pro Pharma may use analytical or automated tools to process operational and regulatory information for supply optimisation, compliance and service delivery. No automated decision-making affecting patient treatment is performed. Clinical decisions remain the responsibility of qualified healthcare professionals. All data is handled in accordance with applicable privacy and data protection laws and protected through appropriate technical and organisational safeguards.

7. AI, DATA SYSTEMS AND AUTOMATED PROCESSING
   Pro Pharma may use data systems, analytics and AI-assisted tools to support operational, regulatory and supply chain activities including forecasting, product availability and service quality. AI tools support decision-making and do not replace human clinical or regulatory judgement. Personal information is processed only where necessary and in accordance with applicable privacy and regulatory obligations.

8. SUPPLIER AND PARTNER DATA
   We may collect and process personal and business information of suppliers, manufacturers, logistics providers and partners for procurement, quality, regulatory and operational purposes. Pro Pharma also processes confidential supplier, batch and regulatory information for compliance, traceability and safety monitoring. Such information is protected and disclosed only where required for lawful operations, pharmacovigilance or regulatory obligations.

9. CLINICAL, SAFETY AND PHARMACOVIGILANCE INFORMATION
   Where required for regulatory compliance or product safety, Pro Pharma may collect and process information related to adverse events, product quality and pharmacovigilance. This information may be shared with manufacturers, regulatory authorities and authorised safety bodies as required by law and is handled with strict confidentiality.

10. LEGAL BASIS FOR PROCESSING
    We process personal information where necessary for performance of a contract or supply relationship, compliance with legal and regulatory obligations, public health and safety requirements, legitimate business operations, and consent where required.

11. DISCLOSURE OF PERSONAL INFORMATION
    We may disclose personal information to suppliers and manufacturers, logistics and freight providers, regulatory authorities and government agencies, IT and platform service providers, and professional advisers where necessary for lawful operations and compliance. We disclose only what is necessary for the relevant purpose.

12. OVERSEAS DISCLOSURE
    Some systems or service providers used by Pro Pharma may store or process information outside Australia. Where this occurs, we take reasonable steps to ensure information is protected in accordance with Australian privacy requirements.

13. DATA SECURITY
    We implement reasonable technical and organisational safeguards to protect personal information from misuse, loss, unauthorised access, modification or disclosure. Access is restricted to authorised personnel and systems.

14. DATA RETENTION
    Personal information is retained only as long as necessary for business, regulatory and legal obligations. Regulatory and pharmacovigilance records may be retained for extended periods where required by law.

15. ACCESS AND CORRECTION
    You may request access to or correction of personal information we hold about you using the contact details below.

16. COOKIES AND TRACKING TECHNOLOGIES
    Our website and digital platforms may use cookies and similar technologies to enable functionality, improve performance, analyse usage, and support system security. Cookies may collect technical data such as IP address, device type, browser and interaction behaviour. Users may control cookies through browser settings. Disabling cookies may affect website functionality.

17. COOKIE CONSENT AND BANNER COMPLIANCE
    Where required, users may be presented with a cookie notice allowing acceptance, rejection or management of non-essential cookies. Essential cookies required for system operation may continue to function.

18. COMPLAINTS
    If you believe we have breached applicable privacy laws, you may contact us. We will investigate and respond within a reasonable timeframe. If unresolved, you may contact the Office of the Australian Information Commissioner.

19. CONTACT
    Privacy Officer
    Pro Pharmaceuticals Group Pty Ltd
    Email: info@propg.com.au
    Melbourne, Victoria, Australia

20. UPDATES TO THIS POLICY
    We may update this Privacy Policy from time to time. The latest version will be available on our website.