Geistlich Pharma Australia Pty Ltd – Privacy Policy

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Introduction

At Geistlich Pharma Australia Pty Ltd (“Geistlich Australia”) your privacy is important to us.  We are committed to ensuring that personal information and credit information we hold about you is held securely and that your privacy is protected.  We collect and use personal information only to the extent permitted by law, particularly the Privacy Act 1988 (Cth) (“Privacy Act”), and the Australian Privacy Principles (as amended), which Geistlich Australia is subject to.

This policy explains how we handle personal information that we hold about you.  It details the types of personal information we collect, how we may use that information and who we allow to access it.  In addition to this policy we will on occasion provide you with specific privacy statements about how we use particular information that we collect from you.

Your use of our website(s) or our services, your purchase of our products or your continual engagement with Geistlich Australia signifies implied agreement to this Privacy Policy.  Please note that our website(s) may contain hyperlinks to third party websites that are not managed by us, and are therefore not subject to this Privacy Policy.

Personal Information

“Personal information” referred to in this Privacy Policy consists of any information or opinion that identifies you or that will enable your identity to be reasonably ascertained.  Personal Information can include your name and contact details such as your practice or postal address, email address, date of birth or your telephone number.

Information which cannot be reasonably linked to your identity (e.g. IP address, browser information, favourite websites or the number of users of a website) does not constitute personal Information and is not regulated by the Privacy Act.

Geistlich Australia collects and stores Personal Information about its customers, suppliers and medical and allied healthcare professionals.  The Personal Information collected may vary depending on your particular interaction with Geistlich Australia but will be limited to the information necessary to record and manage our interaction with you or as permitted or required by law.

The Personal Information that Geistlich Australia collects is primarily related to our products and services.  By providing your Personal Information to us and/or by continuing to engage with Geistlich Australia, you consent to your Personal Information being collected, stored, used and disclosed in accordance with this Privacy Policy.

If we provide you (or an entity related to you) with credit, we may also collect and hold credit information and credit eligibility information about you.  Without limitation, this may include credit reports, identification information, consumer credit liability information, details of amounts payable to us and the terms of the relevant credit, and information relating to payments made, default information and payment information.

Collection of information

Geistlich Australia may collect Personal Information (including credit information and credit eligibility information) about its customers, suppliers and medical and allied healthcare professionals:

  • when an order is placed for our products;
  • when a customer account is opened with us;
  • when a customer visit is undertaken;
  • in the course of responding to enquiries;
  • from adverse event reports; and
  • from Geistlich Australia-sponsored programs (e.g. trade events, conferences, retail events, membership programs, competitions or promotions, expert panels and educational seminars).

Geistlich Australia may collect personal information about prospective employees during the recruitment process to assess whether an applicant is suitable for a role with us.  If you are not ultimately successful in securing employment with Geistlich Australia, your personal information collected during the recruitment process will be handled in accordance with this Privacy Policy.

Occasionally, we may also collect personal information about you from third parties.  For example, we may collect personal information about you from an entity related to you or credit eligibility information about you from Credit Reporting Bodies (“CRBs”) if we provide you (or an entity related to you) with credit.

Personal Information may be collected from you in person, through websites operated by Geistlich Australia, by letter, facsimile, email or through telephone enquiries.

Personal Information that may be collected about you includes:

  • your name and contact details (eg. address, email, telephone number, business and professional details (if applicable) etc.);
  • the nature of your enquiry; and
  • other details about you that might be relevant.

If you contact us by telephone, this information may be collected by Geistlich Australia as a recorded voice message where our staff are temporarily unavailable to answer a call and you choose to leave a voice message.

We will only collect Personal Information that you provide us and you are entirely free to decide whether or not to supply this information.  However, you acknowledge and agree that if you do not provide sufficient or adequate information, Geistlich Australia may not be able to provide you with its full range of products and services or may not be able to fully assist you with your enquiry.

You should be aware that your use of our website(s) does not reveal your identity, unless you have chosen to register and log into our website.

Each time you visit our website, our web servers automatically save the name of your browser and operating system, your IP address, the website from which you accessed our website, the webpages you visit while with us and the date and time you spend on our website.  Geistlich Australia’s servers save this information for security purposes.  We may also evaluate anonymous or de-identified data sets for statistical purposes, for example to aggregate user activity, which may be used by Geistlich Australia to provide insight on the usage of its website.

Use of information

Geistlich Australia will use Personal Information for the primary purposes for which it is collected or for other related purposes as permitted by law including but not limited to the following purposes, where applicable:

  • to manage your product order(s);
  • if we are providing you (or an entity related to you) with credit, to assess your creditworthiness (or the creditworthiness of your related entity which is receiving the credit);
  • to maintain a record of medical enquiries, product complaints and adverse events and to comply with our reporting obligations to relevant regulatory authorities like the Therapeutic Goods Administration.  This information will also be used to monitor, assess and improve our products and services;
  • to provide further information regarding our products or services (including advice) that you have requested;
  • to provide you with material on our activities and products or that may be of interest to you, which you are entitled to opt out of receiving at any time;
  • to administer trade events, retail events, membership programs, competitions, promotions, conferences, expert panels, educational seminars, disease awareness or management programs or other programs organised or sponsored by us, which you agree to be involved with;
  • to notify you of matters that we are required by law to notify you of (e.g. product recalls);
  • to monitor and prepare reports regarding the quality, safety and efficacy of our products;
  • to review our compliance with relevant regulations and codes of conduct;
  • to obtain feedback and customer satisfaction information to assist Geistlich Australia in improving its products and service offerings;
  • for our internal management purposes, to manage our relationship with you and to manage the payment and recovery of amounts payable to us by you;
  • to statistically analyse the distribution of our products; and
  • to generate customer lists for the purposes of market research.

Depending on the purposes for which your personal information is collected, Geistlich Australia may disclose your personal information to:

  • if we are providing you (or an entity related to you) with credit, CRBs, trade insurers and businesses assisting us with providing credit;
  • if you have provided us with referees to assist with a credit application, a job application or the assessment of a potential contract between you and us, the referees you have provided;
  • service providers that provide logistic, financial, legal, administrative or other services in connection with the operation of our business;
  • our head office based in Switzerland
  • regulatory authorities, within or outside of Australia; and
  • other entities as permitted or required by law.

 

Notwithstanding the above, you acknowledge that by providing us with your personal information, you agree and consent to Geistlich Australia storing your Personal Information on storage or computer systems provided by third party suppliers.  Geistlich Australia currently uses cloud-based solutions for its information systems, which includes Personal Information potentially being stored overseas.  All reasonable steps will be taken to keep your Personal Information secure (whether in Australia or overseas).  When we engage a data storage provider, we use contractual arrangements to ensure those providers take appropriate measures to protect your Personal Information and restrict the uses to which they can put that information.  Geistlich Australia may decide to change its third party storage provider and transfer your Personal Information to the new provider at its discretion.

You acknowledge and agree that, Geistlich Australia may use or disclose your personal information:

  • for other purposes for which you have provided your prior consent; or
  • as required by or permitted under any law (including common law) or any direction of a Court or order of a Government authority or body.

Geistlich Australia will only use your information, which is not personal information (such as IP addresses), for security purposes, systems administration, to enforce compliance with Geistlich Australia’s trading terms and website usage terms to protect Geistlich Australia’s business, brands, products, services and website(s) and/or to enforce compliance with any applicable laws.

If you fail to make a payment to Geistlich Australia as and when due or commit a serious credit infringement, we may disclose details of such events to CRBs.  A CRB may use such information in reports given to other credit providers to help assess your creditworthiness.

Geistlich Australia will use de-identified information within its business where possible.  De-identified information may be used to comply with our reporting obligations under the Therapeutic Goods Act 1989 (Cth).  It may also be used to satisfy Geistlich Australia’s corporate reporting obligations, in which case the de-identified information will be sent to our related entities in Switzerland.

Cookies

Cookies are small data files which are placed on your computer by web servers when you visit certain websites.  Geistlich Australia’s website(s) use cookies to allow us to identify regular visitors and collect information about your usage of our website(s).  This enables us to provide a better and more relevant website service to you each time you revisit specific webpages.  Geistlich Australia also utilises third-party plug-ins which may create cookies that may collect information about your visit to our website.  Cookies do not collect nor store any personal information and do not personally identify users, although they do identify a user's browser.  Geistlich Australia does not have any control over, and therefore will not be responsible for, the content of the cookies created by third party plug-ins, the use made of any data collected by third party plug-ins, or the security of that data. The cookies derived from the third party plugins that we utilise do not collect any personal information.  Most browsers are set to accept cookies automatically.  However, you can turn off the ‘Save Cookies’ function or set your browser so that it informs you whenever cookies are transmitted.

Security

Your personal information and credit information are stored in secured premises or in electronic databases requiring usernames and passwords for access only by authorised staff members.  Our security precautions are regularly updated and improved in line with technical developments.  Unfortunately, no data transmission over the internet or storage facility can be guaranteed to be 100% secure.  Accordingly, Geistlich Australia cannot provide absolute assurance that the information you provide to us will be secure at all times and you agree that Geistlich Australia will not be held, and you must not hold Geistlich Australia, responsible for unauthorised access to personal information where it has taken reasonable steps to protect and secure that information.

Please note that Geistlich Australia will store your Personal Information on servers in Switzerland and other locations.  If you provide Personal Information to us, you also consent to the transfer by us of your information to those servers for processing and storage.  However, this does not change any of our commitments to safeguard your privacy to the standard required by the Privacy Act.

Access, Correction and Deletion rights

Geistlich Australia will endeavour to ensure that your personal information is accurate, up-to-date and complete.  You are entitled to request access to and correction of your personal information held by Geistlich Australia if you believe it to be out of date or incorrect.  Simply contact Geistlich Australia’s Privacy Officer as set out below (“Privacy Officer”).

Upon your reasonable request, Geistlich Australia will endeavour to provide you with access to or correct your personal information unless Geistlich Australia believes that denying access or correction is required:

  • by or permitted under any law (including common law) or any direction of a Court or order of a Government authority or body; or
  • for other legal reasons.

If Geistlich Australia refuses your request to access or correct your personal information, it will provide you with written reasons for its refusal.

If you wish to stop receiving any communications from us and have your personal information deleted, please contact Geistlich Australia’s Privacy Officer, and we will take all reasonable steps to delete it, unless we need to keep it for legal reasons.

In addition, if you have any concerns about how your personal information has been collected, used or disclosed, you can contact Geistlich Australia’s Privacy Officer and we will do our best to address your concerns to ensure that you are satisfied that there have been no breaches of privacy laws in relation to any personal information we hold about you.

Making a complaint

If you have any concerns about how your personal information has been collected, used or disclosed, and you wish to make a complaint about a possible breach of privacy laws, you can contact our Privacy Officer.

The Privacy Officer will investigate your concerns and take any necessary steps to resolve your complaint.  We may need to contact you if we need further information to investigate your complaint and will advise you of the outcome of the investigation as soon as it is completed.  We will endeavour to investigate and resolve your complaint within 30 days after receiving your complaint.

If you are not satisfied with the outcome of the investigation, you can contact us again to discuss your concerns, or you may complain to the Australian Privacy Commissioner via www.oaic.gov.au.

Hyperlinks to other Websites

Third party operators of websites which may be accessed via hyperlinks from Geistlich Australia’s website(s) may gather and store personal information as soon as you access their websites.  You acknowledge and agree that Geistlich Australia cannot accept any liability for those third party operators in the event that your Personal Information is collected, used, disclosed or shared by them.  We encourage you to read their privacy policies separately.

Amendments to Privacy Policy

Geistlich Australia reserves the right to amend this Privacy Policy at any time.  Visitors to Geistlich Australia’s website(s), healthcare practitioners and other consumers of Geistlich Australia’s products and services are responsible for carefully reading this policy on a regular basis to inform themselves of any amendments that may have been made.  You acknowledge and agree that the amended Privacy Policy will apply between all relevant parties whether or not Geistlich Australia has given you specific notice of any such change.

Questions

If you have any queries relating to our Privacy Policy, or if you have a problem or complaint that you would like to discuss with Geistlich Australia, please contact Geistlich Australia's Privacy Officer by telephoning Customer Service on 1800 776 326, emailing infogeistlich.com.au or by sending a letter to the Privacy Officer, Geistlich Pharma Australia Pty Ltd, The Zenith Tower A, Suite 1901, 821 Pacific Highway, Chatswood NSW 2067.

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