Personal information is any information or an opinion about an identified individual or an individual who is reasonably identifiable.
You may elect not to submit personal information to us, but this may mean that we are unable to provide you or your medical practitioner, your dispensing pharmacist or the manufacturer sponsoring the Program, with any required information, products or services.
Collection and use of submitted information
We may collect and retain personal and other information about you in various ways (“submitted information”) including when (a) you provide us with personal information in an email, letter, by telephone, during a meeting or by other means; (b) a third party acting on your behalf (such as your doctor) completes and submits an online registration, application or any other online form; (c) you access and use our services through the Sites or otherwise; (d) a third party submits information about you to us: or (e) information is submitted to our computer systems automatically by the computer system(s) operated by or on behalf of a third party.
We will only collect information by lawful and fair means.
If we receive unsolicited personal information that could have been lawfully collected by us as solicited information, we will treat that submitted information in the same way as we treat solicited information. If we receive unsolicited personal information that could not have been lawfully collected by us as solicited information, we will destroy or de-identify that information when such event comes to our attention and as soon as practicable.
The submitted information which we retain may include your name, address, email address, phone number(s), medical and other personal information including sensitive personal information and other information where it is reasonably necessary for our functions or activities.
We may use the submitted information for our normal internal business purposes and to effectively manage and administer the operation of our portal and the provision of associated services.
We may use a third party to provide hosting or other services and as a result your submitted information may be collected and stored using physical infrastructure and software owned or licensed by third parties. In these circumstances (a) we will retain logical control of the submitted information; (b) the third party will not be permitted to access, use or disclose the submitted information except to the limited extent necessary to provide the services (e.g. creating data back-ups or performing maintenance services) or (c) if disclosure is required by a governmental entity. You consent to this limited collection and use of the submitted information by third party hosting and service providers.
We may disclose submitted information to other service providers who assist us in operating our business. Our service providers are subject to strict privacy. You also consent to our disclosure of submitted information to:
- regulatory authorities;
- your medical practitioner or nominated dispenser;
- other service providers that provide services to us;
- parties to transactions facilitated or executed by us to which you are a party;
- those involved with providing, managing or administering our supply of services;
- those required by law;
- those you have consented to our disclosing information about you.
Any Adverse Events (AEs) or events of special interest shall be forwarded to the relevant manufacturer within one (1) business day from receiving information, by sending the collected information (subject to Data Privacy in local countries) to the designated manufacturer email address.
We will not make any overseas disclosure of your submitted information except where this may be necessary in connection with specific transactions involving you.
We may use your submitted information to communicate with you for any reasonable purpose connected with the operation of the portal or our business. You may elect not to receive such communications from us, either at the time you submit the information or at a later time. If you elect to opt out of any direct marketing, we will comply with that election.
We will not sell submitted information to third parties or intentionally disclose submitted information to third parties except to the extent that you have consented to such disclosure.
Except to the extent necessary for the operation of the portal or our business or as authorised by you or as required by law, we will not use or disclose submitted information for any other purpose.
The restrictions on our use and disclosure of submitted information do not apply if we de-identify the submitted information (i.e. remove the information that allows any person to be identified).
If you do not wish to provide your name, you may use a pseudonym, however you must use the same pseudonym whenever you engage with the Program. It is a requirement that you (or the person submitting information on your behalf) accurately complete any data fields that require insertion of your personal details. If you do not wish to provide any required personal information, then you should not proceed or authorise your medical practitioner to proceed with the completion of the relevant process.
We will take reasonable steps to implement and maintain security precautions and to protect personal information from misuse, interference, loss and unauthorised access, modification and disclosure. However, we are unable to guarantee that unauthorised access to submitted information will not occur, either during transmission of that information or after we receive that information.
If you have been issued with a password to allow access to our Sites, you must keep that password secure and not allow it to be shared with unauthorised persons. Failure to comply may endanger your submitted information.
If we no longer require your personal information, we will take reasonable steps to permanently destroy or de-identify that information. You acknowledge that our back-up procedures may make it impractical to locate and destroy or de-identify copies of your personal information which are stored off-line or in a form which does not readily permit location and modification of data and you consent to our continued retention of submitted information in these circumstances.
If you submit information to any other site accessed through a link from our Sites, the privacy principles applying to any information you submit to that site are outside our control. You should check the privacy policies of any other site before submitting information to that site.
If we or any authority suspect that unauthorised access or use of the Sites has occurred or may occur or be attempted, we may gather, use and disclose more extensive information than indicated above regarding access or attempted access to the Sites for the purposes of prevention, detection, investigation or prosecution.
Collection and use of clickstream data and cookies
Correction of errors and access to personal information
We will take reasonable measures to ensure all personal information held about you is accurate, complete, relevant and up-to-date.
We will provide you with access to your personal information on reasonable request and subject to your agreement to pay our access charges and adequate proof of your identity if (a) it is practicable for us to do so and we have no other reasonable grounds for refusing access, (b) the request is not frivolous or vexatious, (c) access will not have an unreasonable impact on the privacy of others, (d) the information does not relate to existing or anticipated legal proceedings (other than information accessible through the discovery process), (e) access will not reveal our intentions in relation to any negotiations with you, (f) access is not unlawful (g) denying access is not required or authorised by law, and (h) access will not prejudice any prevention, detection, investigation or prosecution of possible unlawful or improper activity.
You have the right to require us to correct errors in your personal information.
We will correct any errors in your personal information upon receipt of written evidence from you which satisfies us that a correction is required.
Privacy related complaints, concerns and questions
Version June 2020