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Privacy Policy

STADA Pharmaceuticals Australia Pty Limited (ACN 154 966 944)

 

At STADA Pharmaceuticals Australia Pty Limited (ACN 154 966 944) (“STADA”, “us”, “we”, “our”), we understand that privacy and the security of your personal information is important to you. We are committed to protecting and treating your personal information with care and integrity.

This privacy policy ("Policy") outlines how we manage your personal information and protect your privacy. We are bound by the Australian Privacy Principles contained in the Australian Privacy Act 1988 (Cth) and the New Zealand Privacy Principles contained in the Privacy Act 2020 (NZ) (“the Principles”) and ("the Privacy Acts") as applicable. In New Zealand, to the extent that personal information is health information, STADA is also bound by the New Zealand Health Information Privacy Code 1994 ("Health Code").

By providing us with your personal information, you consent to our collection, use and disclosure of your personal information in accordance with this Policy and any other arrangements that apply between us. From time to time it may be necessary for STADA to review and revise this Policy. STADA encourages you to periodically check our website to ensure you are aware of the most up-to-date version of this Policy.

Personal information includes information or an opinion about an identified individual or an individual who is reasonably identifiable (such as names or email addresses). Within this Policy unless indicated otherwise, references to personal information also include sensitive information, such as information or an opinion about your health, or health services provided to you.

What personal information does STADA collect?

We only collect personal information for purposes which are directly related to our services, functions or activities and only when necessary for, or directly related to those purposes. If you do not provide your personal information, we may not be able to provide some or all of our services or products to you or contact you in order to perform the functions and activities set out in this Policy.

Who does STADA collect personal information about?

STADA generally collects personal information about the following individuals:

  • healthcare professionals (including doctors, pharmacists, nurses);

  • members of the public (in their interactions with STADA);

  • third parties who provide a service to STADA; and

  • prospective employees and contractors.

Types of personal information collected

The personal information STADA collects about you may include:

ID information:

  • identifying information such as your name, age or date of birth and gender;

  • contact information such as your address, employment details, email address and mobile phone number; and

  • educational and professional membership information;

  • financial information such as bank account details, if required for payments;

  • information provided in connection with assessing, recording and reporting adverse events related to our products.

 

Information required by law:

  • if you are a healthcare professional, information necessary to provide product recalls and product safety notifications; and

  • information required to be collected by Australian Federal, State and Territory law, including in relation to adverse event reports and safety issues under the Therapeutic Goods Act 1989 (Cth), and records of sample medicines provided to healthcare professionals under the Medicines Australia Code of Conduct or the Medicines New Zealand Code of Practice.

 

Enquiry or attendance information:

  • if you are a healthcare professional, information about your attendance at programs organised or supported by STADA (including meetings, conferences, expert panels, clinical trials and research or disease awareness programs) (STADA Programs);

  • information about your attendance at educational or disease awareness events;

  • if you are a healthcare professional, your interactions with sales representatives;

  • information you provide through surveys or that you provide to us directly or indirectly through the website or to our representatives;

  • details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those services and respond to your enquiries; and

  • details in relation to complaints that you have made; and

  • any other personal information that may be required in order to facilitate your interaction with us.

 

Anonymity

Where possible, we will allow you to interact with us anonymously (for example, when you contact our enquiries line with a general question). However, for the majority of our functions, we usually require your name and contact information and enough information to allow us to efficiently handle our interaction with you.

How does STADA collect personal information?

We may collect these types of personal information either directly from you, if you are a patient from your healthcare professional, or from third parties. We may collect this information:

  • directly from you, including when:

    • you communicate with us over the telephone, in person, through a form or online portal or by email;

    • you make an inquiry, complaint or report an actual or suspected adverse event or you attend a STADA Program;

    • you use our information services, such as the Medical Information phone line;

  • from organisations engaged by STADA to carry out functions on our behalf including:

    • administrators of patient support or supply programs;

    • event management organisations, in respect of STADA Programs; and

    • recruitment agencies, in respect of prospective employees;

  • in respect of patients (including information in connection with actual or suspected adverse events), from your healthcare professionals; and in respect of healthcare professionals, from online directories which we subscribe to.

 

Why does STADA collect, hold, use and disclose personal information?

We may collect, hold, use and disclose your personal information for the following purposes:

  • as indicated to you at the time we collected your personal information;

  • to provide educational or health products or services (including advice or product medical information) that you or your healthcare professional have requested;

  • to assess, record and report actual or suspected adverse events and safety issues, including (if applicable) to seek additional information in connection with such adverse events or safety issues.

 

Patient Programs

  • to manage patient support programs and patient supply programs that are administered via third parties or STADA; and

  • to identify investigators for, establish and conduct clinical trials (including clinical trials run by a related body corporate of STADA).

 

STADA Programs

  • to provide and invite you to attend educational events and conferences and disease management programs, including any associated logistics; and

  • to invite you to provide services to STADA, including speaking engagements, participation on advisory boards/steering committees, or to provide general opinions on medical and/or patient related issues and the development of materials.

 

General business

  • to maintain a record of enquiries and complaints in relation to STADA products and services;

  • to assist us in responding to, and following up on, your queries and providing you with information, including where you provide us with personal or sensitive information through our Medical Information line;

  • for general sales, marketing and medical activities, including to contact you to provide you with information about, and discuss, STADA products (in accordance with the Marketing section below);

  • to conduct market research;

  • to process, monitor and screen any fees payable, or expenses reimbursable, by STADA to you; and

  • to consider employment applications and recruit STADA personnel; and as required or authorised by law

  • to comply with legal or regulatory obligations or transparency requirements including those that apply to STADA's activities globally; and

  • for other purposes required or authorised by or under law, including purposes for which you have provided your express or implied consent.

 

We may use or disclose information about you in order to combine the information that we hold about you with information about you collected from or held by other trusted partners or from public sources. We do this so that we can serve you better and can improve our services.

We may use de-identified, aggregated data derived from your personal information for internal purposes, such as improving the functionality of our website or services. We may also use such de-identified, aggregated information for analytical purposes, such as to develop analytical insights about the use our website and services (including monitoring website traffic) and participation in patient programs administered by us or third parties.

To whom does STADA disclose your personal information?

STADA may disclose your personal information to third parties, including parties which are located overseas, such as:

  • our affiliates and related bodies corporate, including those located overseas in the US, European Union and Asia Pacific (a full list of countries in which STADA has related bodies corporate can be found here;

  • regulatory authorities and ethics committees as part of a clinical trial evaluation, monitoring or inspection process, including the Therapeutic Goods Administration in Australia and the Food & Drug Administration in the US;

  • third party suppliers and service providers to assist STADA in carrying out the purposes set out in this Policy located globally including in the US, European Union and Asia Pacific such as healthcare professionals, clinical research organisations, patient support program administrators, our finance processing provider, travel agents, market researchers, professional conference or event management organisations, IT support providers, mail houses, recruitment agencies and professional advisors;

  • our IT servers, databases and cloud-based data centres, which are located globally including in United States of America, United Kingdom, the European Union & Israel;

  • parties involved in a prospective or actual transfer of our assets or business; and other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

 

We will take reasonable steps to ensure that any overseas recipient will deal with your personal information in a way that is consistent with the Principles and this Policy. Generally, we require that organisations outside STADA who handle or obtain personal information as service providers to:

STADA acknowledge the confidentiality of this information, undertake to respect an individual’s right to privacy and comply with STADA’s global commitment to privacy.

The collection and use of your information by these third parties may also be subject to separate privacy and security policies.

Marketing

STADA may use your personal information to contact you (including by telephone, text message or email) in relation to STADA products or services we think may be of interest to you. STADA will not send you a commercial electronic message unless permitted by the Spam Act 2003 (Cth) or the Unsolicited Electronic Messages Act 2007 (NZ).

We will only use or disclose your sensitive information for the purpose of direct marketing with your consent.

You may opt-out of receiving marketing information from STADA at any time by contacting the Privacy Officer using the details below or by using the opt-out facilities provided within the relevant marketing material.

Sensitive information

As mentioned previously, some personal information, which includes all health information collected by STADA is considered “sensitive”. Due to the nature of our business, we may sometimes need to collect sensitive information about you. 

We will collect your sensitive information in accordance with the Principles and only where provided by you or your healthcare professional, with your consent and where necessary for or directly related to our services (including support services), functions or activities, such as:

  • information about your health, including your health status or medical conditions, when you call our Medical Information line;

  • information about your health, genetic or biometric information, health services being provided to you or your medical history, if we are providing you with a product or you are involved in a patient program;

  • information about your health, including previous medical and medication history, and side effects, if you have, or are suspected to have, suffered an adverse event in relation to one of our products; or

  • information about your professional association memberships, if such information is required for our dealings with you.

 

We only use and disclose sensitive information for the purposes for which it was provided, or a directly related purpose you would reasonably expect (such as following up in relation to Medical Information line queries or adverse event reports), unless you provide your consent or where required or authorised by or under law such as if the use or disclosure of sensitive information is required to prevent a serious and imminent threat to the life or health of an individual.

Cookies

STADA may collect personal information about you when you use or access our website, through the use of 'cookies'. A cookie is a small file that stores information on your computer, mobile phone or other device. Cookies help provide additional functionality to the web site or to help us analyse site usage more accurately. We use information collected from cookies to better understand, customise and improve user experience with our websites, services and offerings, as well as to manage our advertising. For instance, our server may set a cookie that keeps you from having to enter a password more than once during a visit to one of our sites. Also, we may use web analytics services that leverage cookies to help us to understand how visitors engage with and navigate our site (e.g. how and when pages in a site are visited and by how many visitors).

 

We are also able to offer our visitors a more customised, relevant experience on our sites using cookies by delivering content and functionality based on your preferences and interests. If you have provided us with personal information (e.g. through a registration or a request for certain materials), we may associate this personal information with information gathered through cookies. This allows us to offer increased personalisation and functionality.

 

In all cases in which cookies are used, the cookie will not collect personal information except with your explicit permission. Your web browser can be set to allow you to control whether you will accept cookies, reject cookies or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognise you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies.

 

In addition to STADA cookies, certain third parties may deliver cookies to your computer for a variety of reasons. For example, we sometimes use various web analytics tools that help us understand how visitors engage with our websites. Any third party links or advertising on our site may also use cookies; you may receive these cookies by clicking on the link to the third party site or advertising. We do not control the collection or use of information by these third parties, and these third party cookies are not subject to this Policy. You should contact these companies directly if you have any questions about their collection and/or use of information.

 

In addition, we may use other tracking systems like pixel-tags. Pixel tags, sometimes called web beacons, are similar in function to cookies but because of their insignificant size, they are not visible. However, they are used to pass certain information to our servers to personalize our websites and to track your usage across other STADA websites. In addition, we may also use pixel tags in our HTML based emails.

 

For more information about cookies and how we use cookies, please refer to our Cookie Declaration page

Management and security of personal information

STADA stores your personal information in hard copy documents or as electronic data in our software IT systems (and those of our service providers). As mentioned above, our IT servers, databases and cloud based data centres are located globally.

STADA is committed to keeping your personal and sensitive information secure and has appointed a Privacy Officer to oversee STADA's management of personal information in accordance with this Policy and the respective Privacy Acts.

We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, STADA has directed its staff that personal information must be dealt with in accordance with this Policy and kept secure (using a variety of security technologies and procedures) from unauthorised access or disclosure.

We take steps to destroy or de-identify information that we no longer require.

Does STADA disclose your personal information overseas?

STADA is a global organisation and works with clients, service providers, sponsors and commercial interests across the globe. It is likely that your personal information will be disclosed to overseas recipients.

Unless we have your consent, or an exception under the Australian Privacy Principles applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information.

Entities which are related entities of STADA or are otherwise affiliated with STADA, have operations in

[insert countries or weblink where they can be found]. In circumstances where your information is disclosed to overseas recipients, those recipients are likely to be located in countries in the regions in which STADA and its related entities and affiliates operate.

How can you access or seek correction of your personal information?

You are entitled to access your personal information held by STADA on request. To request access to your personal information please contact our privacy officer using the contact details set out below.

You will not be charged for making a request to access your personal information but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.

We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.

However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.

We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

What should you do if you have a complaint about the handling of your personal information?

You may contact STADA at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.

You may make a complaint about privacy to the privacy officer at the contact details set out below.

The privacy officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.

If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.

If you are not satisfied with our response to your complaint, or you consider that STADA may have breached the Australian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.

In New Zealand you may contact the New Zealand Privacy Commissioner who may investigate your complaint further. Further information about the application of the New Zealand Privacy Act can be found at www.privacy.org.nz.

Your rights under the EU GDPR

Under the European Union (EU) General Data Protection Regulation (“GDPR”), as a data subject you have the right to:

(a) access your data;

(b) have your data deleted or corrected where it is inaccurate;

(c) object to your data being processed and to restrict processing;

(d) withdraw consent to having your data processed;

(e) have your data provided in a standard format so that it can be transferred elsewhere; and

(f) not be subject to a decision based solely on automated processing.

 

(“Data Subject Rights”)

We have processes in place to deal with Data Subject Rights requests. Our actions and responsibilities will depend on whether we are the controller or processer of the personal data at issue. Depending on our role as either a controller or processor, the process for enabling Data Subject Rights may differ, and are always subject to applicable law. Please refer to the Contact Details section of this policy if you would like to make a Data Subject Rights request.

How to contact us

If you have questions about our Policy or privacy practices, wish to provide feedback about this Policy or would like to access or correct your personal information held by STADA, please contact our Privacy Officer at:

Email: info@STADA.com.au

Phone: +61 2 9452 6656

Postal address: The Privacy Officer

STADA Pharmaceutical Australia Pty Ltd, Suite 204,

26 Rodborough Road, Frenchs Forest NSW 2086

Australia

How changes are made to this Privacy Policy?

STADA may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes.

 

This Privacy Policy was last updated in May 2022.

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