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 and credit eligibility information (together, “Credit Related Information”) we hold about you is held securely and that your privacy is protected.  We collect and use Personal Information and Credit Related Information only to the extent permitted by law, particularly the Privacy Act 1988 (Cth) (“Privacy Act”), and the Australian Privacy Principles (as updated and amended from time to time), to which Geistlich Australia is subject.

This policy explains how we handle Personal Information and Credit Related Information that we hold about you. It details the types of Personal Information and Credit Related Information we collect and hold, how we may use that information, who we allow to access it, the choices you have regarding our use of that information, your ability to access or correct that information and how you may complain should you believe we have breached our privacy obligations. 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. If you do not wish to provide Personal Information to us, then you do not have to do so. However, it may affect our ability to provide services to you. 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, whether true or not, and whether recorded in a material form or not, that identifies you or that will enable your identity to be reasonably ascertained from the information or opinion. Personal Information can include your name and contact details such as your practice or postal address, email address, date of birth, and/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 related information about you. Without limitation, this may include:

• credit reports;
• identification information including your current and prior names and addresses, any known aliases you may have, your date of birth and your driver’s licence number;
• details of amounts payable to us and the terms of the relevant credit;
• information relating to payments made, default information and payment information;
• certain publicly available information;
• certain administrative information, such as account numbers.

Collection of information

Generally, when providing services to our customers or obtaining goods and services from our suppliers or contractors, we collect Personal Information directly from the individuals where reasonable and practicable.

Geistlich Australia may collect Personal Information (including Credit Related 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 CRBs if we provide you (or an entity related to you) with credit.

We will only collect your Personal Information from third parties if it is unreasonable or impracticable to collect the necessary information directly from you or if we are otherwise permitted to do so.

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, but is not limited to:

• your name and contact details (e.g. address, email address, telephone number, business and professional details (if applicable), etc.);
• the nature of your enquiry;
• information about your use of our products or services;
• payment information, including bank account details and credit card details;
• information about your use of our website; 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 or that we are otherwise authorised to collect 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 web 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.

Sensitive Information

The Privacy Act describes ‘sensitive information’ as information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual orientation, criminal record and health information about an individual.

We do not collect sensitive information about you.

Use of information

Geistlich Australia will use Personal Information and Credit Related 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);
• collecting payments and other enforcement activities;
• to participate in the credit reporting system and provide information to a CRB as permitted by Part IIIA of the Privacy Act and the Credit Reporting Code;
• to derive scores or ratings summarising your credit risk, which we may use as a factor in determining whether you are eligible for any credit product that we offer;
• 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.

Disclosure of Information

We may disclose your Personal Information to our related entities, to other parties where it is necessary to enable us to provide a product or service, to other third parties or where otherwise permitted by law. We may disclose your Personal Information to such entities for the purposes set out above.

Depending on the purposes for which your Personal Information and Credit Related Information is collected, Geistlich Australia may disclose your Personal Information and Credit 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;
• third parties that perform credit processing functions, management and debt collection activities on our behalf and organisations involved in debt assignment; and
• other entities as permitted or required by law.

In the case of contracted service providers, we may disclose Personal Information to the contracted service provider and the contracted service provider may in turn provide us with Personal Information collected from you in the course of providing the relevant products or services.

Organisations providing professional services to us are required to keep those dealings and Personal Information provided by us as confidential unless required to disclose such information by statute or law.

We use the credit reporting services provided by:

• Equifax Australia Information Services and Solutions Pty Ltd,
• Experian Australia Credit Services Pty Ltd,
• illion Australia Pty Ltd

and may both receive and disclose Credit Related Information to those entities in accordance with the Privacy Act.

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, including in Switzerland. All reasonable steps will be taken to keep your Personal Information secure (whether in Australia or overseas). 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.

Retention

We will take reasonable steps to destroy or permanently de-identify Personal Information that is no longer needed for any purpose that is permitted by the Privacy Act.

Government Related Identifiers

We will not use government related identifiers (such as driver’s licence numbers) as our own identifier of individuals. We will only use or disclose such identifiers in the circumstances permitted by the Privacy Act.

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 plug-ins 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

We take reasonable steps to protect the security of your Personal Information by storing it in a manner that protects it from misuse, loss, interference and from unauthorised access, modification or disclosure. Your Personal Information and Credit Related 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 may request details of Personal Information that we hold about you, in certain circumstances, as set out in the Privacy Act.

You are entitled to request correction of your Personal Information, held by Geistlich Australia, if you believe it to be inaccurate, incomplete, irrelevant, misleading, 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 promptly 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 and the mechanisms available to complain about that refusal.

If we cannot take reasonable steps to correct the information because such correction is not technically possible or would be impracticable for us to perform, we may be unable to continue to provide services to you. In these cases, we will provide reasons for denial of your correction request.

If we refuse to correct your Personal Information you have the right to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will take such steps that are reasonable in the circumstances to associate that statement with all records containing the relevant information.

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 setting out details of the breach.

The Privacy Officer will promptly 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 in writing of the outcome of the investigation as soon as it is completed, including what steps we propose to take to remedy the breach and any other action we will take to deal with your complaint. We will endeavour to investigate and resolve your complaint within 30 days after receiving your complaint.

If you feel that we have not satisfactorily addressed your complaint, you may contact us again to discuss your concerns or make a complaint to the Office of the Australian Information Commissioner by visiting www.oaic.gov.au, emailing enquiries@oaic.gov.au or writing to GPO Box 5218 Sydney NSW 2001.

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/s.

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 info@geistlich.com.au  or by sending a letter addressed to the Privacy Officer at Geistlich Pharma Australia, The Zenith Tower A, Level 21, 821 Pacific Highway, New South Wales 2067, Australia.

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