Privacy Policy
Privacy Policy

Privacy Policy

Introduction. In this privacy policy (Privacy Policy), “we”, “us” and “our” means A. Menarini Australia Pty Ltd, A. Menarini New Zealand Pty Limited and its related body corporates. Please read this Privacy Policy carefully as it describes the way in which we collect and handle your personal information.

We may revise this Privacy Policy from time to time by providing a revised version on our Website. Our revised Privacy Policy will take effect from the time it is posted on our Website.

You have no obligation to provide any Personal Information requested by us. However, if you choose to withhold your Personal Information, we may not be able to assist you with the provision of our services.

For the purposes of this Privacy Policy, the words herein will have the same meaning as in the Terms of Use, except where otherwise expressly defined.

Personal Information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable: (a) whether the information or opinion is true or not; and (b) whether the information or opinion is recorded in a material form or not.

Process“, in relation to Personal Information, means: (i) to carry out any operation or set of operations in relation to the Personal Information, and includes recording, holding, organisation, adaptation/alteration, retrieval, combination, transmission or erasure/ destruction; and (ii) copy, use, access, display, run, store review, manage, modify, transform, translate, extract components into another work, integrate or incorporate as part of a derivative work, and (iii) to permit others to do (i) and (ii). “Processing” shall have the corresponding meaning as a verb for the same.

Disclose” means to disclose, forward, communicate, transmit, transfer, export, supply, provide, show, display, exhibit, grant access to, and enable or facilitate the receipt of Personal Information. “Disclosure” shall have the corresponding meaning as a noun for the same.

 

Consent: Without limitation, by using or accessing this Web site, you agree to be bound by our Privacy Policy and Terms of Use. In addition, whenever you submit Personal Information via this Web site or otherwise to us for any reason whatsoever (including without limitation the submission of (i) testimonials in relation to our goods and/or services, (ii) any information in relation to a job application at Menarini, or (iii) a query in relation to any of Menarini’s products), you consent to our collection, use, Processing and Disclosure of that Personal Information by us in accordance with this Privacy Policy.

The types of Personal Information we collect and hold. Menarini understands the importance of protecting your Personal Information. The types of Personal Information we may collect includes your name, age, email address and phone number. If you apply for a job with us, we may also collect information about you, such as your employment history and qualifications from third parties, including referees, and as part of our background checks. We may also collect sensitive information including health information but only in circumstances where you freely disclose such information to us in the course of our communications or through our surveys, questionnaires, feedback forms or the provision of testimonials or where otherwise permitted or required by law. By providing any sensitive information, you consent to our collection of that sensitive information . If you wish to withdraw such consent please contact our Data Protection Officer and cease to use our Web site.

How we collect Personal Information. We collect Personal Information from or about you through specific questions or allowing you to communicate directly with us via phone, in person, company websites, e-mail, surveys, questionnaires, feedback forms or the provision of testimonials. We may also collect Personal Information about you from a health care professional you have seen in relation to your use of our products.

We collect information about your visits to our Web site for system management, to improve the Content of the Web site, and for market research purposes. The information we collect may include your Personal Information. We collect this information when you access and navigate throughout our Web site including statistical data such as the date, time and specific page you visit using a range of technological means such as cookies, tags, web beacons and other navigational data collection tools.

Navigation Data. The Website uses cookies, tags and web beacons. Cookies are small text files that this Web site sends to your computer’s hard drive to identify the computer you are using. Tags are smaller than cookies and tell the Web site server information such as the Internet Protocol address and the browser types related to your computer. Web beacons are usually invisible to the user but are embedded in a web page or email that tracks whether a user has viewed a web page or email. Other navigational data collection tools are used for system management to improve the Content of the Website and for market research purposes.

By browsing the Website, you consent to the use of Cookies, Tags and Web beacons (and any Personal Information contained in or associated with the same) for the purposes specified in this Privacy Policy.

Most web browsers are automatically set to accept cookies. If you do not wish to receive any cookies on our Web site, you may set your browser to refuse cookies. However, this may affect the functionality of our Website.

Why we collect, hold and use your Personal Information. We generally collect, use, Disclose and Process your Personal information for the following purposes:

  1. a) to provide you with information about our company’s products and/or services and various medical conditions upon your request;
  2. b) to maintain a record of medical enquiries, complaints and adverse event reports relating to our products and to report these to regulatory authorities if required;
  3. c) to inform you of upcoming educational events, including patient education programs and for administering conferences, symposia, meetings  and educational events organised by us, which you agree to be involved in;
  4. d) purposes in relation to data analytics and research activities and, where you consent, marketing of our products and/or services.
  5. e) to process your job application (and, if you are successful, manage your employment); and
  6. f) as otherwise permitted or authorised by law, which includes other purposes related to the purposes above.

How we disclose your Personal Information. We may Disclose your Personal Information for a variety of purposes in connection with our business operations. These include:

  1. a) to a related body corporate or other third party:

(i) for the rendering of services or conduct of legitimate business activity by us or our group members;

(ii) to respond to your requests for customer services or products;

(iii) for the purpose of sending direct marketing materials where you have provided consent; and/or

(iv) to protect and enforce our rights, property or personal safety to the extent permitted or not prohibited by applicable law or;

(v) as otherwise permitted or authorised under applicable law;

  1. b) to any competent legal and/or regulatory authority and law enforcement agencies:

(i) in compliance with legal process, order of court and applicable law; and/or

(ii) to enforce our rights arising out of or in connection with the Terms of Use, Privacy Policy and any other contracts with you.

  1. c) to our successors-in-title, sellers or buyers (or prospective sellers or buyers) of any part or the whole of our business, in connection with a proposed merger, acquisition or sale of any part or the whole of our business.

Note: Transfer of Personal Information may include transfers to territories where our networks or third party hosting providers’ networks are located. We will comply will applicable law when transferring Personal Information.

Overseas disclosure of Personal Information. From time to time, we may Disclose Personal Information to persons located outside Australia for the purposes described above. While it is not practicable to list all such locations, they may include China, Hong Kong, India, Indonesia, Italy, South Korea, Malaysia, New Zealand, Philippines, Singapore, Taiwan, Thailand and Vietnam.

You consent to the offshore disclosures contemplated by this privacy policy, and you understand that we may not be able to, and are not required to, take steps to ensure the offshore recipients comply with Australian or New Zealand privacy law or otherwise protect your personal information in the same way Menarini does, and that you may not be able to seek any redress under Australian or New Zealand privacy law for any mishandling of your personal information by recipients located outside of Australia.

Storage and Protection of Personal Information: We will take such steps as reasonable in the circumstances to ensure that Personal Information we collect, use and disclose is accurate, complete, up-to-date and relevant. We will take all reasonable steps to protect Personal Information in our possession or control by making reasonable security arrangements designed to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Notwithstanding the foregoing, please be aware that the Internet is not a completely secure or error-free environment. We cannot fully guarantee:

  1. a) the confidentiality of any Personal Information you submit to us over the Internet;
  2. b) that unauthorized persons will not view your Personal Information or emails; or
  3. c) that your Personal Information will not be altered, corrupted or destroyed by third party circumvention of our reasonable security measures that have been in place to safeguard your Personal Information.

We urge you to minimize security risks by regularly updating your antivirus software.

Access to Personal Information. You are entitled to request for us to provide you with access to your Personal Information held by us.. Menarini fulfil such requests as required by applicable law.

Please provide us with as much detail as you can about the particular information you wish to access in order to help us retrieve it. We may charge you an access fee to cover our costs of providing that information to you. We will inform you of applicable fees before they are incurred.

Any request for access to Personal Information pursuant to this clause shall be made in writing to our Data Protection Officer at the contact details set out below. We will respond to your request for access to Personal Information as required by applicable law.

In certain circumstances, such as where provision of the Personal Information may pose a serious threat to safety of an individual, we may refuse your request to access your Personal Information. If we refuse you access, we will provide you with reasons for our refusal to the extent permitted by law.

Update and Correction of Personal Information. You are entitled to request that we update your Personal Information or to correct an error or omission in your Personal Information that we hold. Unless we are satisfied  that a correction should not be made or not making a correction is otherwise permitted by law, we will take such steps to make such correction as required by applicable law to ensure the information is accurate, up to date, complete, relevant and not misleading.

Any request for update or correction of Personal Information pursuant to this clause shall be made in writing to our Data Protection Officer at the contact details set out below.

If we refuse to correct the Personal Information as requested by you, we will provide you with a written notice setting out our reasons for refusal to the extent permitted by law) and the mechanisms available to you to lodge a complaint.

Retention of Personal Information. We may need to retain such records containing your Personal Information as may be necessary or desirable to comply with applicable law or regulation, and to retain such information as long as the purposes for which the Personal Information was collected are still being served or retention is necessary for Menarini’s legal or business purposes, including to address disputes or establish our rights (whether such disputes or matters have arisen, or could arise in the future). Where we no longer need your Personal Information for any purpose for which the information may be used or disclosed, we will take reasonable steps to destroy or de-identify the information.

Withdrawal of Consent. Your use of any part of this Website indicates your acceptance of this Privacy Policy and your consent to the collection, use, Processing and Disclosure of your Personal Information in accordance with this Privacy Policy.  If you would like to withdraw your consent given for collection, use, and disclosure of your Personal Information for the purposes set out in this Privacy Policy, please immediately refrain from and cease all usage of this Website and provide us with reasonable notice of your withdrawal of consent in writing to our Data Protection Officer at the contact details set out below. On receipt of your written notice, we will cease the collection, use, Processing and Disclosure of your Personal Information within a reasonable time unless continued use, Processing or Disclosure is otherwise allowed by any applicable law or regulation. Please note that the likely consequence of the withdrawal of consent will be that you will not be able to access or use this Website.

Third Party Websites. This Website may contain links or references to other web sites which are maintained by third parties over whom we have no control. This Privacy Policy does not apply to third party web sites. You should refer to the privacy policies of the relevant third party websites to learn more about how their personal information are processed (including by the use of cookies, web beacons and tags).

Anonymous and pseudonyms. You may request to remain anonymous, or seek to use a pseudonym, in your dealings with us on the Web site. We will honour your request to stay anonymous or use a pseudonym where it is lawful and practicable to do so.

Complaints. If you would like to make a complaint about the way in which we handled your Personal Information, please write to our Data Protection Officer whose contact details are below. We aim to investigate and respond complaints within a reasonable time after receipt.

If you are dissatisfied with our response to your complaint, you may contact:

  1. in Australia, the Office of the Australian Information Commissioner (OAIC) or contact the OAIC by phone on 1300 363 992, or
  2. in New Zealand, the Office of the Privacy Commissioner through its website: https://www.privacy.org.nz/, or by phone on 0800 803 909

Contact. If you have any questions or recommendations about this Privacy Policy, or any queries about the collection, use, Processing and Disclosure of your Personal Information pursuant to this Privacy Policy or if you wish to access or update your Personal Information we hold about you or if you wish to make a complaint, you may contact us at the following details:

Email toPrivacy.officer@menariniapac.com

Write to: Data Protection Officer
A. Menarini Australia Pty Ltd
Level 8, 67 Albert Avenue
Chatswood, NSW 2067
Australia

© 2018 A. Menarini Australia Pty Ltd. All rights reserved.
Last updated in December 2020