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.
“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.
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.
Why we collect, hold and use your Personal Information. We generally collect, use, Disclose and Process your Personal information for the following purposes:
- a) to provide you with information about our company’s products and/or services and various medical conditions upon your request;
- 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;
- 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;
- d) purposes in relation to data analytics and research activities and, where you consent, marketing of our products and/or services.
- e) to process your job application (and, if you are successful, manage your employment); and
- 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:
- 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;
- 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
- 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.
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:
- a) the confidentiality of any Personal Information you submit to us over the Internet;
- b) that unauthorized persons will not view your Personal Information or emails; or
- 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.
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:
- in Australia, the Office of the Australian Information Commissioner (OAIC) through its website: https://www.oaic.gov.au/ or phone on 1300 363 992
Email to: Privacy.firstname.lastname@example.org
Write to: Data Protection Officer
A. Menarini Australia Pty Ltd
Level 8, 67 Albert Avenue
Chatswood, NSW 2067
© 2018 A. Menarini Australia Pty Ltd. All rights reserved.
Last updated in December 2020