MEDISON (AUSTRALIAN) PRIVACY POLICY

Medison Pharma Australia Pty Limited (“Medison”, “we”, “us”, “our”) is committed to maintaining the privacy of individuals whose Personal Information we collect, process, use, disclose and store.

This privacy policy (“Privacy Policy”) governs how Medison is committed to maintaining the privacy of individuals whose Personal Information is provided to (or accessed) by us or collected by us.

Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to your Personal Information. “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being and includes any information deemed as Personally Identifiable Information or otherwise defined as “Personal Information” by the Australian Privacy Principals and the Privacy Act 1988 (Cth) (Privacy Act).

What we cover in this Privacy Policy

When and how we collect and process your Personal Information
What Personal Information we collect, why we collect it and how it is used
Disclosure of Personal Information
Transfers of Personal Information
Your rights
Links to other websites
Analytic tools
Data security
Data retention
Privacy of Children
Questions regarding our Privacy Policy
Revisions and modifications to our Privacy Policy

When and how we collect and processes your Personal Information

When you interact or communicate with us directly or via our online and digital platforms, or when your information is publicly available, (for example on a public website or publication), we collect, store and process your Personal Information (as provided by you, or that is provided to us on your behalf, or is available publicly), in order to process and respond to your query to provide and manage our products and services. We also collect, store and process your Personal Information to generate internal databases relating to our external business stakeholders to inform, gain insights, improve and manage our business processes and outreach.

Examples of when and how your Personal Information may be collected, stored and processed by us include:

When you send any enquiry or communication to us regarding our products or services or when you conduct business with us (or use our products and services). Communication of information may occur via phone, verbal discussion, paper or digital notes or transcriptions, presentation, dedicated email boxes, post mail, online forms, including any information you may share with us via our contractors and business partners;
When you register to attend an event, complete or sign an attendance sheet at one of our (or third party) events or where we sponsor you to attend an event;
When we enter into a contract with you (including collection of your or where relevant, your employees personal information);
When you complete a paper consent form, or provide verbal consent for us to collect your Personal Information, this will be entered into a document or a digital and online system;
When you browse, make use of, or interact with our website https://www.medisonpharma.com.au/ or other communication or project platforms owned or operated by Medison (for example Contact Us form and HCP Portal);
When you contact us (or other third party as the case may be) for reporting of a safety issue, an adverse event or product complaint;
When we process your job application (including where your personal information has been provided to us by a recruiter or third party supporting in the recruitment process).
In certain circumstances, including with your consent, we may also collect your Personal Information from you or your medical centres or healthcare provider in connection with our products and services (for example for processing, managing and monitoring various medicine access programs or patient support programs).

What Personal Information we collect, why we collect it and how it is used

When you or your healthcare provider provide a request for participating in our medical programs or receiving any of our products or services.

We may collect personal information from you or from your healthcare provider, via an enrolment or request form, which may (depending on the circumstances) identify you. For example (in the case of patients) we may collect initials, date of birth, gender and health information and (in the case of physicians and pharmacists) we may collect your name, provider number, contact details, address and institution details.
We will collect your Personal Information to respond to your specific request and provide you with the products and services you wish to receive. We may also process this Personal Information to conduct internal analytics which inform our business process, reporting to government bodies and business partners for the purposes supporting a medical program.
Our legal basis for collecting this information is consent and/or legitimate interest and/or for complying with regulatory, legal, requirements by laws or as outlined in this Privacy Policy.
If you choose not to provide us with your Personal Information, we may not be able to process your request.
We may share this information with third parties (including for example government authorities, vendors or business partners who support Medison in delivering our products and services, or who manufacture, distribute or require certain types of reports from Medison. Your personal information may be shared or accessed by third parties for example by direct communications or sharing information via live digital platforms).

When you browse or visit our Website:

We collect non-personal information, which includes your session durations, the content you accessed on the Website, the frequency and scope of your use of the Website and information about your computer and internet connection including the operating system you use and browser type. We also collect information about you through cookies and analytic tools for necessary, analytics purposes. For more information, please read our cookie policy, available here.
Our legal basis for collecting this information is consent and/or our legitimate interest (e.g. using essential cookies).
We share this information with third party tools such as Google analytics.

When you communicate or interact with us:

We collect information from which you can be personally identified, including but not limited to your name, email addresses, telephone numbers, physical addresses, health care professional provider number, places of work, company, ABN number, bank details, health information (including but not exclusive to gender, date of birth, medical history, dietary requirements) and any other information that you choose to share with us.
We will collect your Personal Information to respond to your specific request and provide you with the services you wish to receive. Such collection of information will enable us to provide you with technical and professional assistance.
If you are a health care professional, Medison collects and records Personal Information (and non personal information) about you into systems (paper and digital), to conduct profiling. The Personal Information (and other information collected about you) include those described in this Privacy Policy above (Section 1), as well as other operational, interests or preferences you may have, which may be collected by us from both publicly available information and information provided by you. Profiling means that the information that is collected by us, is stored, processed and analysed by us (or by a digital or automated system that we use), in order to provide us (and our business partners) with insights into how we can better communicate with you, provide products and services, support the quality use of medicines, improve our products and services and inform business decisions. These insights may be shared with our affiliates companies who are located overseas (e.g. US, Europe, Israel, Canada, South America, Asia) and contractors who assist us to provide our products and services.
If you subscribed to our mailing list, we will use your Personal Information to send you (to the email address you have provided upon your registration) newsletters and updates as well as to update you regarding congresses or other scientific events that we organise (including those organised with third parties) and sending you advertising communications regarding our goods, the services of Medison and for market research purposes. You may choose to unsubscribe from our mailing list at any time by clicking the “unsubscribe” link in the newsletter.
Our legal basis for collecting your Personal Information is that processing is necessary in order to take steps at the request of the data subject prior to entering into a contract and/or our legitimate interest (e.g. to respond to your request).
We may share this information with third party platforms, such as email platforms and/or hosting providers (as detailed below) or other vendors that we engage for providing our services, for example verification services.
If you choose not to provide us with your Personal Information, we may not be able to process your request.

When we process your job application:

We collect the following information: Full name, email address, phone number, CV or LinkedIn link, and any additional information which you would like to share with us.
We collect this information to process your job application and to assess you as a candidate.
Our legal basis for collecting this information include the following: processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, and legitimate interests (e.g. to assess your suitability as a candidate).
We may share this information with third party platforms, such as recruitment software, email platforms and/or hosting providers (as detailed below).
If you do not provide us with your Personal Information, we may not be able to process your application.

Disclosure of Personal Information

In addition to the recipients described above, we may disclose your Personal Information as follows:

With our business partners with whom we jointly offer products or services. We may also share Personal Information with our affiliated companies;
To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Information to such third party (whether actual or potential) in connection with the foregoing events;
In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Information in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or
Where you have provided your consent to us sharing or transferring your Personal Information (e.g., recruitment software).

Transfers of Personal Information

Storage: We store the Personal Information with SPD Hosting with servers located in Israel.

Internal transfers: Transfers to companies in the same corporate group as Medison will be covered by an internal processing arrangement of the Medison group which obliges each member to ensure that Personal Information receives an adequate and consistent level of protection wherever it is transferred to. Countries to which we regularly transfer Personal Information within the Medison group include but are not limited to Switzerland, Israel, Canada, Poland and Slovakia.

External transfers: Where we transfer your Personal Information overseas (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Information. Countries to which we regularly transfer Personal Information in connection with our engagements with third party service providers include but are not limited to England, Germany, US, Poland, Ireland, Netherlands, Asia Pacific and Singapore.

Your rights

You have the right at any time to request to access, modify or correct your Personal Information, or object to or restrict processing of your Personal Information. To exercise these options or otherwise make a complaint regarding the handling of your Personal Information, please contact us at privacy@medisonpharma.com.

In some jurisdictions, in particular those located within the European Union or within the European Economic Area, you may be afforded specific rights regarding your Personal Information. Subject to such eligibility, you may have the following rights to:

Request a rectification of your Personal Information where the information we hold about you is incorrect or incomplete.
Object to the processing of your Personal Information for direct marketing purposes.
Object to the processing of your Personal Information where our legal basis for that processing is that such processing is necessary for our legitimate interests.
Object to an automated decision-making (including profiling) in certain circumstances.
Request the erasure of your Personal Information in certain circumstances, such as where processing is no longer necessary for the purpose it was originally collected for, and there is no compelling reason for us to continue to process or store it;
Receive your Personal Information, or ask us to transfer it to another organisation that you have provided to us, which we process by automated means, where our processing is either based on your consent or is necessary for the performance of a contract with you.
Lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honouring your request. If you wish to file a request regarding any of the above, you may contact us at: privacy@medisonpharma.com.

Links to other websites

This Website may provide links to other websites. Please be aware that these other websites are not covered by our Privacy Policy. This Privacy Policy does not cover the information practices exercised by other providers of products or services, advertisers or other websites, companies or individuals, which are not owned or controlled by Medison. We suggest that when linking to another website, you always read that website’s privacy policy before volunteering any personally identifiable information.

Analytic tools

The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

Data Security

The technical and organisational measures that we deploy are in line with or exceed industry standards to ensure the security, confidentiality, integrity and availability of personal information that we process. We maintain physical, technical and administrative safeguards, and test and update these periodically. We endeavour to restrict access to Personal Information on a ‘need to know’ basis for the provision of services to you. In the event of a security breach, we will take all reasonable action to minimise any harm. Although we will do our best to protect Personal Information, we cannot guarantee the security of data transmitted to our site or to group companies, and transmission is at the users own risk.

Data Retention

Your Personal Information will be stored in accordance with applicable data protection laws and until we delete the record and we proactively delete it or you send a valid deletion request. Please note that in some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings. Regarding retention of cookies, you can read more in our cookie policy available at https://www.medisonpharma.com/cookies-policy/.

Privacy of Children with respect to use of our Website

The Website is not intended for children under the age of 16. We do not, knowingly or intentionally, collect information about children who are under 16 years of age. If you are under the age of sixteen (16), do not provide any Personal Information to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@medisonpharma.com.

Do you have questions regarding our Privacy Policy?

If you have any questions regarding this Privacy Policy or the practices described above, please contact us at privacy@medisonpharma.com. The data controller of this Privacy Policy is Medison Pharma Ltd. In Australia, our APP entity is Medison Pharma Australia Pty Limited.

Updates to our Privacy Policy

We may revise, amend, or modify this Privacy Policy at any time. When changing the policy, we will update this posting accordingly. Please review this Privacy Policy often so that you will remain updated regarding our current policies.

To learn more about the use of Personal Information in the context of adverse event reporting or while delivering our services, please follow this link.

This page was updated on 1 August 2024