PRIVACY POLICY AUSTRALIA & NEW ZEALAND

Effective 16 October 2024

Your privacy is paramount to us.

STADA Pharmaceuticals Australia Pty Limited its subsidiaries and affiliates (collectively referred to as 'STADA') are subject to the Privacy Act 1988 (Cth) ('Australian Privacy Act') and the Privacy Act 2020 ('New Zealand Privacy Act') (together, the 'Acts'). STADA are committed to managing personal information in accordance with the Acts and with other applicable privacy laws.

This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.

In this Privacy Policy, "we" and "us" refers to STADA and "you" refers to any individual about whom we collect personal information.

STADA considers choice to be one of the key principles of privacy. You have the choice not to provide your personal information to us (unless required by law); however, this may limit our ability to offer you products and services or restrict your full participation in all features of our websites and mobile applications. STADA will inform you if it is possible for an interaction to occur on an anonymous basis and, where it is, providing personal information will be optional.

By providing personal information and/or continuing to engage with STADA you consent to your personal information being collected, used and disclosed in accordance with this Privacy Policy.

What is personal information?

Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

• whether the information or opinion is true or not;
• and whether the information or opinion is recorded in a material form or not.

This includes information such as name, date of birth, address, email address, telephone number and credit/debit card information.

Whose personal information does STADA collect and use?

STADA collects personal information from people who are connected to its operations and activities – including customers, employees, clinical trial participants, health professionals, suppliers and service providers. As such, STADA may keep a record of your name, contact details (i.e. address, telephone number, email address, etc.), and when collecting personal information for business purposes your professional details (e.g. qualifications, specialty, areas of interest), details on your practice/business (e.g. size, use of products, prescribing practices) and details of your dealings with us. 


The types of information that we will collect from you will depend on the type of relationship we have with you (e.g. the information we collect from a customer will be different to the information we collect from a health professional). The personal information collected by STADA will be limited to the information necessary to record and manage our interaction with you as permitted or as required by law.

How does STADA collect your personal information?

Where possible, STADA will collect your personal information directly from you. This may be in person, on the telephone, by mail or online. We also obtain personal information from third parties such as contractors, list vendors, health professionals, and social and community workers.

If we collect information about you from a third party and it is unclear that you have consented to the disclosure of your personal information to STADA, we will take reasonable steps to contact you and ensure that you are aware of the purposes for which we collect your personal information.

How does STADA collect, use and disclose your personal information?

STADA may collect your personal information for a number of purposes or as required by law, including but not limited to:

• product and service management: to efficiently administer and manage the products and/or services we provide;
• product and service distribution: to monitor the distribution of our products and services;
• enforcing our terms and conditions;
• marketing: to communicate with you about products and/or services that may be of benefit to you;
• to conduct due diligence with respect to our service providers;
• feedback: to assist us in responding to any complaints or queries;
• complying with our regulatory obligations (e.g. notification of important product safety information or recording reporter details for adverse event reporting);
• involvement with Patient Programs;
• fulfilling orders through STADA programs;
• to provide health related products or services (including advice) that have been requested;
• managing, planning and arranging meetings between healthcare practitioners and our sales representatives;
• maintaining a record of medical queries, complaints and adverse event or adverse reaction reports relating to our products and reporting these to the Government or relevant regulatory bodies, such as the Therapeutic Goods Administration or Medsafe, as may be required;
• other issues: communicating with you in relation to our operations, activities and objectives, to verify your identity, to improve and evaluate our programs and services and to comply with relevant laws.

Wherever practicable, we will provide you with a collection notice which explains the primary purpose for which we are collecting your personal information.

To whom does STADA disclose your personal information?

We may need to disclose your personal information to others in order to carry out our activities. This may include:

• External support services: to health care professionals, lawyers, other professionals, counsellors, funders, financiers, co-ordinators, volunteers, service providers, agencies and support service providers.
• Contractors and service providers: who perform services on our behalf, such as mailing houses, printers, information technology services providers (including offshore cloud computing service providers), database contractors and telemarketing agencies.

We may also be required to disclose your personal information where we reasonably believe that the law requires or permits us to do so. Wherever practicable, we will provide you with a collection notice which explains the circumstances in which we might disclose your personal information.

Health information and other sensitive information

As part of administering STADA products and services, we may collect health information and other sensitive information. For example, we may collect medical history information from you if you are participating in a patient program, health program or clinical trial. Sensitive information is defined by law as the following type of information: racial or ethnic origin; political opinions; membership of a political association; religious beliefs or associations; philosophical beliefs; memberships; sexual orientation; genetic information; biometric information; biometric templates. We will only collect these types of information if it is necessary to deliver a product or service to you, or where it is required for research purposes, and you have specifically consented to the collection of that information.

Patient Programs

If you are participating in a Patient Program or Medicines Access Program (such as Cost-Share Agreements, Compassionate Access Programs, or Product Familiarisation Programs) or a Patient Support Program, STADA may collect additional sensitive data and health information. This information may come directly from you, your healthcare professional, or related third parties, including nominated third party service providers engaged by STADA to support the delivery of these programs.

STADA and its service providers may use and disclose your personal information to administer and manage your participation in the program. STADA and/or our service providers may also communicate with your healthcare professional to exchange information relevant to your involvement in the program.

What happens if you don’t provide all this information?

You are free to provide (or not provide) any information you choose. However, if you do not provide some or all of the personal information requested, we may not be able to offer you products or services or provide you with information requested by you.

How does STADA interact with you via the internet?

You may visit our websites (www.stada.com.au) without identifying yourself. If you identify yourself (for example, by providing your contact details in an enquiry), any personal information you provide to STADA will be managed in accordance with this Privacy Policy.

STADA's websites use cookies. A “cookie” is a small file stored on your computer's browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, IP address, pages you have accessed on our websites and on third-party websites. You are not identifiable from such information.

You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website. For more information about cookies, visit www.aboutcookies.org.

Links

STADA websites may contain links to other websites that we think may be of interest to you. However, STADA is not responsible for the privacy practices or the content of such websites. When linking to the other site, you should always check that the website's privacy policy before providing any personal information.

Does STADA use or disclose your personal information for direct marketing?

Where we have obtained your consent, STADA may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you. Communications of this nature may be sent via post, email, SMS, telephone or other electronic means.

If you do not want to receive direct marketing communications, you can opt-out at any time, you can unsubscribe by following the instructions provided in the communication or by contacting us using the contact details below.

If you opt-out of receiving marketing material from us, STADA may still contact you in relation to its ongoing relationship with you.

STADA may also disclose your personal information to third party service providers who assist us in delivering our direct marketing communications. These service providers are contractually obligated to handle your personal information in accordance with applicable privacy laws and regulations.

Can you deal with STADA anonymously?

STADA will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally, it is not practicable for STADA to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.

How does STADA hold and secure personal information?

We will take all reasonable precautions designed to safeguard personal information that is processed or used by us from loss, misuse, unauthorized access, modification, or disclosure. To ensure that your personal information is secure, we employ several means, including contracting with reputable data storage service providers (including trusted third-party storage providers based in Australia and overseas) which comply with relevant regulatory requirements.

Further, we apply a range of measures including: (i) external and internal premises security; (ii) the requirement for all employees to enter into a confidentiality agreement; (iii) computer firewall protection; (iv) restricted access to personal files and information; (v) computer maintenance to prevent unauthorized access; (vi) document handling and shredding procedures with respect to personal information; limiting access to your personal information; and (viii) educate our employees about their duty to protect your privacy and provide training regarding privacy obligations.

While we endeavour to keep information on STADA sites, including the personal information provided by you or on your behalf, secure and confidential, we will not be responsible for any breach of security caused by third parties and do not represent that STADA sites you may interact with are completely secure.

Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending personal information via the internet.

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 APPs 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 APPs in relation to your personal information.

Entities which are related entities of STADA, or are otherwise affiliated with STADA, have operations throughout the EU, China, Kazakhstan, Philippines, Saudi Arabia, Thailand, United Arab Emirates, Uzbekistan and Vietnam. 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 (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 APPs. 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 APPs or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the OAIC website.

If you are in New Zealand, a complaint may be made to the Office of the Privacy Commissioner (OPC). The OPC can be contacted by telephone on +64 0800 803 909 or by using the contact details on the OPC website.

Personal Information of Minors

Should you be providing us with Personal Data of individuals who are under the age of eighteen (18) years, you confirm that you hold the appropriate authority to do so and can evidence such authority to STADA upon our written request.

How can you contact STADA?

If you have questions about STADA and privacy, wish to provide feedback about this policy, would like to update your personal details held by STADA, wish to access information held by STADA about you or wish to make a privacy related complaint please contact STADA for Australia and New Zealand at:



Email:                 [email protected]


Phone:                +61 (2) 9452 6656


Postal address:    The Privacy Officer


                             STADA Pharmaceuticals Australia Pty Limited


                             Suite 2.04,

                             26 Rodborough Road,

                             Frenchs Forest

                             NSW 2086


How changes are made to this privacy policy?

STADA may update this Privacy Policy from time to time, with or without notice to you. Changes to our revised Privacy Policy are effective as at the date listed. We recommend that you visit our website regularly to review this Policy and to keep up to date with any changes.