ARROTEX GROUP PRIVACY POLICY

Arrotex Group and the scope of this Privacy Policy

This Privacy Policy sets out how Arrotex Pharmaceuticals Pty Limited ABN 30 605 552 234, its subsidiaries, including Arrow Pharmaceuticals Pty Ltd ABN 33 605 909 911, Apotex Pty Ltd (ABN 52 096 916 148), Generic Partners Pty Ltd (ABN 11 132 833 777), and its affiliates Oraderm Pharmaceuticals Pty Ltd (ABN 50 612 828 618) and MyPak Solutions Pty Ltd (ABN 39 162 415 401) (together Arrotex Group) manage and treat Personal Information in the course of the Arrotex Group’s business activities.

The activities of the Arrotex Group include (a) the purchase of pharmaceutical products from suppliers by its subsidiaries Arrow Pharmaceuticals, Apotex and Generic Partners; (b) the marketing, offer for sale, distribution and sale of pharmaceutical products to wholesalers, pharmacies and hospitals by Arrow Pharmaceuticals, Apotex and Oraderm Pharmaceuticals; (c) the provision of Dose Administration Aid professional services by MyPak Solutions and (e) the provision of professional services clinics by Apotex.

Definitions

Personal Information generally means information or opinions about an individual who is reasonably identifiable from that information. Personal Information includes Health Information, Sensitive Information and Credit Information.

Health Information includes information or opinions about the health of a person or health services provided to them.

Sensitive Information includes information or opinions about an individual’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, as well as Health Information, genetic information and biometric information.

Credit Information includes the type and amount of credit being south in a credit application, repayment history information about an individual, payment information about an individual and default information about an individual.

Terms are more fully defined in the Privacy Act.

What types of Personal Information does the Arrotex Group collect, how is it collected and for what purpose is it used?

Pharmacy customers

Members of the Arrotex Group collect your Personal Information where you are an individual that owns a pharmacy or an employee of a pharmacy business. The Personal Information collected includes your name, contact details, how you wish to be contacted, notes of our calls and communications with you, areas of your interest (including your professional interests), details of your business (including your purchasing and (deidentified) dispensing patterns), bank account and credit card details), survey information and feedback provided by you.

This Personal Information is generally collected directly from you when we first make contact and during the course of our business relationship with you. The information is used for the purpose of facilitating and improving our business relationship with you as a customer, including providing you with the benefit under any contracts we have with you (or your employer). Failure by you to provide Personal Information that we seek may hamper our ability to provide you with the optimum services and benefits that you may ordinarily be entitled to.

Consumers

In limited circumstances, members of the Arrotex Group offer therapeutic goods directly to you as a consumer. When we do so we collect your contact details, delivery address and details to facilitate payment of the purchase. These details are collected directly from you when you make your purchase. This Personal Information is used to facilitate the purchase and the delivery of your goods. Any failure to provide the relevant information may result in your purchase not being finalised.

Health professionals

Where you are a health professional (such as a doctor or pharmacist) your contact details are collected when you provide us with queries or feedback in relation to products or pharmacovigilance information (ie the monitoring of medicines and other therapeutic goods). This type of Personal Information is generally collected directly from you when you contact us. Your contact information is used for follow-up activities, including those that are part of standard Pharmacovigilance activities. The failure to provide us with such Personal Information or to consent to the disclosure of this information to our suppliers and distributors (see below) may result in the failure to properly investigate and follow-up on such reports.

Oraderm Pharmaceuticals also collects your contact details if you are a doctor and your details have been provided to us via a third party with your consent or as permitted under law. Once contact has been made with you, further records are kept of the communications and meetings with you. This information is used to monitor our contact with you, including information we provide to you regarding our Oraderm products. Failure to maintain such records may potentially result in repetitive and inefficient contact with you.

If you are a health professional and provide the Arrotex Group with Health Information of your patients, Arrotex expects that you obtain the consent of your patient before disclosing their Health Information to us. The details of your patient may be deidentified where we are not satisfied that you have obtained that consent.

Patients

If you are a patient, your Health Information is collected when pharmacovigilance reports or product complaints are reported to the Arrotex Group directly by you or through your health professional. This Personal Information is generally collected on behalf of the Arrotex Group through its Pharmacovigilance service provider. Health Information is also collected when you register as a patient for any professional service clinics or services provided by the Arrotex Group. The specific types of Health Information collected include your name, contact details, medical status and background, any medications taken, any treatment received and additionally, in the case of professional service clinics or services, the contact details of your treating health professional and any recommendations arising out of such clinic or services.

Health Information of patients is collected for the purpose of investigating and following up product complaints and pharmacovigilance reports, or providing you with professional services (as the case may be). Failure to provide us with all the information sought may result in our inability to provide those services or investigate the pharmacovigilance report or product complaint.

Business associates and contractors

The Arrotex Group collects your Personal Information if you own, or work for, a business associate or contractor of an Arrotex Group member. This information generally consists of contact information and is generally collected directly from you or from your employer. Your Personal information is used for the purposes of facilitating the business relationship (including as contemplated under any contract). Failure to collect such information may hamper our ability to communicate with you.

Potential Employees

The Arrotex Group also collects Personal Information from individuals who are shortlisted as applicants for a position within a member of the Arrotex Group. Where you have applied for a position as employee, your name, contact details, curriculum vitae, professional experience and other associated information are collected either through a service provider or directly from you. This Personal Information is used for assessing your application for employment. In some cases, this information is retained for consideration for any future employment positions.

Disclosure of your Personal Information (including overseas disclosure)

In certain circumstances, where you are a pharmacy customer or an employee of a pharmacy customer, your Personal Information is disclosed to our service providers to assist us in meeting and facilitating our obligations and services to you as a customer. Some of our service providers, such as Survey Monkey and Jotform hold such Personal Information on servers located in the United States.

Where you are a health professional or patient (to the extent your Personal Information has not been deidentified) and your details have been collected for pharmacovigilance or product complaint purposes, your Personal Information is disclosed to our third party pharmacovigilance service provider as well as to our suppliers and distributors to facilitate compliance and follow up Pharmacovigilance activities required under regulatory requirements and to investigate product complaints. In some circumstances these suppliers and/or distributors are located overseas, namely in Israel, Germany, the UK, Switzerland, India, Greece, Sweden, South Africa, Denmark, New Zealand, the United States, Hungary, France, Italy, Oman, Poland, South Korea, Spain and Romania.

Where you are a doctor and your Personal Information has been collected by Oraderm Pharmaceuticals, this Personal Information is shared with Douglas Pharmaceuticals Limited in New Zealand, which owns a 50% interest in Oraderm Pharmaceuticals.

We may also disclose your Personal Information in circumstances permitted by the Privacy Act.

Credit Information

Members of the Arrotex Group may collect your Credit Information if you are a pharmacy owner or an individual guarantor of a pharmacy business, for the purposes of assessing any application for credit. The types of information collected include your name, contact information, the name and contact details of any of your business partners, the name and ABN of your pharmacy business, your pharmacy registration number, your trading history, the credit being requested, the delivery address for goods and business references. In addition, we may obtain a Risk of Late Payment report. It is the general practice of the Arrotex Group not to disclose any Credit Information to third parties.

Arrotex Group websites

When you visit our websites or use other online resources or apps provided by any member of the Arrotex Group, we may collect information about your computer or electronic device (eg your Internet Protocol (IP) address, browser type, and date and time of your request) by using automatic systems of browsing data collection, such as cookies. A cookie is a file stored on your hard drive; it does not contain intelligible information, but it allows linking between a terminal and information about your preferences. These tracking technologies are used to provide additional functionality to your use of our resources; for example, to identify you as a healthcare professional, or to remember your preferences and selections. You may limit or remove cookies from your computer or device, but, in these situations, our ability to provide optimal service may be limited. By using any website of the Arrotex Group, you consent to the use and installation of these cookies and web beacons to provide you with these services.

By using websites, online resources, apps, or any other service of a member of the Arrotex Group, you also consent to the storage and handling of any Personal Information collected in accordance with this Privacy Policy or any update to it

Storage and Security of Personal Information

The Arrotex Group will take commercially reasonable steps to keep secure all Personal Information from misuse, interference, loss and unauthorised access. However, we cannot guarantee that third parties will never be able to defeat our security measures or use your Personal Information for improper purposes; for example, we do not control or monitor web sites to which we may provide a link. Our Privacy Policy does not apply to third party web sites.

Personal Information is stored on secure servers that are protected in controlled facilities, or in hardcopy paper records stored in secure access facilities. The Arrotex Group requires its employees and data processors to protect the confidentiality of any Personal Information held by us.

Accessing your Personal Information

If at any time you want to update or know what Personal Information (including Credit Information) the Arrotex Group holds, you are welcome to access your record by contacting the Arrotex Group using the details set out below. Your information will generally be made available to you within 30 days of receiving your request.

If you make such a request, you will be asked for identification so that we can verify your identity before providing you with your Personal Information. If you require Personal Information to be presented in an alternative format, we will make reasonable efforts to accommodate you. If there is an associated charge to us in order to retrieve your Personal Information, we will advise you of the charges that you would be responsible for and obtain your authorisation before proceeding.

We may not be able to give you access to Personal Information where such access would result in disclosure of other individuals’ Personal Information, would result in a breach of a contract, or would result in disclosure of trade secrets or other proprietary business information belonging to Arrotex or a third party.

The Arrotex Group reserves the right to not provide access to individuals if the request for access is frivolous or vexatious, or falls into another relevant exception category, and we may impose reasonable charges for such access.

Amending or deleting your Personal Information

The Arrotex Group will take reasonable steps to ensure Personal Information (including Credit Information) is accurate, up-to-date and complete and notify you of any such changes. If you wish to update your Personal Information, please contact us to amend your record accordingly. Please note we cannot alter medical information generated as part of a clinical trial or study.

If you wish to have your Personal Information deleted, please contact us and we will take all reasonable steps to delete it. In circumstances where we are required to retain Personal Information, we may not be able to delete your Personal Information. Such circumstances may include, for example, where we are required to retain Personal Information by law or regulation, to continue to manage certain programs, to conduct clinical trials, to defend legal claims, or for certain necessary business purposes.

Contact us

Please contact us if you have a complaint regarding the Arrotex Group’s compliance with this policy or any applicable privacy laws. The Arrotex Group will consider and respond to a complaint within a reasonable time frame. In addition, please contact us if you wish to discuss any privacy issues, have any concerns regarding your Personal Information or do not wish to receive any future communications from any member of the Arrotex Group.

You can contact the Arrotex Group’s through the following means:

By Post:
Arrotex Pharmaceuticals Pty Ltd
Attn: Privacy Officer
15–17 Chapel Street
Cremorne VIC 3121

By e-mail: privacy@arrotex.com.au (and specifying in the subject line “Privacy Policy”)

By phone: 1300 927 769

The Arrotex Group’s commitment to being a leading provider of pharmaceuticals means its business will continue to evolve as new services and products are introduced. Because of this, from time to time, its policies may be reviewed and revised, and we reserve the right to amend or replace its Privacy Policy at any time. The Arrotex Group will notify you of any such changes by posting an updated version of the Privacy Policy on its website

Should there be a discrepancy between this Privacy Policy and the applicable legislation at any time, the applicable legislation at that time will prevail.