Privacy policy

PRIVACY POLICY

Vifor Pharma Pty Ltd ACN 086 114 043 (which, for the purpose of this Privacy Policy includes any of its Related Bodies Corporate (as that term is defined in the Corporations Act 2001 (Cth)) and other Vifor Pharma Group companies (including Vifor Pharma Management AG)) (Vifor Pharma, we, us, our) respects your privacy and is committed to protecting the personal (including sensitive) information that we collect and hold about you.

We have developed this Privacy Policy to inform you of how we manage the personal information that we collect about you.

By providing personal information to us, you are taken to have read, and consented to the collection, use, disclosure and handling of your personal (including sensitive) information in accordance with this Privacy Policy.

1. What personal information we collect about you and how we collect it

Personal information has the meaning given to that term in the Privacy Act 1988 (Cth) (Privacy Act) and includes information or an opinion (whether true or not) about an identified individual, or an individual who is reasonably identifiable.

In this Privacy Policy:

‘personal information’ also includes sensitive information, which is defined in the Privacy Act to include in-formation or an opinion about an individual’s racial or ethnic origin, religious beliefs or affiliations, sexual orientation or practices, health information, or genetic information that is not otherwise health information; and
health information has the meaning given to that term in the Privacy Act, and includes information or an opinion about the health or disability of an individual, health services provided (or to be provided) to an individual, and other personal information that is collected to provide, or in providing, a health service.
We aim to collect personal information only if it is reasonably necessary to providing the service, product or information you have requested from us.

Vifor Pharma may collect personal information about you when you:

are a healthcare professional that works with a Vifor Pharma product;
participate in a Vifor Pharma PFP;
are a healthcare professional, attend a conference and agree that the conference organiser may provide your name to the exhibiting companies;
are an individual that uses a Vifor Pharma product;
make an enquiry about our services or products;
engage with our business or its employees in the course of receiving services from us;
visit one of our websites, www.viforpharma.com/au or www.ironacademy.com.au (Websites);
ask to be placed on one of our mailing lists; or
supply goods or services to us.

In the course of providing you with products and services, Vifor Pharma collects personal information in a variety of ways. Unless it is unreasonable or impracticable to do so, we collect your personal information from you directly including by using cookies on our website.

In some cases, however, we will collect information about you from a third party. If you are a healthcare professional, we may also collect your personal information from:

the medical college available on your website;
Avention Media, a third party that supplies us with the place of work and emails for healthcare professionals directly related to Vifor Pharma products;
One Key, a third party that supplies us with the place of work and contact numbers for healthcare professionals directly related to Vifor Pharma products; and
third parties that administer product familiarisation programs (PFP) for us.

We may also be introduced to you through another healthcare professional, in which case we may receive your contact details in this way.

If you are an individual that uses a Vifor Pharma product, we may collect personal (including health) information about you from healthcare practitioners or from the Medical Information and Pharmacovigilance service.

If you supply goods or services to Vifor Pharma, we may also collect personal information about you from your employer.

At the time of collection, or as soon as practicable after we have collected it, we will take such steps as are reasonable in the circumstances to notify you of the collection and of matters relevant to the collection, unless it is obvious from the circumstances that you would know or would expect us to have the information.

If you are a healthcare professional or third-party supplier of services to Vifor Pharma, we may collect the following personal information about you:

name;
address;
email address;
telephone number and other contact details; and
details about you to assist in managing our relationship with you (including but not limited to the dates and types of our interactions with you and the results of those interactions, your approach to our products and treatments more generally, responses to surveys in which you agreed to participate, information you requested of us and any samples or information we provided, the services you provided to us, and the compensation or financial support for research and education we may have provided).

If you are an individual that uses a Vifor Pharma product we may collect your date of birth, gender, and the initials of your name. Sometimes we may also collect your full name, address and telephone number, but this is generally only when you provide that information to us directly.

For each visitor to our Websites, we may also collect the following non-personally identifiable information:

browser type, version and language;
operating system;
pages viewed while browsing the Websites; and
page access times and referring website address.

2. How We Use Cookies

We may use cookies on some areas of our Websites. A cookie is a small file saved on your computer’s hard drive. When you return to our website, the data saved in the cookie is sent back to the website. We use cookies to gauge visitor traffic, trends and to help us serve you more efficiently if you revisit the Websites. The cookies we use in no way give us access to your computer or any information about you, other than the information you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our Websites.

3. Purpose of collection

If you are a healthcare professional, we collect your personal information primarily to:

comply with our legal obligations, including tax, accounting and transparency obligations and documentation obligations regarding samples, promotional materials, and other information provided to you;
for administrative purposes and to assess how we can support you and further strengthen our relationship;
communicate with you around quality use of medicine, adverse event reporting and market research;
contact you for business purposes and manage our relationship with your or your organisation;
provide you with the goods, services and information that you request from us;
provide you with information about Vifor Pharma’s products and services, including information about our products and services across any of the brands in our group, both current and future; and
suggest Vifor Pharma products and services to you.

If you are an individual that uses a Vifor Pharma product, we collect your personal (including health) information primarily to report adverse events and to monitor the safety of our products, which is a regulatory requirement for the continued registration of our products. Sometimes we also collect your personal information to respond to a request for information about our products.

If it is reasonable to expect that we would use or disclose your personal information for purposes which are related to the above primary purposes, we may also use or disclose your personal information to:

assist you with enquiries or complaints;
develop and improve our products, client service and relationships;
promote, advertise and market any of our products and services, including to invite you to seminars or events hosted by Vifor Pharma;
for market and product research purposes;
comply with our legal and reporting obligations (including to comply with any law or any lawful request of a law enforcement agency or government authority), resolve any disputes that we may have with any of our clients and enforce our agreements with third parties such as your employer. This includes our obligations to the Therapeutic Goods Administration (TGA) and Medicines Australia.
inform you of developments at Vifor Pharma and other services that we can provide.

We may use information collected through our Websites for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are at our Websites.

Where possible, we will provide you with a choice to opt-out of any of the above and any of our marketing communications. We will respect your request to decline to receive these marketing communications.

4. Sharing of your personal information

We may disclose your personal information to:

external providers of services that we use to provide business or administrative services to our business or manage our business systems (for example, file storage service providers, database and mailing service providers, marketing service providers, couriers and/or freight service providers, printers, call centers, providers of payment processing and identity verification services and IT technicians who may need access when providing on-site support (although it is our practice for them to work under supervision) and other profession-al service providers as required from time to time);
Medicines Australia or the TGA; or
our professional advisors and agents.

If you are a healthcare professional, we may disclose your personal information to other Vifor Pharma Group companies to enable them to send you information they believe may be of interest to you, including information about our products and services across any of the brands in our group, both current and future. Information about the companies within the Vifor Pharma Group is available at: https://www.viforpharma.com/about-vifor-pharma/global-presence#list-view. If you participate in a PFP, we may also disclose your personal information to third parties that assist us in connection with the PFP, including to administer the program or to evaluate the PFP on our behalf.

We may disclose your personal information to these third parties so that they can assist us with providing the best possible service to you.

Those people or companies will be permitted to access only the personal information they need to deliver the service to Vifor Pharma or to you, or where required by law or Vifor Pharma’s reporting requirements. Vifor Pharma takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.

Some Vifor Pharma Group companies and third-party service providers who will have access to your personal information are located overseas, including in the European Economic Area, Switzerland and the United States. Because the specific countries may change from time to time, you can find the current countries:

in relation to Vifor Pharma Group companies, on our website, at https://www.viforpharma.com/about-vifor-pharma/global-presence#list-view; and
in relation to third party service providers, on request from us.

When you provide us with your personal information you give us your consent to disclose your personal information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with the privacy Act. However, where information is disclosed to Vifor Pharma Group companies that are located overseas, those companies will handle your personal information in accordance with the requirements of the country to which the information is disclosed. You may request a copy of the relevant safeguards that Vifor Pharma Group companies have in place by contacting us as specified below.

We are not otherwise likely to disclose information to overseas recipients unless it is with your consent, or the dis-closure is required or authorised by law.

The privacy and collection practices of entities to which we disclose personal information are governed by their own privacy policies and collection notices.

We will not otherwise disclose information about you unless the disclosure:

is required or authorised by law; or
you have consented to our disclosing the information about you.

5. Quality of your personal information

We aim to ensure that your personal information is accurate, complete and up to date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested and properly update the information to us to keep it true, accurate, current and complete.

6. Securing your personal information

We may hold your personal information in electronic or hard copy form. We will take reasonable precautions to protect your personal information from misuse, interference and loss, as well as from unauthorised access, modification or disclosure. We use a number of physical, encryption, administrative, personnel and technical measures to protect your personal information.

We will retain your personal information (including your health information) as required by law, and then take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed.

7. Changes to this Privacy Policy

Vifor Pharma reserves the right to make amendments to this Privacy Policy at any time for any reason. We will publish any updated privacy policy on our Websites.

8. Accessing and correcting your personal information

You have a right to request access to, or the correction of, your personal information that we hold about you, subject to exceptions allowed by law. You may be required to put your request in writing for security reasons.

We will give you access to, or correct, your personal information unless there is a lawful reason for refusing your request for access or correction. If we refuse your request, we will give you a written notice explaining our reasons for that refusal and how you may complain about that refusal.

9. Change in control of Vifor Pharma

If we sell or otherwise transfer part or the whole of Vifor Pharma or our business to another organisation (including in the course of a transaction like a sale, merger or acquisition or as part of a dissolution, liquidation, administration, receivership or other form of insolvency), you agree that your personal information that is collected by Vifor Pharma may be disclosed to a third party, prospective buyer, transferee or insolvency practitioner and that this is reasonable to enable that party to continue or manage the business.

10. Complaints

If you have a complaint about our collection, use or disclosure of your personal information, or you wish to make a complaint about a breach of the APPs, please contact our Privacy Officer at the details set out below.

In your complaint, please set out the details of your complaint and your contact details. Our Privacy Officer will contact you to acknowledge your request and ask for any other applicable information. Our Privacy Officer will then investigate the issue and advise you in writing of the outcome.

You can also make a complaint to the Office of the Australian Information Commissioner. Further information is available at www.oaic.gov.au.

11. Contacting us

If you have any questions about this Privacy Policy or our privacy practices, would like to make a complaint or request access to or correction of your personal information, please contact us by any of the following means.

Our contact details in respect of any issues in relation to privacy are:

Telephone +61 3 9686 0111

Email info_au@viforpharma.com

Post Vifor Pharma Pty Ltd

Level 9, 140 William Street

Melbourne VIC 3000