Customer Relationship Management Privacy Notice

At Ferring, your privacy is important to us and we are committed to ensuring our data protection practices adhere to applicable European and local data protection laws, regulations and codes of practice (“laws”).

This Privacy Notice will provide information as to how Ferring may collect, hold, use, disclose and process your personal data in this context, and will describe the ways in which we will ensure your personal data is protected in accordance with the applicable laws, and should be read together with our privacy policy located at www.ferring.com.au/privacy

This Privacy Notice applies only to this process, therefore if you visit another website related to or recommended by Ferring or else enter into a business relationship with Ferring of a different nature, please consult the privacy notice on the respective website or as otherwise provided by Ferring in that context.

This Privacy Notice describes our practices in connection with information that we or our service providers collect through the website, paper forms or applications operated by our sales representatives and controlled by us from which you are accessing this Privacy Notice.

The controller of your personal data is Ferring Pharmaceuticals Pty Ltd, Suite 2, Level 1, Building 1 Pymble Corporate Centre, 20 Bridge Street, Pymble NSW 2073 Australia.

 

What is personal data?

Personal data means all information that relates to an identified or identifiable individual, and includes the meaning given to “personal information” under the Australian Privacy Act (1988) (Cth). This may include name, postal address, phone number, email address, GMC or practice number, IP address.

 

What categories of personal data does Ferring process in the context of the Customer Relationship Management system?

Depending on our relationship with you, Ferring may collect and use the following categories of personal data in this context for the purposes described below:

- data such as your name, age, gender and contact details;
- professional data such as your workplace, position, the medical field in which you are active, your professional qualifications, and scientific activities (such as previous clinical trials and participation in previous or ongoing studies at Ferring and others), publication of academic or scientific research and articles and membership of associations and boards;
- financial details such as payment details, including tax identification number;
- for transparency reporting purposes, details of amounts paid (or value of benefits received) for specific services you may provide to Ferring from time to time; and
- details of the interactions with us, such as topics discussed, your knowledge of and questions you have had about our company and our products, what kind of material we have shown you and what feedback you have given, as well as your views and routines about prescribing, routines related to your patients and diagnosis, and similar data.

 

From what sources does Ferring collect your personal data?

The data described above is provided either directly by you (on our website, paper form, email, or to our sales representatives to Ferring) or indirectly via companies that have organised activities sponsored or supported by Ferring, such as clinical research, and development activities; public sources, recruitment agencies, interim offices, and third parties, such as IQVIA.

 

For what purposes does Ferring process your personal data?

Generally, we use your personal data for our activities and business and to assist patients who may be treated with our products by their doctor or other healthcare professional, and in our efforts to expand and improve our business. Examples include:

  1. Improving your customer experience;
  2. Product improvement and innovation;
  3. Management of the business or professional relationship we may have with you;
  4. Complying with transparency reporting requirements to report amounts paid to healthcare professionals; and
  5. Promote and market directly to healthcare professionals materials on our products and related activities (including symposiums, seminars, expert panels or other events organised by Ferring) that we consider may be of interest to you, unless you tell us not to do so.

Ferring ensures that it has an appropriate legal basis to deal with your personal information in these ways, including where you have provided your consent for processing your personal data, or our legitimate business interests, in line with applicable law.

 

With whom and how does Ferring share my personal data?

Your personal data may be transferred to other locations in which Ferring maintain facilities (including Ferring affiliates, contractors, partners or agents), where there are legitimate grounds for such a transfer, such as a valid business reason. Such locations may include countries outside the European Economic Area (EEA), or if you are an Australian resident, your personal information may be held and processed overseas by our related companies or our service providers. Any such transfers will be safeguarded by internal international data transfer agreements, to ensure that your personal data is protected in accordance with the applicable European and local data protection laws.

Ferring may, in certain circumstances, share your personal data with third parties, such as vendors, contractors, partners or agents, if necessary to achieve the notified purposes, or if such third parties are assisting Ferring with the processing of the data. Ferring will only disclose personal data about you to a third party in the following circumstances:

  • Relevant consent has been provided by you;
  • where applicable, as a result of a request by you as a data subject
  • whereby there is a legal basis for the disclosure of the data and you have been provided with suitable notice of this
  • where we are required to do so under applicable laws or as a result of a court order; or
  • where Ferring decides to sell, buy, merge or otherwise reorganise its business structure.

Ferring will never sell your information to a third party.

We may transfer your personal data to the following categories of recipients:

- to the companies within our group;
- to external service providers and partners who provide data processing services on our behalf, such as email service providers, hosting, transport, etc.;
- to any competent supervisory or regulatory authority (including the Office of the Australian Information Commissioner), public authority, court or other third party where we believe that disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to protect our legal rights (iii) to protect your vital interests or those of any other person;
- to any other person with your consent to the communication.

 

Storage Restriction

We will retain the personal data we collect for a maximum period of 10 years after termination of our business relationship (or such other period required by applicable law) so that Ferring can comply with its legal obligations.

 

Your data protection rights

You have the following data protection rights:

- You have the right to access your data;
- You have the right to rectify, update or delete your data;
- You can object to the processing of your data;
- subject to applicable law, you can ask us to limit the processing of your data;
- where applicable under data protection laws, you can ask for the portability of your data;
- You have the right to complain to a data protection authority (Office of the Australian Information Commissioner) about the collection and use of your personal data.

You can exercise these rights by contacting Ferring at in DATA SUBJECT CONTACT FORM. In addition, you can always unsubscribe from direct marketing by clicking on the "unsubscribe" or "opt-out" link in the emails we send you.

- You have the right to unsubscribe at any time from marketing communications that we send you.
- If we have collected and processed your data with your consent, you can withdraw your consent at any time. Withdrawal your consent does not affect the lawfulness of the processing that we have carried out prior to your withdrawal, nor does it affect the processing of your data based on other processing grounds.

You can unsubscribe from physical forms of marketing (such as post-marketing or telemarketing), via enquiries@ferring.com or by contacting us on our behalf at our postal address set out below.

Please also note that if you opt out of receiving marketing related messages from us, we may still send you important transactional and administrative messages in line with applicable law.

 

Cookies

In case you used the dedicated website, data about your use of the website may be collected using Google Analytics when visiting the Ferring website dedicated to consent management. This tracking technology uses cookies to collect aggregate data about website usage and activity, such as how many users visit the website and how often. This data may be shared with a third-party service provider in order to further improve our web services. No personal data can be accessed or collected via these cookies. The use of this type of technology shall comply with applicable data protection regulations and the current E-Privacy Regulation. We may also, collect information via:

Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, and Internet browser type and version. We may collect similar information, such as your device type and identifier, if you access the Service through a mobile device. We use this information to ensure that the Service functions properly.

IP address: Your IP address is a number that is automatically assigned to your computer by your Internet Service Provider. An IP address is identified and logged automatically in our server log files whenever a user visits the Service, along with the time of the visit and the pages visited. Collecting IP addresses is standard practice and is done automatically by many online services. We use IP addresses for purposes such as calculating Service usage levels, diagnosing server problems, and administering the Service. We may also derive your approximate location from your IP address.

Device Information: We may collect information about your mobile device, such as a unique device identifier, to understand how you use the Service.

 

Security information

Ferring maintains various technical and organisational security measures to safeguard your personal data from unauthorised access, use, disclosure, accidental destruction or loss. For example, where appropriate, Ferring is committed to the encryption, anonymization or pseudonymization of personal data, and personal data will be stored securely in a designated system. Our internal policies and procedures are designed to prioritise and promote the protection of personal data.

While our data security measures are continually evaluated and updated, the security of data transferred via the internet from a computer or other device cannot be guaranteed and you are encouraged to take steps to protect yourself online and against unauthorized use of your passwords, and mobile devices, as well as installing the appropriate firewall, anti-virus and anti-spyware protections for your computer.

A non-exhaustive list of possible data incidents may include,

  • a lost/stolen laptop
  • an external hacker
  • an email containing personal data sent in error
  • employees access personal information they are not legitimately authorised/required to access to perform their duties/functions
  • information lost in transit
  • documents left in unsecured location.

A data breach is not required to be notified to the Supervisory Authority and to data subjects unless it is an 'eligible data breach’. For this reason, in case of an incident or potential data breach, we will take all reasonable steps within 30 days to determine whether an eligible data breach has occurred by conducting the appropriate check (assessment).

If you suspect any security compromise or detect vulnerabilities, it is essential to report these data incidents immediately by using the Data Subject Contact Form.

 

Children

The Service is not directed to individuals under the age of 13, and we request that these individuals not provide personal information through the Service. If your child has submitted personal data and you would like to request that such personal data be removed, please contact us as explained below under Contact Us.

 

Modifications

Any changes to this Privacy Notice will be communicated at this location (https://ferring.com.au/crm-privacy). We recommend you consult our Privacy Notice when revisiting our website to review any changes and to keep informed about our ongoing commitment to respecting the right to privacy and to providing the highest possible level of data protection.

 

Contact information

If you have any questions or comments question regarding this Privacy Notice, please contact Ferring via enquiries@ferring.com.

You can always unsubscribe from direct marketing by clicking on the "unsubscribe" or "opt-out" (hyper link to preference page) link in the confirmation emails we send you or contact us at the following address:

 

AUSTRALIA

Ferring Pharmaceutical Pty Ltd
Suite 2, Level 1, Building 1
Pymble Corporate Centre
20 Bridge Street
PYMBLE NSW 2073
AUSTRALIA
Phone: +612 9497 2300 (Toll free :1800 33 77 46)

Please note you can opt out only for those service and communication you have consented to.

In addition, you can exercise your rights by contacting Ferring via:

  1. DATA SUBJECT CONTACT FORM
  2. Alternatively, mail us to the following address:

    (Att.: Data Protection Officer)
    Ferring International Center S.A.
    Chemin De la Vergognausaz 50
    1162 St Prex
    Switzerland

This Privacy Notice was last updated on 15/5/2020.