1. DBG Group and the scope of this Privacy Policy
This Privacy Policy sets out how DBG Health Pty Ltd (ABN 93 631 940 308), and its related entities, including but not limited to Arrotex Pharmaceuticals Pty Ltd (ABN 30 605 552 234) (Arrotex), VidaCorp Pty Ltd (ABN 73 677 672 052) (Vidacorp), Axe Health Pty Ltd (ABN 23 627 538 934) (Axe Health), Independent Pharmacies of Australia Group Pty Ltd (ABN 73 609 137 546) (IPA), My DNA Life Australia Pty Ltd (ABN 18 1256 393 94) (MyDNA) (together 'DBG Group', or 'we', or 'us', or 'our') manage and treat Personal Information in the course of the DBG Group's business activities.
The activities of the DBG Group include:
- the procurement of pharmaceutical products from suppliers by Arrotex and its related entities
- the marketing, offering for sale, distribution, and sale of pharmaceutical products to wholesalers, pharmacies, and hospitals
- the provision of dose administration aid professional services
- the provision of professional services clinics
We are committed to protecting your privacy and complying with our obligations under the Privacy Act, including the APPs. This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information.
2. Definitions
Terms are more fully defined in the Privacy Act.
3. What types of Personal Information does the DBG Group collect, how is it collected, and for what purpose is it used?
Pharmacy Customers
We 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
Members of the DBG Group may offer therapeutic and cosmetic goods and beauty services 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. For beauty services, we may collect certain sensitive health information relevant to the provision of services. These details are collected directly from you when you make your purchase or book a beauty service (either in-store or through our online platforms), and is used to facilitate the purchase and the delivery of your goods or the provision of our services. Failure to provide the relevant information may result in your purchase not being finalised or our inability to provide beauty services.
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 (i.e. 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 may result in the failure to properly investigate and follow-up on such reports.
We also collect 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 products.
If you are a health professional and provide the DBG Group with Health Information about your patients, you must obtain the consent of your patient before disclosing their Health Information to us. The details of your patient may be de-identified where we are not satisfied that you have obtained that consent or you notified us accordingly.
Patients
If you are a patient, your Health Information may be collected when pharmacovigilance reports or product complaints are reported to the DBG Group directly by you or through your health professional. This Personal Information is generally collected on behalf of the DBG 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 DBG 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
We collect your Personal Information if you own, or work for, a business associate or contractor of DBG 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, and give effect to any contract.
Potential Employees and Employees
We collect Personal Information from individuals who are shortlisted as applicants for a position within the DBG Group. Where you have applied for a position as an 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.
4. How is your Personal Information disclosed and is it disclosed overseas?
In certain circumstances, 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 Jetform 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 de-identified) 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. We take reasonable steps to ensure that overseas recipients do not breach the Australian Privacy Principles (APPs) under the Privacy Act, and have safeguards in place to ensure your personal information is not accessed by unauthorised users.
We may also disclose your Personal Information to:
- our related entities and commercial partners for purpose of product improvement
- our marketing providers for the purpose of advertising, provided you have given us your express consent to do so
- analytics providers for the purpose of customer engagement activities, subject to compliance with the Data Protection Legislation such disclosure may include disclosure overseas to countries as set out in clause 4.2
We may also disclose your Personal Information in circumstances permitted by the Privacy Act, including to regulatory authorities.
5. Does the GDPR apply?
Where we process data of individuals in the European Economic Area, we will comply with the GDPR to the extent applicable, including upholding individual rights such as access, correction, erasure, and objection to processing.
6. What Credit Information is collected and is it disclosed?
Members of the DBG 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 DBG Group not to disclose any Credit Information to third parties.
7. How is your Personal Information collected when using a DBG website?
When you visit our websites or use other online resources or apps provided by any member of the DBG Group, we may collect information about your computer or electronic device (e.g. 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, web beacons, pixel tags, and other similar tracking technologies (collectively, "Cookies"). These technologies help us recognise your browser or device, remember your preferences, understand how you use our website, and improve your experience.
We use the following types of Cookies:
- Strictly Necessary Cookies: these are essential for the proper functioning of our websites and cannot be disabled in our systems. They are usually set in response to your actions, such as logging in or filling out forms
- Performance and Analytics Cookies: these Cookies collect aggregated, anonymous information about how visitors use our website (e.g., which pages are most visited), helping us understand and improve site performance
- Functionality Cookies: these allow our websites to remember the choices you make (e.g., your region or language) and provide enhanced, more personalised features
- Targeting or Advertising Cookies: these may be set through our site by us or our advertising partners. They may be used to build a profile of your interests and show you relevant ads on other sites
You can control or disable Cookies through your browser settings. Please note that disabling certain Cookies may affect the functionality and user experience of our websites.
By using our websites, online resources, apps, or any other services of a member of the DBG Group, you consent to:
- our use of Cookies in accordance with this Privacy Policy. If you do not agree to the use of Cookies, please disable them via your browser
- collection, storage and handling of any Personal Information collected in accordance with this Privacy Policy or any update to it
8. Does DBG use Automated Decision Making?
DBG Group does not currently engage in automated decision-making that has a legal or similarly significant effect on individuals. Should this change, we will ensure transparency and compliance with applicable legal obligations under the Privacy Act and emerging regulatory expectations.
9. How is my Personal Information stored and secured?
Personal Information is stored on secure servers that are protected in controlled facilities, or in hardcopy paper records stored in secure access facilities. The DBG Group requires its employees and data processors to protect the confidentiality of any Personal Information held by us.
The DBG Group will take commercially reasonable steps to keep secure all Personal Information from misuse, interference, loss and unauthorised access.
We implement both technical and organisational security measures, such as encryption, access controls, staff training and regular audits, in accordance with current industry standards.
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.
10. How can I access my Personal Information?
If at any time you want to update or know what Personal Information (including Credit Information) the DBG Group holds about you, you are welcome to access your record by contacting the DBG Group using the details set out below. We aim to respond to access requests within 30 days, as required under the Privacy Act, unless exceptional circumstances apply.
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 a member of the DBG Group or a third party.
11. How can I amend or delete my Personal Information?
The DBG Group will take reasonable steps to ensure your Personal Information (including Credit Information) is accurate, up-to-date and complete and notify you of any such changes.
If you wish to have your Personal Information updated, 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.
12. How long is my Personal Information retained for?
We will retain your personal information only for as long as necessary to fulfil the purposes for which it was collected or to comply with legal, regulatory or reporting obligations. Once no longer needed, we will securely destroy or de-identify it.
13. Will I receive marketing communications?
We will not send you marketing communications unless you have opted in to receive them. You can withdraw your consent at any time by following the unsubscribe link provided by contacting us directly.
14. How can I contact you?
Please contact us if you:
- have a complaint regarding the DBG Group's compliance with this Policy or any applicable privacy laws. The DBG Group will consider and respond to a complaint within a reasonable time frame
- wish to discuss any privacy issues, have any concerns regarding your Personal Information
- do not wish to receive any future communications from any member of the DBG Group
Contact Details:
DBG Health Pty Ltd
Attn: Privacy Officer
Level 3, 459 Church Street,
Richmond, VIC 3121
The DBG Group is committed to being a leading provider of health care products and services. As the business evolves and new services and products are introduced, this Policy may be reviewed and revised, and we reserve the right to amend or replace this Policy at any time. The DBG Group will notify you of any such changes by posting an updated version of the Policy on our 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.
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