1.1 Care Pharmaceuticals Pty Limited (“CP”, “we”, “our”, “us”) respects and upholds your rights to privacy protection under the Privacy Act 1988 (Cth) and is required to comply with the Australian Privacy Principles in respect of the collection, use, disclosure and handling of personal information. This policy details the practices we have adopted to protect your privacy, so that you can feel confident about how we manage the personal information you entrust to us.
2. When and how do we collect personal information?
2.1 We collect personal information from consumers (existing and prospective), suppliers, contractors, prospective employees, and consumers and other individuals for various business and other purposes further listed below. In this section, we explain the types of personal information we usually collect as well as how we usually collect this information.
2.2 The types of personal information we usually collect and hold will depend on the circumstances in which that information is collected. It may include:
- (a) contact details (such as name, e-mail, phone number, date of birth and postal address);
- (b) age and information on personal lifestyle preferences;
- (c) information required as part of a recruitment process;
- (d) statistical information regarding the use of the our websites, including website users’ IP addresses and the dates and times of visits; and
- (e) where you consent to its collection by us, health information, including medical history or current and previous medication use.
2.3 We usually collect personal information in the following ways:
- (a) through our websites, including via the “Contact Us” section;
- (b) when you contact our Consumer Advisory Service in order to make a consumer inquiry or complaint about a particular CP product;
- (c) when you participate in CP consumer promotions and market research;
- (d) when you apply for employment with CP; and
- (e) through third party service providers.
2.4 Unless otherwise required by law, we will not collect, hold, use or disclose your sensitive information without your consent.
2.5 If you do not provide us with the information we request, we may not be able to fulfil the applicable purpose of collection, such as to supply products or services to you or to assess your application for employment.
2.6 Where practicable, we will collect personal information directly from you. If we receive information about you from someone else (for example from someone who supplies goods or services to us), we will take reasonable steps to ensure you are aware that we have collected personal information about you and the circumstances of the collection.
3. What do we do with the personal information?
3.1 CP’s primary purposes in collecting, holding, using and disclosing personal information are:
- (a) to ensure that our consumers are satisfied with our products;
- (b) to provide our consumers with the best possible quality of customer service;
- (c) to respond to enquiries from existing or prospective consumers seeking information about our products or services;
- (d) to obtain products and services from our suppliers;
- (e) to assess and process warranty claims;
- (f) to enforce agreements between you and CP;
- (g) to process and assess employment applications; and
- (h) to undertake research and surveys and analyse statistical information.
3.3 In carrying out our business, it may be necessary to share information about you with and between our related bodies corporate and organisations that provide services to us. We would not otherwise routinely disclose personal information to another organisation unless:
- (a) required by law;
- (b) we believe it is necessary to provide you with a product or service which you have requested;
- (c) it is necessary to protect the rights, property or personal safety of any of our consumers, any member of the public or our interests;
- (d) the assets and operations of our business are transferred to another party as a going concern; or
- (e) you have provided your consent.
4. Information collected through our websites
4.1 We do not collect personal information from you via our websites, unless you provide it to us voluntarily and knowingly. This means you are under no obligation to provide personal information when visiting our websites. However, if you specifically agree to follow-up contacts by us or ask to be put on our mailing list, we may require your personal information in order to contact you from time to time.
4.2 There are some features of our websites that require you to sign up to use. If you do sign up, we use the information you supply for the purpose of providing products, product information or services you request. Because of the volume of requests we receive, we may have to give your name, e-mail and postal addresses to a fulfilment house or distributor of our products who assist us in carrying out your requests.
4.3 Our websites sometimes include notices of sweepstakes or other promotions we are conducting, and we may permit you to enter electronically in some cases. If that occurs, we will use the information in accordance with the section below entitled “Consumer Promotions and Market Research”.
5.1 Like many companies, we sometimes use “cookie” technology on our websites. These cookies are stored on your computer by your browser. When you log in, the cookie tells us whether you’ve visited us before or you are a new visitor. The cookie doesn’t obtain any personal information about you or provide us with any way to contact you and the cookie doesn’t extract any information from your computer. We use the cookie to help us identify website features in which you have the greatest interest, so that we can provide more of what you want.
6.1 Websites operated by CP may contain links to other sites operated by third parties. CP makes no representations or warranties as to the privacy practices of any third-party site and is not responsible for the Privacy Policies of other sites.
7. Information collected through Consumer Advisory Service
7.1 CP will use the details you provide to our Consumer Advisory Service (whether by e-mail, telephone, letter or fax) in order to provide you with the information, services and products necessary to satisfy your consumer inquiry or complaint. This may involve sending a replacement product, information sheet or follow-up letter in relation to your inquiry or complaint or making a follow-up call. We may also use the information you provide to monitor repeat complaints about a particular CP product. This information will be retained for the purposes of reference and regulatory records until it is no longer required (and will be dealt with in accordance with section 13 below).
7.2 Personal information collected from you by our Consumer Advisory Service may also be used for internal product development and quality control purposes.
7.3 Your personal information is stored in a database. If your complaint is escalated and requires further investigation, your personal information is de-identified (made anonymous) and forwarded to CP’s manufacturing plants for the purposes of determining whether further inquiries into the manufacturing processes need to be conducted. If the complaint is of a particularly serious or urgent nature, then de-identified personal or health information about you may be provided to CP’s manufacturing plants or to external laboratories so that the issue may be analysed and resolved as quickly and effectively as possible.
8. Information collected through Consumer Promotions and Market Research
8.1 In accordance with applicable laws, CP will use the personal information you supply to us via on-pack promotional stickers, claim/entry forms, coupons, survey forms, questionnaires and through our websites for the purpose of providing you with incentives, prizes, samples and other promotional products, information and services. Any personal information you provide to us may be entered into a database, recorded in spreadsheets and kept in hard copy format. That information may be used for future promotional, marketing, market research, product development and publicity purposes. If you are receiving such material from us, and do not wish to receive it any longer, you can opt-out by using the unsubscribe facilities included in our marketing communications, or by contacting CP at the details provided in the section below entitled “CP contact details” and requesting your removal from our mailing lists.
9. Information collected through Employment Applications
9.1 In processing applications for employment, CP collects resumes, references, certificates of graduation and qualification and other personal information about candidates. All applications for employment that we receive are stored in our Human Resources Division. A member of our Human Resources team will review your application. Alternatively, we may provide your application to a recruitment agency or contractor who assists in reviewing applications that we receive.
9.2 Resumes sent to CP as part of an application for an advertised position, or sent generally to ascertain whether any positions are available, will be used to match applicants with available opportunities. If we consider that your application may be suitable to our current requirements, we, or a party acting on our behalf, will contact you to request that you attend an interview. We may also ask you to provide us with contact information for individuals who will act as professional and personal referees. We may contact these individuals and ask them questions we feel are relevant to your possible employment with us. We may contact you again to request that you attend further interviews or to inform you of whether we are able to offer you a position with us.
9.3 If your application is not suitable to our requirements, we will inform you and destroy or de-identify your application. If your application is not suitable to our current requirements, but we feel that there may be a position in the future for you with us, we will send you a letter informing you that we will keep a record of your application and may contact you again if a suitable position becomes available.
10. Service providers
10.1 We may share your personal information between different departments of CP and with third parties such as fulfilment houses and advertising agencies who assist us with our promotional, marketing and research activities. We impose obligations on any external organisations with which we share your personal information to maintain the integrity and security of that information.
11. Disclosure of information outside the jurisdiction of collection
11.1 We may disclose personal information outside of the jurisdiction from which it was collected. In the conduct of our business, we transfer to, hold or access personal information from various countries including Australia, New Zealand and the USA. The privacy laws of those countries may not provide the same level of protection as the privacy laws of the country from which the personal information was collected. However, this does not change our commitments to safeguard your privacy and we will comply with all applicable laws relating to the cross-border data disclosure.
12. Security of your personal information
12.1 We will endeavour to take all reasonable steps to keep secure any information which we hold about you, and to keep this information accurate, up to date and complete. We require our employees and data processors to respect the confidentiality of any personal information held by us.
13. Retention of information
13.1 When we no longer need to use your information, we will take steps to properly de-identify or destroy it.
14. Can you access and correct personal information that you have submitted to us?
14.1 If your personal information changes (such as your address), or if you no longer wish us to keep your personal information on file, we will endeavour to provide a way to correct, update or remove your records. We may charge you a small fee to cover any administrative costs that we may incur in providing personal information to you. If you believe for any reason that we are holding inaccurate or incomplete information about you, you may ask us to correct it. If you wish to have your personal information deleted, please let us know in the same manner as referred to above and we will take all reasonable steps to delete it unless we need to keep it for legal reasons.
14.2 If you wish to access, correct or update your personal information, please contact CP using the details provided in the section below entitled “CP contact details”.
15. Complaints about privacy
15.2 In most cases we will ask that you put your request in writing to us. We will investigate your complaint and will use reasonable endeavours to respond to you in writing within 30 days of receiving the written complaint. If we fail to respond to your complaint within 30 days of receiving it in writing or if you are dissatisfied with the response that you receive from us, you may have the right, depending on the jurisdiction, to make a complaint to the applicable regulator.
16. CP contact details
Care Pharmaceuticals Pty Limited
The Privacy Officer
PO Box 1674
Bondi Junction NSW 2061
Phone Australia: 1800 788 870
Fax Australia: +61 (0) 2 9387 6654