Privacy policy
This Privacy Policy applies to personal information collected by Galderma Holding S.A. and its affiliated companies, including Galderma Australia Pty Ltd and sets out how we collect, store, use and disclose your personal information and how you can access and update your personal information or make a complaint.
We handle your personal information in accordance with its obligations under the relevant privacy legislation including the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).
WHAT IS PERSONAL INFORMATION?
Personal information is information or an opinion (whether it is true or not) about an identified individual, or an individual who is reasonably identifiable.
WHAT PERSONAL DATA DO WE COLLECT AND WHY?
Email campaign:
We only collect email addresses and statements of intent to ensure our email campaign remains relevant to you, the end user, providing information that is pertinent to your rosacea journey.
For us to hold your details, you must first double opt-in to the email campaign. All your data is stored securely on our third-party, cloud-based mail service platform. Depending on what statement of intent you have selected upon sign-up, we will ensure you only receive information that is relevant to that statement. A record of consent and how it was obtained will be stored on the same mail service platform.
Should you wish to delete (unsubscribe) yourself from the mailing list, simply check on the corresponding link in your email and we will permanently remove all personal data provided at the point of sign-up. We will not be able to add this back in, but should you wish to sign-up again, you can do so by following the process on the website as before.
Deletion is both an automated and manual process run through our mail platform provider. All notifications are automatically sent to our team of administrators who will then personally process your request. We will undertake this process within 30 days, and you will receive notification accordingly.
Downloading the appointment guide:
The site’s purpose is to provide you with an appointment guide that enables you to express and log the symptoms and triggers pertinent to your disease, enabling you to succinctly discuss the key areas that need treatment. However, the information collected is completely anonymized at the point of constructing the appointment guide. The PDF created is browser/session based and upon download, the anonymized data is collected and stored securely and used for information purposes only - to gain a better understanding of rosacea and the development of ongoing content and support materials. When you close the download window the PDF will be automatically deleted.
The legal basis for the collection and usage of personal data is consent.
PERSONAL DATA OF CHILDREN
This website is intended for adult use only, i.e. anyone 16 years of age or older. We do not knowingly collect personal data from anyone under the age of 16 through this website. We assume that any person who provides their personal data through this website is 16 years of age or older. If we learn that we have collected any personal data from a child under the age of 16, we will take steps to delete such information promptly.
DISCLOSURE OF PERSONAL INFORMATION
We may share your personal information with our affiliates and with other third parties, for example service providers, to provide support for our business functions and so that they may perform services on our behalf.
We may also disclose your personal information if we are required to do so by law, or if in our good faith judgment, such action is reasonably necessary to comply with legal processes, to respond to any claims, assist government and law enforcement agencies or regulators or to protect the safety or rights of Galderma, its customers, or the public.
The use, collection, storage and disclosure of your information described in this Privacy Policy may involve us disclosing your personal information to third parties in countries including Australia, New Zealand, Brazil, Canada, China, Switzerland and the United States. Where we disclose personal information to other countries, we are often subject to cross-border disclosure privacy requirements, which are designed to protect your privacy in these situations.
DATA STORAGE AND SECURITY
We take all reasonable technical and organisational measures to protect the personal information we hold against loss, unauthorised access, use, modification or disclosure, and against other misuse.
We store most information about you in computer systems and databases operated by either us or our external service providers.
We will only keep your personal information for as long as it is reasonably necessary taking into consideration our need to provide services to you and comply with legal requirements under applicable laws. This means that we may retain your personal information for a reasonable period after you stop using this website. When the personal information that we collect is no longer required, we will take reasonable steps to de-identify it or destroy or delete it in a secure manner, in accordance with best practice for document and data destruction.
Where we disclose personal information to a third party as specified above, any such third party must at all times provide the same levels of security for your personal information as we do, and, where required, are bound by a legal agreement to keep your personal information private, secure and to process it only on our specific instructions.
UPDATES TO THIS PRIVACY POLICY
We may periodically update this privacy policy. In this case, we will post updated versions on this website. If we make significant changes to our privacy policy, we will display a prominent notice of the change on this website so that users are aware of the change. A revised privacy policy will apply only to personal data collected after its effective date (see below).
ACCESS TO YOUR PERSONAL INFORMATION
You can request access to the personal information we hold about you by contacting us using the details listed below. We will deal with all requests for access as quickly as practicable. Requests for large amounts of information, or information which is not currently in use may require further time before a response can be given. If we cannot provide access to your personal information, we will provide you with the reasons why. There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).Depending on the nature of the request, we may charge for providing access to your personal information, however such charge will not be excessive.
If the personal information we hold about you is inaccurate, incomplete or not up to date you may request that we correct the information by contacting us using the details listed below.
HOT TO MAKE A COMPLAINT AND HOW COMPLAINTS WILL BE HANDLED
If you are concerned about a possible interference with your privacy or misuse of your personal information by us or if you have a complaint about the way in which we have handled any privacy issue, please contact us using the details listed below or by contacting Customer Services Call Centre on 1800 800 765 to obtain a Privacy Complaint form.
It is our policy to handle complaints in a timely, effective, fair and consistent manner. On making a privacy complaint to us, you will receive an acknowledgment letter or email within 5 business days. This communication will set out the name of the person responsible for handling your complaint and the expected response time to the complaint. We endeavour to make a decision on all written complaints within 20 business days after a complaint is received. If we need more time to respond to your complaint we will notify you as to the delay, the reasons for it and seek your agreement to a longer period.
If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC).
For more information about your right to privacy please visit OAIC’s website at www.oaic.gov.au.
HOW TO CONTACT US
Please contact us if you have any questions about this privacy policy or if you wish to exercise your privacy rights to your personal data.
Galderma
4/13B Narabang Way
Belrose, NSW 2085
Attention: Data Privacy Officer
Email Address: privacyofficer.au@galderma.com
(This is the “Controller” of the personal data)
Data Processor on behalf of Galderma for the campaign is:
Havas Life Medicom, part of the Havas Group
Ferry Works,
Summer Road,
Thames Ditton,
Surrey KT7 0QJ
Phone number:
+44 (0) 20 8481 8100 (This is the “Processor” of the personal data)