Privacy Policy

Last Updated: 21/5/2018

Welcome to PharmOut

Privacy and online safety are important to PharmOut. We offer consulting services, training (both offline and online) and downloadable templates to organisations that must meet regulations enforced by the Australian Therapeutic Goods Administration and equivalent government bodies in other countries that are members of the Pharmaceutical Inspection Co-operation Scheme. We collect data about organisations, their employees, suppliers and customers (“Data”) when they use our services and visit our websites (collectively, “Services”). This privacy policy describes how we collect, use and disclose that data.

In this privacy policy, we sometimes refer to “You”. “You” may be a visitor to one of our websites, a user of one or more of our Services (“User”), a customer of a User (“Customer”) or a supplier of a User (“Supplier”). We’ll do our best to clarify who we are referring to at various points in the policy. This policy does not apply to third-party websites, products, or services even if they link to our Services, and You should consider the privacy practices of those third-parties carefully.

If You disagree with the practices described in this policy, You should (a) take the necessary steps to remove cookies from Your computer after leaving our website, and (b) discontinue Your use of our Services.

We respect and are committed to protecting your privacy. PharmOut is bound by and intends to comply with the Australian National Privacy Principle (NPPs) contained in the Privacy Act 1988 (Cth) when dealing with personal information. For further information about the NPPs, you can visit the Australian Privacy Commissioner’s website at www.privacy.gov.au. PharmOut may rely on the related bodies corporate exemption and the employee records exemption in the Privacy Act and any other applicable exemption in the Privacy Act or other legislation. We also seek to comply with:

PharmOut uses and safeguards the information collected, as outlined in the below policy.

Who is collecting your data?

PharmOut is an Australian private company, headquartered in Melbourne, Australia. Our Australian Business Number is 85 117 673 766.

Overview

The Data we collect depends on how our Services are used. Sometimes we receive Data directly, such as when an account on our website is created, an application is made for a job or we receive an email. Other times, we get Data by recording interactions with our Services by, for example, using technologies like cookies. We also get Data from third parties, like our credit card processing suppliers.

The collection and use of data from a variety of sources is essential to our ability to provide our Services.

Data We Collect

  1. Personal Data. We call Data that identifies, or that could reasonably be used to identify, You as an individual as “Personal Data”. We collect Personal Data in different ways. For example, we collect Personal Data when an account is created on our training website, when a purchase is made from us, when a person registers for an event, when a person responds to PharmOut emails or surveys or when someone applies for a job with PharmOut. We also receive Personal Data from other sources, such as our partners, financial service providers, and publicly available sources. Personal Data does not include Data that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person. The Personal Data that we may collect includes:
         > Contact details, such as name, postal address, telephone number, email address;
         > Employment details, so as previous employers, roles and responsibilities
         > Other Personal Data, such as date of birth, tax file number and gender.
         > Opinions and questions, such as the comments made and questions asked at events and online.
  2. Other Data. We call Data other than Personal Data “Other Data”. We collect Other Data through a variety of sources. One of our sources for Other Data is cookies and other technologies that record Data about the use of our websites, websites that implement our Services, and the use of our Services generally. Other Data that we may collect include:
  3. Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the version of the Services You are using;
  4. Transaction data, such as purchases, purchase amount, date of purchase, and payment method;
  5. Cookie and tracking technology data, such as time spent on the Services, pages visited, language preferences, and other anonymous traffic data; and
  6. Company data, such as a company’s legal structure, product and service offerings, jurisdiction, company financial, human resources and GMP records and information provided as part of engaging our services.

 

How We Use Data

Personal Data

We and our service providers use Personal Data to: (i) provide the Services; (ii) detect and prevent fraud; (iii) mitigate financial loss or other harm to Users, Customers, and PharmOut; and (iv) promote, analyze and improve our products, systems, and tools. Examples of how we may use Personal Data include:

  • To verify an identity for compliance purposes;
  • To evaluate an application for a job;
  • To respond to inquiries, send service notices and provide customer support;
  • To process a payment to PharmOut and provide related customer service;
  • For audits, regulatory purposes, and compliance with industry standards;
  • To develop new products and services;
  • To send marketing communications;
  • To improve or modify our Services; and
  • To conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business.

 

Credit card information

PharmOut does not retain any credit card information entered on our websites. When purchasing from PharmOut  your credit card details are passed through a secure server using the latest encryption technology. All purchases are paid for on our merchant account website, stripe.com.  When you enter your credit card details, the information is used by Stripe to confirm your details and approve the payment. PharmOut does not receive your credit card information – only confirmation that the payment has been accepted.

Other Data

We may use Other Data for a range of different purposes, provided we comply with applicable law and our contractual commitments. In some countries (for example, European Economic Area countries), local legal regimes may require us to treat some or all of Other Data as “personal data” under applicable data protection laws. Where this is the case, we will process Other Data only for the same purposes as Personal Data under this privacy policy.

How We Disclose Data

PharmOut does not sell or rent Personal Data to marketers or unaffiliated third parties. We share Your Personal Data with trusted third parties, including:

  1. To PharmOut Service Providers. We share Data with service providers who help us provide the Services. Service providers help us with things like payment processing (i.e., banks, credit bureaus, payment method providers), website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing. We also use service providers to provide specialist skills and equipment in order to provide our Services.
  2. To Authorized Third Parties. We share data with parties directly authorized by a User to receive Data, such as when a User authorizes a third party to work on a project PharmOut has been commissioned to complete or when a User uses a third party service at a PharmOut event for the purposes of participating in the event. The use of Data by an authorized third party is subject to the third party’s privacy policy;
  3. To Third Parties. We will share Data with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
  4. Safety, Legal Purposes and Law Enforcement. We use and disclose Data as we believe necessary: (i) under applicable law, or payment method rules; (ii) to enforce our terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, You or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside Your country of residence.

 

Security

We use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If You have reason to believe that Your interaction with us is no longer secure (for example, if You feel that the security of Your PharmOut account has been compromised), please contact us immediately.

Choice and Access

You have choices regarding our use and disclosure of Your Personal Data:

  1. Opting out of receiving electronic communications from us. If You no longer want to receive marketing-related emails from us on a going-forward basis, You may opt-out via the unsubscribe link included in such emails. We will try to comply with Your request(s) as soon as reasonably practicable, as per the Australian Privacy Laws. Please note that if You opt-out of receiving marketing-related emails from us, we may still send You important administrative messages that are required to provide You with our Services.
  2. How You can access or change Your Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by signing in to Your account on our websites or by contacting us.

If emailing us Your request, please make clear in the email what Personal Data You would like to have changed. For Your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that You use to send us Your request, and we may need to verify Your identity before implementing Your request. We will try to comply with Your request as soon as reasonably practicable.

Retention Period

We will retain Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Data that forms part of a Good Manufacturing Practice (GMP) record, such as training records, will be retained for the period specified by the appropriate GMP regulation or guideline. Please note that we have a variety of obligations to retain the Data that You provide to us, including to meet GMP requirements. Accordingly, even if You close Your PharmOut Account, we will retain certain Data to meet our obligations. There may also be residual Data that will remain within our databases and other records, which will not be removed.

Typical retention periods for the personal data we most commonly receive are as follows:

  • Event registrations: We will typically keep the information you provide when registering for a PharmOut hosted event for five years after the last event you register for.
  • Emails: If you send us an unsolicited email we may retain it for 1 year, to facilitate any subsequent communications.
  • Resumes: If you apply for a job with PharmOut we may retain your resume and other information you provide for approximately 12 months. We may refer to this information in order to communicate with you about other job opportunities.
  • Data received as part of doing business with us: If you purchase Services or Products from PharmOut we will keep your information in our databases for approximately 5 years after date of completion of the last purchase. This allows us to respond to any subsequent requests for support or for further products and services. If any of the data forms part of a GMP record then we will keep it for 5 years or for the retention period specified in the relevant GMP regulation or guidelines, whichever is longer.

 

Use of Services by Minors

The Services are not directed to individuals under the age of thirteen (13), and we request that they not provide Personal Data through the Services.

Jurisdiction and Cross-Border Transfer

Our services are global and Data (including Personal Data) may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer Data to countries outside of Your country of residence, which may have data protection rules that are different from those of Your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that Your Data remains protected to the standards described in this privacy policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access Your Personal Data.

PharmOut as a Data Processor

We may collect, use and disclose certain Personal Data about Customers when acting as the User’s service provider, for example, if we have been commissioned to perform due diligence activities prior to a purchase by a User. Our Users are responsible for making sure that the Customer’s privacy rights are respected, including ensuring appropriate disclosures about third party data collection and use. To the extent that we are acting as a User’s data processor, we will process Personal Data in accordance with the terms of our agreement with the User and the User’s lawful instructions.

Updates to this Privacy Policy and Notifications

We may change this Privacy Policy. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services.

We may provide You with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if You are a User, by contacting You using the email address or mailing address we have in our records. You agree that electronic disclosures and notices have the same meaning and effect as if we had provided You with hard copy disclosures. Disclosures and notices in relation to this Privacy Policy or Personal Data shall be considered to be received by You within 24 hours of the time they are posted to our website or, in the case of Users, sent to through one of means listed in this paragraph.

Contact Us

If You have any questions about this Privacy Policy, please contact us at info@pharmout.net or at:

PharmOut Pty Ltd.
Unit 10, 24 Lakeside Drive
Burwood East, VIC 3151
Australia
Ph: + 61 3 9887 6412

Sensitive Information

Because email communications are not always secure, please do not include credit card or other sensitive Data (such as racial or ethnic origin, political opinions, religion, health, or the like) in Your emails to us.

Accountability

If you feel that PharmOut is not living up to its stated information policy, you may contact the Australian Privacy Commissioner. Their website is www.privacy.gov.au