Recordati Rare Diseases Group companies are constantly committed in respecting the privacy of individuals with whom they come into contact, in accordance with the Australian Privacy Principles (“APPs”) to the extent required by the provisions of the Privacy Act 1988 (Cth), the Privacy Act 2020 (NZ) and other applicable data protection laws to the extent that it applies to our operations.

 

This Privacy Policy provides you in your capacity as a professional in the medical-health sector (“Healthcare professional” or “HCP“) with the information necessary to illustrate how Recordati Rare Diseases Group (hereinafter, “Recordati Group” or “Recordati”) companies will process your personal data (“Data”) through our customer relationship management (“CRM”) system.

1.      Data Controllers, Data Protection Officers and Privacy Officers

The companies of the Recordati Group that process your personal data via the CRM system are the following. Each of them acts in its capacity as data controller, or as the entity otherwise responsible for processing any personal information collected from you:

 

Country	Entity	Registered office
Australia	Recordati Rare Diseases Australia Pty Ltd	Level 10, 100 Arthur Street, North Sydney NSW 2060, Australia
New Zealand	Recordati Rare Diseases Australia Pty Ltd]	Level 10, 100 Arthur Street, North Sydney NSW 2060, Australia

Your Data will be processed only by the company located in the country where you habitually exercise your professional activity for the purposes set out in this Privacy Policy. Without prejudice to the provisions of paragraph 7 below no other Recordati Group companies will process your Data.

The Data Protection Officer of the Recordati Group can be contacted using the following contact details: Data Protection Officer – DPO, Recordati S.p.A., Via Matteo Civitali 1, Milan – Italy; e-mail: .

2.      Types of Data Processed 

The Data that will be processed includes:

–        personal and identification data, such as name, surname, professional title, registration in the register of doctors, specialty(ies), gender;

–        Contact data, such as e-mail address, phone number, professional address;

–        Interactions with Recordati such as meetings held and email exchanged;

–        Information on the HCP profile, such as whether the HCP is a regional, national or international expert on a certain field and the level of awareness on certain products.

3.      Method of collection of information

Recordati collects information from you in a number of ways which include the following:

–        directly from you when you provide information via mail, email, SMS or phone;

–        when you sign up or complete forms or subscribe to our services;

–        from publicly available sources of information;

–        when you provide information through our website;

–        from third parties but only in circumstances where that third party warrants to us that they have complied with the Australian and New Zealand privacy laws and you have consented to your personal information being used and disclosed to organisations such as ours.

If Recordati receives personal information being unsolicited personal information that we did not request, and cannot be collected under the APPs, then we will undertake to reasonably destroy and de-identify the personal information within a reasonable period of time.

4.      Purposes and legal basis of the processing

Recordati processes your personal data for the following purposes and sets out the corresponding legal bases below:

#	Purpose of processing	Basis
1	To carry out scientific information activities on our products and related tasks (such as, by way of example, the presentation of medicines, the collection of requests and the supply of samples, as well as activities aimed at planning visits, orientation, guidance and monitoring of scientific information activities), in clinics, doctors’ offices and hospitals where HCPs carry out their professional activity as well as via remote channels.	The processing is based on Recordati legitimate interest in planning, carrying out and optimizing scientific information activities. The provision of the Data for this purpose is optional and you may exercise your right to object to this processing at any time by contacting the relevant data controller or Group DPO.
2	To send scientific information communications on drugs and products marketed by the Recordati Group through e-mail, phone or other digital or web-based communication tools (including sending communications on medical and promotional activities, research projects, awareness materials, invitation to participate in congresses, conferences or medical-scientific meetings, webinars and training events and similar future services). You can provide your preferences on the means of contact directly to our field force.	The processing is based on your prior consent. The provision of the Data for this purpose is optional and, if we do not have your consent, you will not be contacted for scientific information communications. You can withdraw your consent at any time, by contacting the data controller or the DPO at the addresses indicated above.
3	Carry out profiling activities based on the expertise of an HCP and the HCP’s awareness on certain treatments or diseases, in order to better plan our activities, prioritizing efforts and tailoring our approach.	The processing is based on Recordati legitimate interest in planning and carrying out scientific information activities. The provision of the Data for this purpose is optional and you may exercise your right to object to this processing at any time by contacting the relevant data controller or Group DPO at the addresses indicated above. In the event of objection to the processing, we inform you that you may still receive general medical and scientific information and content from Recordati.

5.      Direct marketing

We may use your personal information for our direct marketing purposes.

If you do not wish to receive any of these materials, please:

–        contact our Data Protection Officer at to opt out; or         

–        follow the prompts in the communication which will provide a method for opting out.

You can change your mind about receiving our marketing materials or information at any time by contacting us. We will not sell, license, trade or provide your information to another person for direct marketing purposes.

We will not disclose your information to any third party for their direct marketing purposes unless you have provided us with your express consent.

6.      Data retention period

The Data will be stored for 5 years from the registration in our systems. Once the retention period has passed, we will delete your data unless you confirm to us that you would like to be kept in our systems for an additional period of time.

7.      Data recipients – Data transfer to third-party countries/international organizations

Our authorized personnel may have access to your Data. In addition, your Data may be shared or made accessible to the following recipients or categories of recipients, in their capacity as independent data controllers or data processors specifically selected and appointed by the data controller on the basis of a specific contract:

–        Affiliates of the Recordati group, notably Recordati Rare Diseases S.a.r.l. and Recordati S.p.A. for administrative purposes;

–        Third-party suppliers of platforms for customer relationship management (CRM) and related technical assistance and maintenance services; 

–        Third-party suppliers for the management and organization of trainings and events;

–        competent authorities for their institutional purposes.

The complete list of recipients can be requested by contacting the data controller at the addresses indicated above.

Recordati will not otherwise disclose your personal information to a third party unless you have provided your express consent.

Should your personal information be transferred overseas, Recordati will take appropriate steps to ensure that the recipient party of the personal information has in place data handling and security arrangements that are either in line with or more stringent than the Australian and New Zealand privacy laws, or that we have a contractual arrangement that ensures the recipient shall comply at a minimum, to the Australian or New Zealand privacy laws.

For the full list of countries where data may be transferred and the legal basis for such a transfer, please visit the following page.

For further information about the applicable safeguards, you can contact us at .

 

8.      Automated Decision-making

 

Recordati will not use or disclose any personal information in any open-sourced automated decision making, or generative application (e.g. ChatGPT). If at any time this changes, we will update this information notice accordingly.

9.      Your rights

The Recordati Group companies inform you that:

a.            you have the right to request access to Data together with information on the processing purpose, category of data processed, subjects or categories of subjects to whom they have been or will be communicated;

b.            you also have the right to obtain:

        i.    the correction of your data, if it is incorrect or incomplete;

        i.    the erasure of the Data, in certain circumstances;

       ii.    the restriction of the processing of your Data;

      iii.    the Data is in a structured, commonly used and machine-readable format, also in order to send the Data to another data controller if the processing is based on consent or on a contract and is carried out by automated means (so-called data portability right). If you are interested, you can ask the Data Controller to send the Data directly to the other data controller if this will be technically feasible.

c.             You have the right to object to the processing of the Data, in certain circumstances, unless there are legitimate reasons for the Data Controller to proceed with the processing.

d.            You have the right to withdraw the consent given at any time for the purposes described in paragraph 4 above, without prejudice to the lawfulness of the data processing based on consent and carried out before the withdrawal.

Any correction or erasure of the Data or processing restrictions made upon request – unless this proves impossible or involves a disproportionate effort – will be communicated to each of the recipients to whom the Data may have been transmitted in accordance with this policy.

The exercise of the previous rights is not subject to any form of constraint and is free of charge. We may only ask you to verify your identity before taking further action upon your request.

You may exercise your rights by sending a written communication to the Data Protection Officer of the Recordati Group at .   

10.   Complaints handling

If you wish to make a complaint about the collection, use, or disclosure of your personal information, please contact our Data Protection Officer at .   

In Australia, if you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner via an online form, via mail or fax, following the process in the “Lodge a privacy complaint with us” page of the website at: https://www.oaic.gov.au/privacy/privacy-complaints/lodge-a-privacy-complaint-with-us#section-how-to-lodge-a-complaint-with-us.

In New Zealand, if you are not satisfied with our response, you may lodge a complaint with the Office of the Privacy Commissioner via an online form or via mail following the process in the “Complain to the Privacy Commissioner” page of the website at: https://www.privacy.org.nz/your-rights/making-a-complaint-to-the-privacy-commissioner/