Privacy Policy New Zealand

Introduction
At Geistlich Pharma New Zealand Ltd (“Geistlich New Zealand”) your privacy is important to us. We are committed to ensuring that personal information we hold about you is held securely and that your privacy is protected. We collect and use personal information only to the extent permitted by law, particularly the Privacy Act, which Geistlich New Zealand is subject to. This policy explains how we handle personal information that we hold about you. It details the types of personal information we collect, how we may use that information and who we allow to access it. In addition to this policy we will on occasion provide you with specific privacy statements about how we use particular information that we collect from you. Your use of our website(s) or our services, your purchase of our products or your continual engagement with Geistlich New Zealand signifies implied agreement to this Privacy Policy. Please note that our website(s) may contain hyperlinks to third party websites that are not managed by us, and are therefore not subject to this Privacy Policy.

Personal Information
“Personal Information” referred to in this Privacy Policy consists of any information about an identifiable individual, as defined in the Privacy Act. Personal information includes an opinion about an identifiable individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.
Geistlich New Zealand collects and stores Personal Information about its customers, suppliers and medical and allied healthcare professionals. The Personal Information collected may vary depending on your particular interaction with Geistlich New Zealand but will be limited to the information necessary to record and manage our interaction with you or as permitted or required by law.

The Personal Information that Geistlich New Zealand collects is primarily related to our products and services. By providing your Personal Information to us and/or by continuing to engage with Geistlich New Zealand, you consent to your Personal Information being collected, stored, used and disclosed in accordance with this Privacy Policy. If we provide you (or an entity related to you) with credit, we may also collect and hold credit information and credit eligibility information about you. Without limitation, this may include credit reports, identification information, consumer credit liability information, details of amounts payable to us and the terms of the relevant credit, and information relating to payments made, default information and payment information.
If you provide us information about another person then you are responsible for making that individual aware that you have disclosed their personal information to us and that we can use that information as set out in this Privacy Policy.

Collection of information
It is Geistlich New Zealand’s usual practice to collect personal information directly from you. Personal Information may be collected from you in person, through websites operated by Geistlich New Zealand, by letter, facsimile, email or through telephone enquiries. Geistlich New Zealand may collect Personal Information (including credit information and credit eligibility information) from its
customers, suppliers and medical and allied healthcare professionals:

• when an order is placed for our products
• when a customer account is opened with us
• when a customer visit is undertaken
• in the course of responding to enquiries
• from adverse event reports; and
• from Geistlich New Zealand‐sponsored programs (e.g. trade events, conferences, retail events, membership programs, competitions or promotions, expert panels and educational seminars)

Geistlich New Zealand may collect Personal Information about prospective employees during the recruitment process to assess whether an applicant is suitable for a role with us. If you are not ultimately successful in securing employment with Geistlich New Zealand, your Personal Information collected during the recruitment process will be handled in accordance with this Privacy Policy.
Occasionally, we may also collect Personal Information about you from third parties. For example, we may collect Personal Information about you from an entity related to you or credit eligibility information about you from Credit Reporting Bodies (“CRBs”) if we provide you (or an entity related to you) with credit. 

The type of Personal Information we collect will depend on various factors such as the type of service you request or use and the applicable legal and regulatory obligations. Personal Information that may be collected about you includes: 

• your name and contact details (e.g. address, email, telephone number, business and professional details (if applicable) etc.)
• the nature of your enquiry; and
• other details about you that might be relevant

If you contact us by telephone, this information may be collected by Geistlich New Zealand as a recorded voice message where our staff are temporarily unavailable to answer a call and you choose to leave a voice message.
If we request information from you, you are entirely free to decide whether or not to supply this information. However, you acknowledge and agree that if you do not provide sufficient or adequate information, Geistlich New Zealand may not be able to provide you with its full range of products and services or may not be able to fully assist you with your enquiry. 
You should be aware that your use of our website(s) does not reveal your identity, unless you have chosen to register and log into our website.
Each time you visit our website, our web servers automatically save the name of your browser and operating system, your IP address, the website from which you accessed our website, the webpages you visit while with us and the date and time you spend on our website. Geistlich New Zealand’s servers save this information for security purposes. We may also evaluate anonymous or deidentified
data sets for statistical purposes, for example to aggregate user activity, which may be used by Geistlich New Zealand to provide insight on the usage of its website.

While Geistlich New Zealand takes reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk. Geistlich New Zealand makes no warranty (express or implied) in respect of data transferred over the internet. You acknowledge that the security of any personal information collected
via the internet is not guaranteed.

Use of information
Geistlich New Zealand will use Personal Information for the primary purposes for which it is collected or for other related purposes as permitted by law including but not limited to the following purposes, where applicable:

• to manage your product order(s)
• if we are providing you (or an entity related to you) with credit, to assess your creditworthiness (or the creditworthiness of your related entity which is receiving the credit)
• to maintain a record of medical enquiries, product complaints and adverse events and to comply with our reporting obligations to any relevant regulatory authorities. This information will also be used to monitor, assess and improve our products and services
• to provide further information regarding our products or services (including advice) that you have requested
• to provide you with material on our activities and products or that may be of interest to you, which you are entitled to opt out of receiving at any time
• to administer trade events, retail events, membership programs, competitions, promotions, conferences, expert panels, educational seminars, disease awareness or management programs or other programs organised or sponsored by us, which you agree to be involved with
• to notify you of matters that we are required by law to notify you of (e.g. product recalls)
• to monitor and prepare reports regarding the quality, safety and efficacy of our products
• to review our compliance with relevant regulations and codes of conduct
• to obtain feedback and customer satisfaction information to assist Geistlich New Zealand in improving its products and service offerings
• for our internal management and administration purposes, to manage our relationship with you and to manage the payment and recovery of amounts payable to us by you
• to statistically analyse the distribution of our products; and 
• to generate customer lists for the purposes of market research

Geistlich New Zealand may also use personal information for purposes directly related or incidental to the above, and for any other purpose authorised by you or permitted by law. Depending on the purposes for which your Personal Information is collected, Geistlich New Zealand may disclose your Personal Information for the purpose it was collected as set out in this Privacy Policy and as otherwise permitted by law. Accordingly, Geistlich New Zealand may disclose Personal Information to other parties (located locally and/or overseas) including to: 

• if we are providing you (or an entity related to you) with credit, CRBs, trade insurers and businesses assisting us with providing credit
• if you have provided us with referees to assist with a credit application, a job application or the assessment of a potential contract between you and us, the referees you have provided
• service providers that provide logistic, financial, legal, administrative or other services in connection with the operation of our business
• our head office based in Switzerland
• regulatory authorities, within or outside of New Zealand; and
• other entities as permitted or required by law

You acknowledge and consent to Geistlich New Zealand storing your Personal Information on storage or computer systems provided by third party suppliers. Geistlich New Zealand currently use cloud‐based solutions for our information systems, which includes Personal Information potentially being stored overseas. All reasonable steps will be taken to keep your Personal Information secure
(whether in New Zealand or overseas). When we engage a data storage provider, we use contractual arrangements to ensure those providers take appropriate measures to protect your Personal Information and restrict the uses to which they can put that information. Geistlich New Zealand may decide to change its third‐party storage provider and transfer your Personal Information to
the new provider at its discretion.

You acknowledge and agree that, Geistlich New Zealand may use or disclose your Personal Information:

• for other purposes for which you have provided your prior consent; or
• as required by or permitted under any law (including common law) or any direction of a Court or order of a Government authority or body

If you fail to make a payment to Geistlich New Zealand as and when due or commit a serious credit infringement, we may disclose details of such events to CRBs. A CRB may use such information in reports given to other credit providers to help assess your creditworthiness. Further, if you fail to make a payment to Geistlich New Zealand, we may disclose your details to a debt collection
agency to recover any outstanding debt.

Geistlich New Zealand will use de‐identified information within its business where possible. It may be used to satisfy Geistlich New Zealand’s corporate reporting obligations, in which case the de‐identified information will be sent to our related entities in Switzerland.

Cookies
Cookies are small data files which are placed on your computer by web servers when you visit certain websites. Geistlich New Zealand’s website(s) use cookies to allow us to identify regular visitors and collect information about your usage of our website(s). This enables us to provide a better and more relevant website service to you each time you revisit specific webpages. Geistlich New
Zealand also utilises third‐party plug‐ins which may create cookies that may collect information about your visit to our website. Cookies do not collect nor store any Personal Information and do not personally identify users, although they do identify a user's browser. Geistlich New Zealand does not have any control over, and therefore will not be responsible for, the content of the cookies
created by third party plug‐ins, the use made of any data collected by third party plug‐ins, or the security of that data. The cookies derived from the third‐party plug‐ins that we utilise do not collect any Personal Information. Most browsers are set to accept cookies automatically. However, you can turn off the ‘Save Cookies’ function or set your browser so that it informs you whenever cookies are transmitted.

Security
Your Personal Information is stored in secured premises or in electronic databases requiring usernames and passwords for access only by authorised staff members. Our security precautions are regularly updated and improved in line with technical developments. Unfortunately, no data transmission over the internet or storage facility can be guaranteed to be 100% secure. Accordingly, Geistlich New Zealand cannot provide absolute assurance that the information you provide to us will be secure at all times and you agree that Geistlich New Zealand will not be held, and you must not hold Geistlich New Zealand, responsible for unauthorised access to Personal Information where it has taken reasonable steps to protect and secure that information. Please note that Geistlich New Zealand will store your Personal Information on servers in Switzerland and other locations. If you provide Personal Information to us, you also consent to the transfer by us of your information to those servers for processing and storage. However, this does not change any of our commitments to safeguard your privacy to the standard required by the Privacy Act.

Access, Correction and Deletion rights
Geistlich New Zealand will endeavour to ensure that your Personal Information is accurate, up‐to‐date and complete. You are entitled to request access to your Personal Information held by Geistlich New Zealand. Geistlich New Zealand will respond to your request within 20 working days. Further, you may ask us to correct your Personal Information if you believe it to be out of date or incorrect.
To make such requests, simply contact Geistlich New Zealand’s Privacy Officer as set out below (“Privacy Officer”). We may charge you our reasonable costs of providing you copies of your Personal Information. Upon your reasonable request, Geistlich New Zealand will endeavour to provide you with access to or correct your Personal Information unless Geistlich New Zealand believes that denying access or correction is: 

• required by or permitted under and law (including common law) or any direction of a Court or order of a Government
• authority or body; or
• required for other legal reasons

If Geistlich New Zealand refuses your request to access or correct your Personal Information, it will provide you with written reasons
for its refusal. If you wish to stop receiving any communications from us and have your Personal Information deleted, please contact Geistlich New Zealand’s Privacy Officer, and we will take all reasonable steps to delete it, unless we need to keep it for legal reasons.
In addition, if you have any concerns about how your Personal Information has been collected, used or disclosed, you can contact Geistlich New Zealand’s Privacy Officer and we will do our best to address your concerns to ensure that you are satisfied that there have been no breaches of privacy laws in relation to any Personal Information we hold about you. Making a complaint
If you have any concerns about how your Personal Information has been collected, used or disclosed, and you wish to make a complaint about a possible breach of privacy laws, you can contact our Privacy Officer.
The Privacy Officer will investigate your concerns and take any necessary steps to resolve your complaint. We may need to contact you if we need further information to investigate your complaint and will advise you of the outcome of the investigation as soon as it is completed. We will endeavour to investigate and resolve your complaint within 30 days after receiving your complaint.

If you are not satisfied with the outcome of the investigation, you can contact us again to discuss your concerns, or you may complain to the New Zealand Privacy Commissioner via www.privacy.org.nz.

Hyperlinks to other Websites
Third party operators of websites which may be accessed via hyperlinks from Geistlich New Zealand’s website(s) may gather and store Personal Information as soon as you access their websites. You acknowledge and agree that Geistlich New Zealand cannot accept any liability for those third‐party operators in the event that your Personal Information is collected, used, disclosed or shared by them.We encourage you to read their privacy policies separately.

Amendments to Privacy Policy
Geistlich New Zealand reserves the right to amend this Privacy Policy at any time. Visitors to Geistlich New Zealand’s website(s), healthcare practitioners and other consumers of Geistlich New Zealand’s products and services are responsible for carefully reading this policy on a regular basis to inform themselves of any amendments that may have been made. You acknowledge and agree that the amended Privacy Policy will apply between all relevant parties whether or not Geistlich New Zealand has given you specific notice of any such change.

Questions
If you have any queries relating to our Privacy Policy, or if you have a problem or complaint that you would like to discuss with Geistlich New Zealand, please contact Geistlich New Zealand’s Privacy Officer by telephoning Customer Service on 0800 500 043, emailing info@geistlich.co.nz or by sending a letter to the Privacy Officer, Geistlich Pharma New Zealand Ltd, C/‐ Duncan Cotterill, Level 2, 50
Customhouse Quay, Wellington 6011,New Zealand.

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