Privacy Policy

Introduction

In this privacy policy (Privacy Policy), “we”, “us” and “our” means A. Menarini Australia Pty Ltd and its related body corporates. Please read this Privacy Policy carefully as it describes the way in which we collect and handle your personal information.

We may revise this Privacy Policy from time to time by providing a revised version on our Web site. Our revised Privacy Policy will take effect from the time it is posted on our Web site.

You have no obligation to provide any Personal Information requested by us. However, if you choose to withhold your Personal Information, we may not be able to assist you with the provision of our services.

For the purposes of this Privacy Policy, the words herein will have the same meaning as in the Terms of Use, except where otherwise expressly defined. For the purposes of this Privacy Policy, “Personal Information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable: (a) whether the information or opinion is true or not; and (b) whether the information or opinion is recorded in a material form or not.

Consent

By using or accessing this Web site, you agree to be bound by our Privacy Policy and Terms of Use. Whenever you submit Personal Information via this Web site (e.g. submission of testimonials in relation to our goods and/or services), you consent to our collection, use and disclosure of that Personal Information by us in accordance with this Privacy Policy.

The types of Personal Information we collect and hold

The types of Personal Information we collect generally include your name, age, email address and phone number. We may also collect sensitive information including health information but only in circumstances where you freely disclose such information to us in the course of our communications or through our surveys, questionnaires, feedback forms or the provision of testimonials. By providing any sensitive information, you consent to our collection of sensitive information where you have elected to submit such information to us. If you wish to withdraw such consent please contact our Data Protection Officer and cease to use our Web site.

How we collect Personal Information

We collect Personal Information from you through specific questions or allowing you to communicate directly with us via e-mail, surveys, questionnaires, feedback forms or the provision of testimonials.

We collect information about your visits to our Web site for system management, to improve the Content of the Web site, and for market research purposes. The information we collect may include your Personal Information. We collect this information when you access and navigate throughout our Web site including statistical data such as the date, time and specific page you visit using a range of technological means such as cookies, tags, web beacons and other navigational data collection tools.

Cookies are small text files that this Web site sends to your computer’s hard drive to identify the computer you are using. Tags are smaller than cookies and tell the Web site server information such as the Internet Protocol address and the browser types related to your computer. Web beacons are usually invisible to the user but are embedded in a web page or email that tracks whether a user has viewed a web page or email.

Most web browsers are automatically set to accept cookies. If you do not wish to receive any cookies on our Web site, you may set your browser to refuse cookies. However, this may affect the functionality of our Web site.

Why we collect, hold and use your Personal Information

1. to provide you with information about fungal nail infections upon your request; and
2. other related purposes.

How we disclose your Personal Information

We may disclose your Personal Information for a variety of purposes in connection with our business operations. These include:

1. to third parties:
   • for the rendering of services or conduct of legitimate business activity related to this Web Site;
   • to respond to your requests for customer services or products;
   • for the purpose of sending direct marketing materials; and/or
   • to protect and enforce our rights, property or personal safety;
2. to our competent legal and/or regulatory authority and law enforcement agencies:
   • in compliance with legal process, order of court and applicable law; and/or
   • to enforce our rights arising out of or in connection with the Terms of Use, Privacy Policy and any other contracts with you.
3. to our successors-in-title, prospective sellers or buyers of any part or the whole of our business, in connection with a merger, acquisition or sale of any part or the whole of our business.

Overseas disclosure of Personal Information

We are likely to disclose Personal Information, for the purposes described above, to organisations located in China, Hong Kong, India, Indonesia, Italy, South Korea, Malaysia, Philippines, Singapore, Taiwan, Thailand and Vietnam. We are currently building agreements with the overseas recipients to whom we disclose Personal Information which require them to comply with the Privacy Act 1988 (Cth) (including the Australian Privacy Principles).

Storage and Protection of Personal Information

We will take such steps as reasonable in the circumstances to ensure that Personal Information we collect, use and disclose is accurate, complete, up-to-date and relevant. We will take all reasonable steps to protect Personal Information in our possession or control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Notwithstanding the foregoing, please be aware that the Internet is not a completely secure or error-free environment. We cannot fully guarantee:

1. the confidentiality of any Personal Information you submit to us over the Internet;
2. that unauthorized persons will not view your Personal Information or emails; or
3. that your Personal Information will not be altered, corrupted or destroyed by third party circumvention of our reasonable security measures that have been in place to safeguard your Personal Information.

We urge you to minimize security risks by regularly updating your antivirus software.

Access to Personal Information

You may request in writing for us to provide you with access to your Personal Information in our possession or effective control and/or information about the ways in which your Personal Information has been or may have been used by us.

Please provide us with as much detail as you can about the particular information you wish to access in order to help us retrieve it. We may charge you an access fee to cover our costs of providing that information to you. We will inform you of applicable fees before they are incurred.

Any request for access to Personal Information pursuant to this clause shall be made in writing to our Data Protection Officer at the contact details set out below. We will respond to your request for access to Personal Information within a reasonable period after the request is made.

In certain circumstances, such as where the Personal Information relates to an on-going criminal inquiry, we may refuse your request to access your Personal Information. If we refuse you access, we will provide you with reasons for our refusal unless it is unreasonable for us to do so.

Update and Correction of Personal Information

You are entitled to request in writing that we update your Personal Information or to correct an error or omission in your Personal Information that is in our possession or control. Unless we are satisfied on reasonable grounds that a correction should not be made, we will take such steps as are reasonable in the circumstances to make such correction as soon as practicable to ensure the information is accurate, up to date, complete, relevant and not misleading.

Any request for update or correction of Personal Information pursuant to this clause shall be made in writing to our Data Protection Officer at the contact details set out below. We will respond to a request within a reasonable period.

If we refuse to correct the Personal Information as requested by you, we will provide you with a written notice setting out our reasons for refusal (unless it is unreasonable to do so) and the mechanisms available to you to lodge a complaint.

Retention of Personal Information

We may need to retain such records containing your Personal Information as may be necessary or desirable to comply with applicable law or regulation, and to retain such information as may be required to address disputes or establish our rights (whether such disputes or matters have arisen, or could arise in the future). Where we no longer need your Personal Information for any purpose for which the information may be used or disclosed, we will take reasonable steps to destroy or de-identify the information.

Withdrawal of Consent

If you would like to withdraw your consent given for collection, use, and disclosure of your Personal Information for the purposes set out in this Privacy Policy, please immediately refrain from and cease all usage of this Web site and provide us with reasonable notice of your withdrawal of consent in writing to our Data Protection Officer at the contact details set out below.

Third Party Web sites

This Web site may contain links or references to other web sites which are maintained by third parties over whom we have no control. This Privacy Policy does not apply to third party web sites.

Anonymous and pseudonyms

You may request to remain anonymous, or seek to use a pseudonym, in your dealings with us on the Web site. We will honour your request to stay anonymous or use a pseudonym where it is lawful and practicable to do so.

Complaints

If you would like to make a complaint about the way in which we handled your Personal Information, please write to our Data Protection Officer whose contact details are below. We aim to investigate and respond to complaints within a reasonable time after receipt.

If you are dissatisfied with our response to your complaint, you may contact the Office of the Australian Information Commissioner (OAIC) or contact the OAIC by phone on 1300 363 992.

Contact

If you have any questions or recommendations about this Privacy Policy, if you wish to update your Personal Information we hold about you or if you wish to make a complaint,

Email to: Privacy.officer@menariniapac.com
Write to: Privacy Officer
A. Menarini Australia Pty Ltd
Level 8, 67 Albert Avenue
Chatswood, NSW 2067 Australia

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