Privacy Policy
- Boehringer Ingelheim Pty Ltd (ACN: 000 452 308) of Level 1, 78 Waterloo Road, North Ryde, New South Wales 2113, Australia;
- Boehringer Ingelheim NZ Limited (NZCN: 88986) of Level 2, 3 Te Kehu Way, Mount Wellington, Auckland 1060, New Zealand;
- Boehringer Ingelheim Animal Health Australia Pty Ltd (ACN: 071 187 285) of Level 1, 78 Waterloo Road, North Ryde, New South Wales 2113, Australia; and
- Boehringer Ingelheim Animal Health New Zealand Limited (NZCN: 664734) of Level 2, 3 Te Kehu Way, Mount Wellington, Auckland 1060, New Zealand,
each of which is a part of the worldwide group of Boehringer Ingelheim companies (collectively referred to as Boehringer Ingelheim, we, our and us) are bound by and comply with, in Australia, the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), and in New Zealand, the Privacy Act 2020 (NZ) and the New Zealand Information Privacy Principles (IPPs)/any relevant codes of practice (as applicable).
Boehringer Ingelheim respects individual privacy and the rights of individuals to control their personal information. Boehringer Ingelheim and our third party contractors are bound by privacy laws in respect of the collection, use, disclosure and handling of your personal information.
Boehringer Ingelheim recognises the importance of your privacy and understands that the security of your personal information is important to you. We are committed to protecting the personal information you provide to us and which we collect from you.
This Privacy Policy sets out the basis on which Boehringer Ingelheim collects personal information and the basis on which any such personal information will be dealt with.
1. TYPES OF INFORMATION COLLECTED AND HELD
Personal Information
"Personal information" means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true and whether or not the information or opinion is recorded in a material form.
Boehringer Ingelheim collects and processes personal information about you for a lawful purpose connected with our functions or activities and the collection of the information is reasonably necessary for us to perform our functions and activities, including providing quality customer service to you.
Wherever it is practical, Boehringer Ingelheim will only collect your personal information where you have provided it to us voluntarily and knowingly. This means you are under no obligation to provide personal information to us, although a failure to provide all or some of the requested personal information in some circumstances may limit our ability to provide products, services or information to you or otherwise to do business with you.
The types of personal information that we collect includes:
- your name, email address(es) and other contact details;
- any questions or comments that you may post;
- information about you in relation to the goods and services we provide;
- if you are a healthcare professional, veterinary clinic personnel or a Boehringer Ingelheim third party contractor, we may collect your professional details (including but not limited to your curriculum vitae, qualifications, education and training records), your business details and details of the interaction we have with you;
- if you are visiting our websites, the IP address of your machine when connected to the internet and the domain name from which you are accessing the internet;
- if you are interacting with any of our websites for educational and/or training purposes, such website history in connection with any education and/or training you have been involved in;
- if you are accessing services via a web portal, platform or mobile application (a “Platform”), this may also include any personal information you have provided to us on a voluntary basis for the purposes of operating, providing, managing, maintaining and supporting the Platform. Your personal information is collected in accordance with any third party subscription agreements, terms of use, terms or service or any other agreements you have concluded, accepted and/or complied with as a condition for access to such services via the relevant Platform;
- if you are visiting or present at one of our sites or offices, video and still recordings of you, whenever you are in the field of vision of one of our on-site video cameras.
Boehringer Ingelheim may collect other types of personal information where it is necessary for us to take appropriate action in relation to a reasonable suspicion of unlawful activity or misconduct of a serious nature, that relates to our functions or activities.
Clinical trials Information
If you are a participant to a research study, the types of information collected, the purpose for collection and additional information on how we treat your data is explained to you during the informed consent process.
Sensitive Information
We may collect information that is considered "sensitive information" in Australia, such as information about your state of health and medical history. We will only collect sensitive information if you consent and the information is reasonably necessary for our functions or activities, or a relevant exemption applies.
Web Server Information
If you are visiting or interacting with any of our websites, or accessing services via a Platform, we may additionally collect web server information including but not limited to: the hardware ID of your hardware connected to your user account, the hardware ID of your terminal devices, your user ID, the date and time of your visit of the Platform, the sites that you visited on the Platform, the referrer website, your browser type, your operating system, and the domain name and the address of your internet access provider.
2. HOW WE COLLECT AND HOLD PERSONAL INFORMATION
Boehringer Ingelheim collects your personal information that you voluntarily and knowingly provide when:
- you purchase one of our products and you apply for a credit account with us;
- you access or interact with any of our websites, or access or use Boehringer Ingelheim services via a Platform;
- you subscribe to our social media accounts including those on Twitter and Facebook;
- you contact Boehringer Ingelheim in order to make an enquiry about Boehringer Ingelheim or a particular Boehringer Ingelheim product;
- you participate in Boehringer Ingelheim surveys, questionnaires or promotions;
- you attend one of our conference meetings or events;
- you participate in a Boehringer Ingelheim sponsored program (including but not limited to research study, compassionate use program, product familiarization program, patient support program, educational program, disease management program) as either a healthcare professional, a Boehringer Ingelheim third party contractor or a participant;
- you create an account and/or participate in any educational and/or training opportunities or resources offered by us;
- you visit or are present on our sites or offices, from our on-site video cameras, visitor management systems, sign-in books, or otherwise.
Boehringer Ingelheim will usually only collect personal information directly from you. We may also collect personal information from third parties (where it is unreasonable or impractical to collect personal information from you directly or where you have authorised collection from such third parties) or from publicly available resources. Where the collection of personal information is carried out on our behalf by external third parties such as, but not limited to, contractors, software vendors, data suppliers, and recruitment agencies, we will take reasonable measures to ensure that those third parties are aware of and comply with this Privacy Policy.
If you are visiting or interacting with any of our websites, or accessing services via a Platform, personal information may be automatically collected via cookies (i.e. small files placed or stored on your computer or mobile phone): (a) for essential purposes or providing basic features such as page navigation, access to secure areas within the website or Platform, or language settings; or (b) for analytical purposes to assess how you are using the relevant website or Platform so that we can adjust, optimise and improve the same. When accessing websites, you may disable cookies by adjusting the settings on your web browser, but this may affect full functionality of features of the website.
Boehringer Ingelheim takes reasonable steps to ensure that all personal information is kept secure in accordance with reasonable physical, electronic, and managerial procedures. However, for personal information collected online and stored in electronic databases, you acknowledge that no security system is impenetrable and that the security of those databases can never be guaranteed. Boehringer Ingelheim also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us is transmitted at your own risk. Nevertheless, once we receive your transmission, we will take reasonable steps to preserve the security of such information and ensure that there are appropriate security protections in place.
3. PURPOSE FOR WHICH WE COLLECT, HOLD, USE AND DISCLOSE YOUR PERSONAL INFORMATION
Boehringer Ingelheim will collect, hold, use and disclose your personal information only for the purpose for which you provide it to us.
We will not use or disclose personal information about you for any secondary purpose, unless you consent to that use or disclosure, or:
- if in Australia, you would reasonably expect the use or disclosure in the circumstances, and that secondary purpose is:
- in the case of non-sensitive information: related to the primary purpose for which we have collected that information, and
- in the case of sensitive information: directly related to the primary purpose.
- if in New Zealand, that secondary purpose is directly related to the primary purpose.
Furthermore, your personal information will not be shared, sold, rented or otherwise used or disclosed outside the Boehringer Ingelheim group of companies (except as required for any statutory or legal requirements) in ways different from what is described in this Privacy Policy.
The purposes for which Boehringer Ingelheim may use or disclose your personal information include:
- to provide you with any services or goods that you may request;
- to provide you with information in relation to educational materials, educational events and products in a field you have indicated is of interest to you or we think may be of interest to you (including providing you with information to assist you to keep track of your continuing professional development, if applicable);
- to respond to any query or complaint that you may make;
- investigate the behaviour, needs, attitudes, opinions, motivations or other characteristics of a whole population or particular part of a population;
- to determine the ways Boehringer Ingelheim products, services, promotional materials, educational materials and other information provided to you could be improved;
- to involve health professionals and investigators (and people who assist them) in clinical trials;
- for internal administration, product research, evaluation and development, and quality control purposes;
- to assist with investigating security breaches or any incidents that may arise on our sites and offices, and to otherwise ensure that we maintain a safe and secure working environment at our sites and offices;
- for other purposes to which you have consented; and
- for any other purposes required or authorised by law or a court/tribunal order or by a regulatory body.
Boehringer Ingelheim may disclose personal information it collects about you to:
- any entity within the group of Boehringer Ingelheim entities (within and outside of Australia and New Zealand);
- third parties within or outside of Australia and New Zealand engaged to help Boehringer Ingelheim improve its pharmaceutical products;
- third party contractors engaged to perform functions or provide services relating to the purposes for which we collect personal information as set out in this Privacy Policy. This may include third party software vendors located overseas;
- your employer (or other person that engages you to provide services), but only your personal information in connection with your participation in educational or training opportunities and resources offered by us;
- enforcement authorities and regulatory bodies, within and outside of Australia and New Zealand, and ethics committees as part of a clinical trial evaluation, monitoring and inspection process;
- any other parties it deems necessary in relation to providing you access to the Website.
Any disclosure of your personal information overseas will be done in accordance with applicable laws. See further information in the “Overseas disclosures” section of this Privacy Policy.
Boehringer Ingelheim may combine any information which it collects from you with information collected by any entity within the group of Boehringer Ingelheim entities or any third party contractors or service providers engaged to perform functions or provide services relating to the purposes for which we collect your personal information.
4. ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
Boehringer Ingelheim will take all reasonable steps to ensure any personal information we collect is up-to-date, complete and accurate. We will also take reasonable steps to ensure that any personal information that we use or disclose is up-to-date, complete, accurate, relevant and not misleading.
You have the right to request access to the personal information we hold about you, or request that your personal information be corrected if you believe for any reason that the information we hold is inaccurate, incomplete, or out-of-date, irrelevant or misleading, or ask for your personal information to be removed if you no longer wish Boehringer Ingelheim to keep your personal information on file.
Boehringer Ingelheim will take reasonable steps to provide a way to correct, update or remove your records. Boehringer Ingelheim may charge you a small fee to cover any administrative costs that we incur in providing you with access to your personal information. We will facilitate access (including through the use of an intermediary if necessary) unless we are required or authorised under any relevant law or court/tribunal order to withhold access. You can obtain further information about how to request access to or correct the information held about you by Boehringer Ingelheim by contacting our Privacy Officer:
Postal address: The Privacy Officer
PO Box 1969
Macquarie Centre NSW 2113
Telephone: + (61) (2) 8875 8800
Fax: + (61) (2) 8875 8801
Email: privacyofficer.syd@boehringer-ingelheim.com
5. COMPLAINTS ABOUT A BREACH
If you consider a breach of the APPs or the IPPs has occurred, you may direct your query to our Privacy Officer in the first instance at privacyofficer.syd@boehringer-ingelheim.com. We may require you to put your complaint in writing.
Our Privacy Officer will investigate the issue and take steps (if any) to resolve your complaint and will notify you in writing of the outcome of the investigation. You should allow us a reasonable time (usually 30 days) to respond to your complaint. If you do not consider our response satisfactory, you may contact us to discuss your concerns or contact the Australian Privacy Commissioner at its website https://www.oaic.gov.au/ or the Office of the Privacy Commissioner in New Zealand (as applicable) at www.privacy.org.nz.
6. OVERSEAS DISCLOSURES
We may, in the course of providing products and services to you, disclose personal information to overseas entities (including our group companies which are located overseas including but not limited to Singapore, USA, Spain and Germany) and external data processors/web hosting servers/web analytics service providers located outside of Australia and New Zealand (such as in the USA, Japan, Singapore and Germany). If we disclose your personal information to one or more of the aforementioned entities, any use of your personal information by the said entities will be done in accordance with their respective privacy policies.
The types of personal information that we are likely to disclose to overseas entities include (without limitation):
- your name;
- email address;
- physical address;
- de-identified sensitive information;
- information about you relating to the services and goods we provide you;
- professional and business details;
- information related to adverse events related to our products;
- information about your browsing activity; and
- use of any Boehringer Ingelheim Platform.
You acknowledge that where personal information is disclosed overseas to those third parties referred to above, the Privacy Act 1988 (Cth) and the Privacy Act 2020 (NZ) may not apply and those third parties may not be required to protect your personal information in a way that, overall, provides comparable safeguards to the safeguards we provide. If you would prefer that we did not disclose your personal information to third parties overseas, you may opt out of this sharing by contacting our Privacy Officer at privacyofficer.syd@boehringer-ingelheim.com.
7. CHANGES TO OUR PRIVACY POLICY
This is our current Privacy Policy and replaces any other privacy policy previously published by us. We may vary this Privacy Policy from time to time, including to take into account amendments to the applicable privacy legislation. If we make changes to this Privacy Policy we will publish an updated Privacy Policy on this website. We encourage you to review this website regularly to ensure that you are aware of our current Privacy Policy.
[Policy last updated June 2024]