Effective 2 August 2022
Pfizer Australia Pty Ltd and its Australian affiliates (separately and together, 'Pfizer') are bound by the Privacy Act 1988 (Cth) (Act) and will only collect and use personal information in accordance with the Act and this Policy.
Pfizer believes that choice is one of the most important privacy principles. You have the choice not to submit personal information (other than as may be required by law) to us although this may result in us being unable to provide products and services to you or reduce your ability to fully participate in all aspects of our web sites and apps. We will inform you if it is possible for an interaction to occur on an anonymous basis and, where it is, it will be optional for you to provide personal information.
DATA WE COLLECT AND USE
Pfizer may collect personal information about you through all of our interactions with you. Generally, Pfizer may keep a record of your name, contact details (i.e. address, telephone number, etc), and when collecting personal information for business purposes your professional details (e.g. qualifications, speciality, areas of interest), details on your practice/business (e.g. size, use of products, prescribing practices) and details of your dealings with us. Pfizer may also collect some health information if you register for particular patient support programs. Other information may be collected from other sources but those sources will provide details of what personal information is being collected and why.
When you post data or materials on public forum message boards, chat, profile pages, blogs and other services, you acknowledge that this information may be available to the general public.
By way of example, without limitation, Pfizer may collect information about:
Healthcare Professionals (e.g. doctor, nurse, pharmacist etc.) in the course of:
o responding to product queries;
o meetings with our sales representatives;
o complying with our regulatory obligations (e.g. notification of important product safety information or recording reporter details for adverse event reporting); and
o participation in Pfizer sponsored programs (e.g. clinical trials, expert panels, educational programs, research grants and disease management programs).
Members of the general public in the course of:
o using our customer or product information services;
o participation in non-prescription product promotional activities; and
o participation in Pfizer sponsored programs (e.g. clinical trials, educational programs and disease management programs).
Service providers in the course of:
o providing services to Pfizer; and
o completing due diligence questionnaires.
Pharmacy customers in the course of:
o Fulfilling orders through PfizerDirect.
The personal information collected may vary depending on your particular interaction with Pfizer but will be limited to that information necessary to record and manage our interaction with you or as permitted or required by law.
In addition, Pfizer may gather information about you automatically through your use of our web sites and apps (e.g. your Internet Protocol ('IP') address and how you navigate our web sites or device location). See also the section below on cookies and other tools.
HOW WE USE AND DISCLOSE PERSONAL DATA
Pfizer uses the personal information we collect for the primary purposes for which it is collected, other related purposes or as permitted or required by law including the following purposes:
- maintaining a record of medical queries, complaints and adverse event or adverse reaction reports relating to our products and reporting these to relevant regulatory bodies, such as the Therapeutic Goods Administration, as may be required;
- to enforce our terms and conditions;
- to provide health products or services (including advice) that have been requested;
- sending you material on our activities and products or developments in pharmaceutical treatments that Pfizer believes may be of interest to you and tailoring marketing services to suit your needs;
- administering conferences, symposia, expert panels, seminars or other similar programs organised by us, which you agree to participate in or be involved with;
- administering disease awareness/management programs or other similar programs organised by us, which you agree to participate in or be involved with;
- to involve doctors/investigators (and people who assist them) in clinical trials;
- to comply with legal obligations such as notifying you of matters that we may be required by law to notify you of (e.g. product recalls);
- to conduct due diligence with respect to our service providers;
- managing, planning and arranging meetings between healthcare practitioners and our sales representatives;
- managing and administering our PfizerDirect service for pharmacies;
- monitoring and reviewing our compliance with relevant regulations and codes of conduct in our dealings with you and monitoring the quality, safety and efficacy of our products;
- to gain insights in to how Pfizer's products are prescribed and used in practice; and
- generating customer lists for the purposes of market research.
For any of the above purposes, Pfizer may disclose your personal information to:
- its affiliates within or outside of Australia or the United States (a full list of Pfizer Global Affiliates and their locations is available here, in which case your personal information will be collected, used, disclosed, managed and stored in accordance with this policy;
- third parties within or outside of Australia (Pfizer's service providers are mainly located in the USA, Europe, Singapore, China, India, Costa Rica and New Zealand). However from time to time we may need to engage a service provider in a country not identified. A list of all countries where we may send your information can be found here; and
- regulatory authorities, within or outside of Australia, and ethics committees as part of a clinical trial evaluation, monitoring or inspection process.
As Pfizer changes and grows Pfizer might buy or sell companies, subsidiaries or assets and generally, customer information is one of the transferred business assets, particularly if Pfizer or substantially all of its assets are acquired. We may disclose personal data to companies that were formerly wholly or partly included in the Pfizer family of companies to which we provide services during a transition period following separation.
Generally, we require that third parties who handle or obtain personal information as service providers to Pfizer acknowledge the confidentiality of this information, undertake to respect an individual’s right to privacy and comply with the Act and this Policy. However, you acknowledge that, by agreeing to the disclosure of your personal information to these third parties operating outside of Australia, we will no longer be required to take reasonable steps to ensure the overseas third parties' compliance with the Act (including the privacy principles) in relation to your personal information and we will not be liable to you for any breach of the Act by these overseas third parties and on this basis you consent to such disclosure.
From time to time, Pfizer may collect or solicit personal information from a third party using available resources, either from where you would reasonably expect it (including, without limitation, publicly available information) or where you have previously consented to personal information being shared, for Pfizer's own internal use.
Security of personal information
Pfizer takes reasonable precautions to protect your personal information from loss, misuse, alteration disclosure or interference and unauthorised access.
While we endeavour to keep information on Pfizer web sites, including the personal information provided by you or on your behalf, secure and confidential, we will not be responsible for any breach of security caused by third parties and do not represent that Pfizer websites are completely secure.
Pfizer has directed its staff that personal information must be dealt with in accordance with this Policy and kept secure from unauthorised access or disclosure. We will limit access to personal information to Pfizer personnel on a need to know basis. We educate our staff about their duty to protect your privacy and provide training regarding this Policy.
In the aggregate/de-identified
Pfizer may also disclose aggregate or de-identified data that is not personally identifiable with third parties. Aggregate data is created by pooling information about individuals and describing the data in the aggregate (e.g. 20% of customers who clicked on the X promotion participated in the promotion).
COOKIES AND OTHER TOOLS
Pfizer and its business partners, in common with many web site operators, may use standard technology called cookies on its websites. Cookies are small data files that are downloaded onto your computer when you visit a particular website. Cookies help provide additional functionality to the web site or to help us analyse site usage more accurately. We use information collected from cookies to better understand, customise and improve user experience with our websites, services and offerings, as well as to manage our advertising. For instance, our server may set a cookie that keeps you from having to enter a password more than once during a visit to one of our sites. Also, we may use web analytics services that leverage cookies to help us to understand how visitors engage with and navigate our site (e.g. how and when pages in a site are visited and by how many visitors).
We are also able to offer our visitors a more customised, relevant experience on our sites using cookies by delivering content and functionality based on your preferences and interests. If you have provided us with personal information (e.g. through a registration or a request for certain materials), we may associate this personal information with information gathered through cookies. This allows us to offer increased personalisation and functionality.
In all cases in which cookies are used, the cookie will not collect personal information except with your explicit permission. Your web browser can be set to allow you to control whether you will accept cookies, reject cookies or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognise you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to precent your browser from accepting cookies.
In addition, we may use other tracking systems like pixel-tags. Pixel tags, sometimes called web beacons, are similar in function to cookies but because of their insignificant size, they are not visible. However, they are used to pass certain information to our servers to personalize our websites and to track your usage across other Pfizer websites. In addition, we may also use pixel tags in our HTML based emails.
For more information about cookies, visit www.aboutcookies.org
Unless specified in the individual app, Pfizer does not collect or use personal information about a user of its mobile apps. Pfizer’s mobile apps use data analytics to understand how the app is used, optimise user engagement with the app and customise and enhance user experience as well as ensuring the app functions properly.
This information may include:
- Data about your device, such as screen resolution, device manufacturer and model, and language. We use this data to ensure the app functions properly.
- Data about your use of the app, including content viewed, features used and dates and times of interactions. We use this data to understand how users engage with the app to customise and improve the app experience.
- We may collect your IP address along with the time of the visit. We use this to calculate usage levels, diagnose server problems and administer the app. We may also derive your approximate location from your IP address.
- We collect the physical location of your device to provide you with location-based services and content. You may be able to allow or deny such collection and/or use through your device settings.
You may stop all collection of data by the app by uninstalling the app.
ONLINE BEHAVIOURAL ADVERTISING
Pfizer hopes to deliver to you advertising for products and services you need or want. There are many ways to do this in the online advertising world. For example, Pfizer partners with websites with whom you have shared your interests, condition and concerns directly and asks that they serve our ads to users who have expressed an interest in Pfizer products or health conditions that our products treat. We may also partner with advertising companies to serve you ads based on your web browsing activity, purchases and/or interests. Some techniques for delivering content based on your interests are referred to as online behavioural advertising (“OBA”).
You can read more about OBA at a site offered by the Office of the Australian Information Commissioner at https://www.oaic.gov.au/privacy/your-privacy-rights/advertising-and-marketing/targeted-advertising/
We want it to be easy for you to understand how we and our business partners use information to serve ads tailored for you and to opt-out from targeting based on OBA. We, therefore, offer plain English explanations for our practices in this Policy. We also provide you with an easy-to-use means for opting-out from the use of your information for OBA. If you have any questions about our use of OBA, please do not hesitate to contact our Privacy Officer (see contact details below).
ACCESSING AND UPDATING PERSONAL INFORMATION PFIZER HOLDS ABOUT YOU
Pfizer has appointed a Privacy Officer to oversee Pfizer’s management of personal information in accordance with this Policy and the Commonwealth Privacy Act. The Privacy Officer’s contact details are set out below.
You can, in most cases, access the personal information Pfizer holds about you. If you wish to do so, please contact the Privacy Officer.
Pfizer endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. Please contact the Privacy Officer if you believe that the information Pfizer holds about you requires changing or becomes out-of-date.
PERSONAL INFORMATION OF MINORS
If you are providing us with Personal Data of individuals under the age of eighteen (18), you represent that you have the appropriate authority to do so and can demonstrate such authority to Pfizer upon request.
If you have questions about Pfizer and privacy, wish to provide feedback about this policy, would like to update your personal details held by Pfizer, wish to access information held by Pfizer about you or wish to make a privacy related complaint please contact Pfizer Australia’s Privacy Officer at:
Phone: (02) 9850 3333
Postal address: The Privacy Officer
Pfizer Australia Pty Ltd
GPO Box 7015
Sydney NSW 2000