This Privacy Policy applies to personal information collected by Galderma Australia Pty Ltd (ABN 12 003 976 930) (Galderma) and sets out how Galderma collects, stores, uses and discloses your personal information and how you can access and update your personal information or make a complaint.

Unless otherwise notified to you that your personal information will be used in a particular way (for example, in a website or form seeking personal information from you), all personal information collected by Galderma is held and used in accordance with this Privacy Policy.

Galderma handles your personal information in accordance with its obligations under the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act).

You consent to Galderma collecting, holding, using and disclosing your personal information in accordance with this Privacy Policy.

1. Personal information

Personal information is defined in s 6(1) of the Privacy Act as information or an opinion (whether it is true or not) about an identified individual, or an individual who is reasonably identifiable.

2. How personal information is collected

This Privacy Policy applies to personal information of individuals that Galderma collects via an individual’s interaction with Galderma including via the following:

Galderma websites - any customer-directed websites operated by Galderma, including Galderma owned websites and websites that we run on third party social networks such as Facebook (e.g. Facebook fan page), Instagram or Twitter.

Galderma mobile sites/apps - any customer-directed mobile sites or applications operated by Galderma, including our smartphone apps (e.g., iPhone apps).

Galderma text messaging programs - any customer-directed text messaging programs operated by Galderma which may be advertised on one of our websites or applications or in a print ad.

Hardcopy forms - including hardcopy registration cards or competition entry forms that we may collect from individuals via post, in-store demos, or other events and credit application forms for business customers (as governed by the Galderma Credit Reporting Policy).

Customer Services call centre - any personal information that we may collect from customers through our Customer Services call centre, for example if you call us with a question or comment or to sign up for marketing communications over the phone.

Social networking sites - any personal information that we may collect when you interact with third party social networking features such as “Facebook Connect”. These features may be integrated in our sites or applications. If you use these features, we may have the ability to obtain certain information about you from your social networking profile.

Data from third parties – in most instances, Galderma collects personal information directly from you. However, Galderma may obtain personal information about you from other sources such as third party data aggregators engaged to provide us with additional information about our existing customers or from third parties with whom we may occasionally partner with to run promotions. We may also receive information about individuals when we acquire other companies, or when we consider business customer credit applications.

3. Kinds of personal information held by Galderma

Galderma only collects personal information that is reasonably necessary for one or more of its business functions. We may combine personal information that we collect via one method (e.g., a website) with personal information that we collect via another method (e.g., an offline event). We do this to get a more complete view of our customers, which, in turn, allows us to serve you better and with greater customisation. Personal information collected includes the following:

Personal contact information - any information that would allow us to personally contact you, such as your name, home or mailing address, phone number or email address.

Account login information - any information that is required for you to establish a unique account with us or for us to give you access to your specific account profile.

Demographic information - any information that describes your demographic or psychographic characteristics, such as your, age or age range, gender, geographic location (e.g., post code, city and state, mobile location), favourite products, hobbies and interests, and household or lifestyle information.

Technical computer information - any information about a computer system or other technological device that you may be using to access one of our websites or applications, including your IP address, browser type and operating system.

Website usage information - any information about how you use and navigate our websites and applications, including which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions with a Galderma website or application (e.g., date and time of visit, which site you came from, and site activities, etc.).

Customer feedback - any information that you voluntarily share with us about your experience in using our products and services, including our websites and applications. Examples may include unsolicited comments and suggestions, testimonials, or other questions or feedback related to our products.

Customer-generated content - any content that you create and then share with us and perhaps others, by uploading it to one of our websites or applications, including those websites that we run on third party social networks.

Social network information - any information that is part of your profile on a third party social network (such as Facebook) and that you allow the third party social network to share with us (examples: name, email address, gender, birthday, profile picture and any other information you allow to be shared). We may use this information to match information with a social network for advertising purposes.

Payment information - any information that you use to make a purchase, such as your credit card details (cardholder name, card number, expiration date, etc.) or other forms of payment (if such are made available).

Children under 17 - In general, Galderma products are not directed at children and most of the online services that we offer are designed for individuals who are 18 years of age or over. In certain circumstances promotions are open to children aged between 13 and 17 years old, in this case, these children will be instructed to seek their parent or legal guardian’s consent before providing their personal information for the purposes of entry into the promotion. Galderma does not knowingly collect personal information from children below the age of 13. If we discover that we’ve accidentally collected information from a child under the age of 13, we will remove that child’s information from our records as soon as feasibly possible. Galderma may collect personal information about children below the age of 17 from the parent or custodian directly.

4. The purposes for which personal information is collected

Galderma may collect and use your personal information for some or all of the following purposes. Please note that not all of the uses below will be relevant to every individual.

Marketing communications - Where you have opted-into receiving marketing communications about Galderma we may collect and use your personal information to keep you up to date with the latest news, events, special offers and promotions of our brands including as follows:

• General marketing communications- to send you communications such as emails, SMS text messages and postal mailings.
• Targeted advertising- to show you marketing communications on other websites, including on social media sites where you are a member (such as Facebook), by matching activities or information collected on our websites with those collected on third party sites (ie data-matching).

You can always opt-out from receiving marketing communications by following the unsubscribe instructions provided in each such communication or by contacting our Customer Service Call Centre on 1800 800 765.

You may also visit social media sites where you are a member to explore opt-out options they may provide for targeted advertising. Please note that even if you opt-out from receiving marketing communications from us, you may still receive administrative communications from us (such as order confirmations, notifications about your account activities). You will also still see generic ads on other websites, including on social media sites where you are a member.

Account maintenance- We may collect and use your personal information to maintain your accounts with us, including administering any customer loyalty or rewards programs that are associated with your account.

Customer service- We may collect and use your personal information to provide you with customer service, including responses to your inquiries, complaints and general feedback about our products. Customer service may be provided through various forms of communication, including via email, telephone and online chat features.

Product improvement and customisation- We may collect and use your personal information so we can constantly improve our products, tailor them to your needs, and come up with new product ideas and inform you of any changes to our products.

Consumer engagement- We may collect and use your personal information to get you more actively engaged with our products and services (including our websites and applications), thereby increasing overall brand engagement and awareness. This mostly involves the collection, use, and publication of customer-generated content.

Promotions and competitions- We may collect and use your personal information for promotions, giveaways, competitions, or other similar marketing campaigns. These events typically require the collection and use of personal information (for eligibility, prize fulfilment etc.) To comply with legal requirements, we may publish or share a limited amount of personal information (such as name and city of residence) about the winners of a particular promotion. For more information about our contests and other promotions, please see the official terms and conditions applicable to each promotion.

Website improvement and personalisation- We may collect and use your information to improve and personalise your experience on our websites and applications. This is typically done through automated tracking technologies (such as cookies) that collect and remember certain account login information, technical information and website usage information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our website for any of your future visits to the website. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the website. You may refuse to use cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of the website.

Order fulfilment- We may collect and use your personal information to process and ship your orders, and to inform you about the status of your orders.

Other general purposes (e.g., website security, internal research, surveys) - We may collect and use your personal information for other general business purposes, such as to maintain the day-to-day operation and security of our websites and applications and to conduct internal marketing, demographic studies and contact you for consumer research.

5. Disclosure of personal information

Subject to the paragraphs below, Galderma will not disclose your personal information with any third party that intends to use it for direct marketing purposes unless we have specifically informed you and you have given us specific permission to do this.

We may share your personal information with our related companies in the Galderma Group, including Galderma companies in Switzerland and New Zealand.

Galderma may also share your personal information with other third parties, but only in the following circumstances:

Service Providers, Agents and Contractors - We may use third parties, like service providers, agents or contractors to provide support for our business functions and so that they may perform services for us on our behalf (such as internal operations of our websites and applications, database or website hosting, including cloud infrastructure, handling houses, promotions agencies etc). Your personal information may be accessed by Galderma’s service providers located outside of Australia in countries including Switzerland and New Zealand or be stored by them in such countries.

Partners and Joint Promotions - From time to time, we may run a joint or co-sponsored program or promotion on our website or application with another company, and, as part of this event, collect and process personal information. Your personal information will only be shared with a third party if you have consented to opt-in to receive information directly from that third party company.

Legal requirements and business transfers - We may also disclose your personal information if we are required to do so by law, or if in our good faith judgment, such action is reasonably necessary to comply with legal processes, to respond to any claims, assist government and law enforcement agencies or regulators or to protect the safety or rights of Galderma, its customers, or the public.

In the event of a merger or acquisition of all or part of Galderma by another company, or in the event that Galderma were to sell or dispose of all or a part of the Galderma business, the acquirer would have access to the information maintained by that Galderma business, which could include personal information.

Aggregate Information- We may share aggregated demographic or survey information with third parties, but this information is in anonymous form and does not contain any personal information. The aggregate information that we share may include anonymous information that is captured through the use of cookies and other similar tracking technology.

The use, collection, storage and disclosure of your information described in this Privacy Policy may involve us disclosing your personal information to third parties in countries including:
Australia, New Zealand, Argentina, Austria, Brazil, Canada, Chile, China, Colombia, Czech Republic, Denmark, Finland, France, Germany, Hong Kong, India, Italy, Japan, Korea, Mexico, Middle East, Netherlands, Norway, Poland, Portugal, Russia, Spain, Sweden, Switzerland, Taiwan, Thailand and the United States.

Where we disclose personal information to other countries, we are often subject to cross-border disclosure privacy requirements, which are designed to protect your privacy in these situations.

6. Data storage and security

We take all reasonable technical and organisational measures to protect the personal information we hold against loss, unauthorised access, use, modification or disclosure, and against other misuse.

We store most information about you in computer systems and databases operated by either us or our external service providers. Some information about you is recorded in paper files that we store securely.

We will only keep your personal information for as long as it is reasonably necessary taking into consideration our need to answer queries or resolve problems, provide improved and new services and comply with legal requirements under applicable laws. This means that we may retain your personal information for a reasonable period after you stop using Galderma services or stop using our websites or applications. When the personal information that we collect is no longer required, we will take reasonable steps to de-identify it or destroy or delete it in a secure manner, in accordance with best practice for document and data destruction.

Third party data security – Where Galderma does disclose personal information to a third party as specified in point 5 above, any such third party must at all times provide the same levels of security for your personal information as Galderma does, and, where required, are bound by a legal agreement to keep your personal information private, secure and to process it only on the specific instructions of Galderma.

7. How you may access your personal information and seek its correction

You can request access to the personal information Galderma holds about you by contacting the Galderma Privacy Officer in writing here. We will deal with all requests for access as quickly as practicable. Requests for large amounts of information, or information which is not currently in use may require further time before a response can be given. If Galderma cannot provide access to your personal information, it will provide you with the reasons why. There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).

If the personal information Galderma holds about you is inaccurate, incomplete or not up to date you may request that Galderma correct the information here.

8. How to make a complaint and how complaints will be handled

If you are concerned about a possible interference with your privacy or misuse of your personal information by Galderma or if you have a complaint about the way in which we have handled any privacy issue, please contact the Galderma Privacy Officer here or by contacting Customer Services call centre on 1800 800 765 to obtain a Privacy Complaint form.

It is Galderma’s policy to handle complaints in a timely, effective, fair and consistent manner. On making a privacy complaint to Galderma, you will receive an acknowledgment letter or email within 5 business days. This communication will set out the name of the person responsible for handling your complaint and the expected response time to the complaint. Galderma endeavours to make a decision on all written complaints within 20 business days after a complaint is received. If we need more time to respond to your complaint we will notify you as to the delay, the reasons for it and seek your agreement to a longer period.

If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC).

For more information about your right to privacy please visit OAIC's website at www.oaic.gov.au.

9. Privacy Policy updates

This Privacy Policy was updated in May 2021.

We reserve the right to make changes to this Privacy Policy at any time with any changes to the Privacy Policy being published on our website. We encourage you to regularly review this Privacy Policy to make sure you are aware of any changes and how your information may be used.

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