Value through Innovation24 June 2016

Boehringer Ingelheim Pty Limited (78 Waterloo Road, North Ryde, New South Wales, Australia, 2113) and Boehringer Ingelheim (N.Z) Limited (Level 1, Unit 9, 42 Ormiston Road, East Tamaki, Manukau, 2016, New Zealand) (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), in New Zealand, the Privacy Act 1993 (N.Z) and the New Zealand Information Privacy Principles (IPPs) respectively.

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 also the basis on which any such personal information will be dealt with.

Types of information collected and held

"Personal information" is information or an opinion about an identified individual, or an individual who is identifiable: whether or not the information or opinion is true and whether or not the information 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 the best possible quality of customer service to you.

Boehringer Ingelheim does not collect your personal information, unless you provide 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:

1. your name, email address and other contact details;

2. any questions or comments that you may post;

3. if you are visiting our website at www.boehringer-ingelheim.com.au (Website), the IP address of your machine when connected to the internet and the domain name from which you are accessing the internet; and

4. if you are a healthcare professional 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.

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

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", such as information about your state of health and medical history.

How we collect and hold personal information

Boehringer Ingelheim collects your personal information that you voluntarily and knowingly provide when:

1. you purchase one of our products and you apply for a credit account with us;

2. you access the Website;

3. you contact Boehringer Ingelheim in order to make an enquiry about Boehringer Ingelheim or a particular Boehringer Ingelheim product;

4. you participate in a Boehringer Ingelheim non-prescription product survey or promotion;

5. you attend one of our conference meetings or events;

6. you are participating 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.

Boehringer Ingelheim will only collect personal information directly from you. However, from time to time the collection and processing of personal information is carried out by our third party contractors, third party data suppliers, recruitment agencies etc. When your personal information is collected by external third parties, we will take reasonable measures to ensure that those third parties are aware of and comply with this Privacy Policy.

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.

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 you would reasonably expect the use or disclosure in the circumstances, and that secondary purpose is:

(a) in the case of non-sensitive information: related to the primary purpose for which we have collected that information, and

(b) in the case of sensitive information: 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 (except as required for any statutory or legal requirements) in ways different from what is described in this Privacy Policy.

Your personal information may be provided to 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.

The purposes for which Boehringer Ingelheim may use or disclose your personal information include:

1. to provide you with any services or goods that you may request;

2. to respond to any query or complaint that you may make;

3. for internal administration, product research, evaluation and development, and quality control purposes, and

4. 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:

1. its related companies (within and outside of Australia and New Zealand);

2. third parties within or outside of Australia and New Zealand engaged to help Boehringer Ingelheim improve its pharmaceutical products;

3. 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; and

4. any other parties it deems necessary in relation to providing you access to the Website.

Boehringer Ingelheim may combine any information which it collects from you with information collected by the Boehringer Ingelheim group of companies 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.

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, not accurate or up to date, 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
Boehringer Ingelheim Pty Limited
PO Box 1969
Macquarie Centre NSW 2113

Telephone: + (61)(2) 8875 8800
Fax:              + (61)(2) 8875 8801
Email:          privacyofficer.syd@boehringer-ingelheim.com

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. 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 www.oaic.gov.au or the Office of the Privacy Commissioner in New Zealand (as applicable) at www.privacy.org.nz.

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 and Germany) and external data processors/web hosting servers located outside of Australia and New Zealand (such as in the USA, Japan and Germany).

The types of personal information that we are likely to disclose to overseas entities include your name, email, address, de-identified sensitive information, professional and business details and/or information related to adverse events related to our products.

You agree that where personal information is disclosed to the countries above, the Privacy Act 1988 (Cth) and the Privacy Act 1993 (N.Z) will not apply to that information.

Changes to our Privacy Policy and Privacy Statements

Boehringer Ingelheim will use and disclose personal information in accordance with the Privacy Statement under which the information was collected. If Boehringer Ingelheim changes this Privacy Policy or any Privacy Statement, it will post those changes on its Website so you are always aware of what personal information Boehringer Ingelheim collects, how Boehringer Ingelheim uses it, and under what circumstances, if any, Boehringer Ingelheim discloses it.

Amendments will be effective immediately upon being placed on the Website for those who continue to access the Website. Your continued use of the Website following such amendments being placed on the Website will represent an agreement by you to be bound by the Privacy Policy or Privacy Statement, as the case may be, as amended.

[Policy last updated September 2015]