SUMMARY OF OUR ONLINE PRIVACY COMMITMENT TO YOU

Respect for the privacy of personal information about you is very important to STRONGFORT*. STRONGFORT is committed to collecting, maintaining, and securing personal information about you in accordance with this privacy policy(“policy”), as well as applicable laws, rules and regulations(including the Australian Privacy Act 1988 (Cth), the New Zealand Privacy Act 1993 and, in respect of certain health information, the New Zealand Health Information the New South Wales Health Records and Information Privacy Act 2002, Victorian Health Records Act 2001, and ACT Health Records (Privacy and Access) Act 1997) (the “relevant privacy laws”).

This policy applies to personal information (as defined below) that is collected, held, used or disclosed by STRONGFORT in Australia, New Zealand or Australia’s external territories including via online resources and communications (such as websites, e-mail, forms, and other online and downloadable tools) that display a link to this policy. This policy does not apply to third-party resources to which STRONGFORT’s websites may link, where STRONGFORT does not control the content or the privacy practices of such resources. STRONGFORT may, in appropriate circumstances, rely on the exemptions that are available to it under the relevant privacy laws (including in respect of employee records and related bodies corporate).

This policy is consistent with STRONGFORT’s Safe Harbor Privacy Policy for transfers of personal information from the European Economic Area and from Switzerland to the United States. The adoption of STRONGFORT’s Safe Harbor Privacy Policy allows STRONGFORT to transfer personal information from the European Union and Switzerland to STRONGFORT’s affiliates in other countries in compliance with European Union and Swiss data protection laws. Any transfer of personal information outside of Australia and New Zealand will be done in accordance with this policy and the relevant privacy laws.

This policy should be read together with STRONGFORT’s Global Cross Border Privacy Rules Policy available at http://strongfort.com.au/privacy/cross-border-privacy-policy/

Please read this policy and STRONGFORT’s Global Cross Border Privacy Rules Policy carefully. If you have any questions about of these policies, complaints or concerns about our data collection, holding, use or disclosure practices, please contact us at the address provided below.

How does this Privacy Policy define “personal information”?

How does STRONGFORT collect personal information?

Does STRONGFORT collect sensitive information?

How long does STRONGFORT hold your personal information?

Why does STRONGFORT collect, use and disclose personal information?

Does STRONGFORT consolidate personal information?

Who will have access to personal information about me?

Does STRONGFORT share personal information with third parties?

How does STRONGFORT secure personal information?

How does STRONGFORT protect the privacy of children?

How may I access and correct personal information about me?

What is STRONGFORT’s contact address for privacy questions, complaints or concerns?

How will I know whether STRONGFORT has updated this policy?

*As referred to in this Privacy Policy, “STRONGFORT” means STRONGFORT PTY LTD, Wollstonecraft, NSW, Australia its successors, subsidiaries, divisions and groups worldwide and excluding joint ventures to which STRONGFORT is a party.

How does this Privacy Policy define “personal information”?

The term “personal information” as used throughout this policy, applies to any information or an opinion about an identified individual, or an individual who is reasonably identifiable: whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not.

You are not required to provide your personal information or your real name to STRONGFORT. However, if you choose not to provide STRONGFORT with your personal information or your real name, STRONGFORT may not be able to provide you with full access to information and use of our Websites and other online resources. The types of personal information we collect depends on the nature of the relationship you have with STRONGFORT and the requirements of applicable laws. This information may include, among other things:

contact information professional credentials, publications, patents and other scientific and medical achievements roles or positions held with governmental bodies, hospitals or organisations date of birth, day or year of birth, or age organisational and institutional affiliations programs and activities in which you participated your preferred types of medical information agreements you have executed with STRONGFORT payment-related information, including your Australian Business Number or your IRD number your communications preferences information about your scientific and medical colleagues and leaders in your specialty area records of any interaction we have with you.

How does STRONGFORT collect personal information?

STRONGFORT collects personal information from paper forms you complete and online through STRONGFORT’s websites and other online resources. STRONGFORT also offers online resources in collaboration with other online service providers, from which STRONGFORT may receive personal information about users of such resources. These online collaborations are governed by agreements that require personal information to be protected appropriately.

Individuals may access information or parts of STRONGFORT’s websites and online resources without disclosing any personal information. There are three methods that STRONGFORT uses to collect personal information:

1.Information that you provide:

STRONGFORT collects personal information and other data that you may enter on forms and data fields on our Websites or online resources. STRONGFORT may also collect information about you that you provide by responding to our questions and surveys or through your use of online and downloadable software tools we provide. Some of our Websites enable users to place orders, such as for our vaccines. These Websites may collect credit card information to process those orders.

2.Information from public or third-party information sources:

STRONGFORT may collect personal information about professionals who register on our websites from public or third-party information sources to verify their professional credentials and identity. When customers use a credit card to place an order on our websites, STRONGFORT verifies the validity of the credit card information with financial or credit organizations. In some cases, we may augment our existing user databases with information from third parties. Some of this information may be personal information, such as change of postal address information.

3.Information collected from your computer or other electronic device:

We collect information about your computer or other electronic device when you visit our websites and use our online resources. This information may include your Internet Protocol (IP) address, domain name, browser type, date and time of your request and information provided by tracking technologies, such as cookies and single-pixel tags. If you use a mobile device to access our websites and online resources, we also may collect information about your device, such as your device ID and device type, as well as usage information about your device and your use of our mobile websites and other mobile resources.

Some of our websites and other online resources use tracking technologies to provide additional functionality that enables you to use these resources more effectively.

Does STRONGFORT collect sensitive information?

In limited circumstances (for example, adverse event reports), STRONGFORT may collect sensitive information from you. In this policy, the term “sensitive information” includes health information and genetic information. Except where certain exceptions set out in the relevant privacy laws apply, STRONGFORT will not collect sensitive information from you unless you consent to the collection of that information, and that information is reasonably necessary for one or more of STRONGFORT’s functions or activities.

How long does STRONGFORT hold your personal information?

STRONGFORT keeps your personal information and sensitive information only for as long as it is reasonably necessary for the purpose of collection and in accordance with any applicable legal reporting or documentation retention requirements.

STRONGFORT may also use your personal information to send you further information, if it relates to the purpose of collection, which we consider to be of importance to you, but we will always provide you with the opportunity to tell us if you do not want to receive this further information.

What are cookies?

A cookie is a small data file that is sent by Web servers to your computer’s hard drive, where your Internet browser files are kept. Cookies enable websites to store small bits of information on your computer and retrieve that information at a later time. STRONGFORT uses two types of cookies: session cookies, which are temporary cookies that are erased from your computer’s memory when you close your Internet browser or turn your computer off, and persistent cookies, which exist on your computer’s hard drive until they expire, unless you delete them at an earlier time.

What are single-pixel tags?

Single-pixel tags, also known as web beacons or web tags, are graphics that function similar to cookies. Single-pixel tags are not visible because of their small size. They are used to collect information in web logs that does not identify you personally such as web pages viewed, the web site you came from and the advertisement you clicked on to visit our web sites. They are also used to determine whether certain promotional or other commercial e-mail messages we send are opened.

Why does STRONGFORT collect, use and disclose personal information?

1.Generally, STRONGFORT collects, receives, uses and shares personal information about professionals in accordance with and as permitted by applicable laws, and, where applicable, as authorised by applicable government authorities, in connection with our everyday business operations, which may include:

verifying your identity; providing you with our products or services; providing you with information in relation to the use of our products or services; administering and managing those products or services, including charging, billing and collecting debts; promoting and marketing our products or services to you; internal management purposes, complaint handling, planning, quality assurance and audit purposes; for the purpose of surveys, research and analytics (by us or our third party service providers); to process and consider your application for employment; for direct marketing by us; to provide products and services to you, to provide you with information about those products and services, to assist you with enquiries or purchases, to enhance your experience on our network, or to provide you with better service; to gain an understanding of your information and communication needs, to perform research and analysis, and to improve or develop our products and services symposia, conferences and other scientific and educational programs requests for product samples and orders for our products, where permitted by law financial disclosure reporting auditing our programs and resources for compliance and security purposes identifying and engaging scientific experts and leaders providing access to our resources and keeping track of our interactions with you both offline and online (our online practices are governed by our Internet Privacy Policy) tracking payments made to health care professionals for services performed on behalf of STRONGFORT development of sales and marketing programs delivery of programs and materials to your patients to enable you to use online social media resources that we may offer from time to time. to enhance the mobile computing tools we provide you as required or expressly authorised by laws applicable to our business globally. Where local laws require that you provide specific consent for the collection, use and disclosure of personal information, you may be asked to provide your consent by filling out a paper form, an online form, in a telephone discussion, by a text message or by other appropriate and permitted means.

Does STRONGFORT consolidate personal information?

Consistent with the purposes identified and standards set within this policy and other applicable privacy notices that have been provided, in some cases STRONGFORT consolidates and uses personal information that individuals share with STRONGFORT through various services and channels, such as the telephone, surveys, Websites and other online resources and communications, in order to enhance the quality of services that we offer.

Who will have access to personal information about me?

Personal information (and, in some circumstances, sensitive information) about you will be accessible to STRONGFORT, including its subsidiaries, divisions and groups worldwide which are outside Australia or New Zealand, and to individuals and organisations that use personal information solely for and at the direction of STRONGFORT.

Uses and disclosures of personal information by external individuals and organisations acting on STRONGFORT’s behalf are governed by agreements that require personal information to be protected appropriately.

We endeavour to ensure that such individuals and organisations acting on STRONGFORT’s behalf provide the same level of protection as STRONGFORT, and as required by applicable laws.

Personal information about you will only be used and disclosed by STRONGFORT and individuals and organisations working on its behalf, in a manner consistent with this policy, other applicable privacy notices, the terms of the relevant agreement between the individual or organisation with STRONGFORT, and as explicitly permitted or required by applicable laws, rules and regulations.

Does STRONGFORT share personal information with third parties?

Except as provided in this policy and other applicable privacy notices, personal information about you will not otherwise be shared without your permission.

Reasons personal information about you could be shared	Do we share?	Can you limit this sharing?

To companies STRONGFORT collaborates with: to use for their own products and services	No, unless you provide your express (opt-in) permission	Yes
To companies that STRONGFORT does not collaborate with: to use to market to you	No, unless you provide your express (opt-in) permission for this sharing.	Yes
Reporting to government authorities	Yes, for example, to report safety information about our products.	No. We will be required to comply with our legal obligations in relation to the disclosure of information to the relevant government authority.
To parties in relevant legal proceedings as authorized by the presiding court or tribunal and otherwise to the extent required or explicitly authorized by applicable law	Yes	No. We will be required to comply with our legal obligations in relation to the disclosure of information in accordance with the order of the court or tribunal.
In the event that for business reasons STRONGFORT decides to divest part or all of its business through sale, merger or acquisition, to actual or prospective purchasers	Yes, based on written agreements that personal information will be protected appropriately in these circumstances unless we are, by law, required to seek your consent.	Yes, based on written agreements that personal information will be protected appropriately in these circumstances unless we are, by law, required to seek your consent. No, To other companies we collaborate with solely for activities related to products or services jointly offered or developed by STRONGFORT and that company Yes, provided that we are authorised by law to do so and based on written agreements in place between STRONGFORT and those companies; these agreements will require the protection of personal information in accordance with applicable law. If we are required by law to seek your consent to any sharing of personal information we will do so. Yes, where permitted by law or if you specifically request to opt-out.
With companies globally that provide services on our behalf and in accordance with our instructions (for example, to deliver specificinformation you have requested)	Yes, if the business operation is supported by another company and such sharing is permissible under any applicable law. As a global company, we may work with companies around the world to provide services for or on our behalf, and we will require those companies to protect personal information in accordance with applicable laws, rules and regulations and STRONGFORT Global Privacy and Data Protection Policy (as amended from time to time).	Generally, no. We have instituted policy, contractual and administrative mechanisms requiring protection of personal information by other companies that process personal information on our behalf globally. You may request that we do not share this information however in circumstances where our business operations are supported by other companies, such as a company that we contract with to mail the materials you request, you will not be able to receive this service if you limit or not give your consent to us sharing your personal information with our contractors.
To affiliates* within the STRONGFORT family of companies globally for everyday business purposes as described in this notice *Affiliates are companies related by common ownership or control. Outside of the United States, affiliates of STRONGFORT PTY LTD, Wollstonercraft, NSW, Australia generally operate under the names” STRONGFORT ” or ” STRONGFORT PTY LTD” .	Yes, as a global company, we generally share personal information across our offices globally for the purposes described in this notice, however, only those individuals with a legitimate business need to access personal information for these purposes are granted such access. For example, payment information will be available only to local STRONGFORT or STRONGFORT office in your country and, if applicable, the USA group responsible for payments	Generally, no. We have instituted policy, contractual and administrative mechanisms requiring protection of personal information across our business globally. You may request that we not transfer personal information outside of your country, however, in most cases this will substantially limit the services we can provide to you. Where our computer servers, databases or processes are located in another country, in most cases we will be unable to fulfill such a request and still provide the service to you.

How does STRONGFORT secure personal information?

STRONGFORT stores your data on servers located in Australia and the United States. STRONGFORT takes reasonable steps to protect personal information you provide to us, including as it is transmitted from you to STRONGFORT’s websites or other online resources and servers. STRONGFORT also protects your personal information in its possession from misuse, interference and loss, and from unauthorized access, modification and disclosure.

It is your personal responsibility to secure your own copies of your passwords and related access codes for our online resources.

How does STRONGFORT protect the privacy of children?

In general, STRONGFORT Websites 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 older.

This subsection of our policy only applies to STRONGFORT Websites that provide optional features for children. It is not applicable to our other websites and online resources.

For Kids Only

In some cases, STRONGFORT Websites provide options for children under the age of 13. Most of these optional services do not collect personal information. Where these optional services do collect personal information about children, we require parental consent for children to participate in these optional services. Requests for parental consent explain how we collect, use and disclose personal information about children, and include an opportunity for parents to prevent collection, use and disclosure of information about their children. If, at anytime, a parent withdraws his or her consent to our use or disclosure of personal information collected from his or her child, we will use reasonable efforts to promptly remove such information from our database.

How may I access and correct personal information about myself?

STRONGFORT will take reasonable steps to ensure that personal information we collect, when we are advised by individuals, is accurate, up to date and complete.

To request access to personal information about yourself collected and to keep it accurate, complete and current, unless certain circumstances set out in the Australian Privacy Act 1988 (Cth), and the New Zealand Privacy Act 1993 apply, you may contact the Privacy Officer.

Where offered, you may also update online personal information about yourself by modifying information or deleting some or all of your personal information that you previously have entered into forms or data fields on our Websites. Where permitted by law, your ability to access and correct personal information will be limited where access and correction would: inhibit STRONGFORT’s ability to comply with a legal or ethical obligation, inhibit STRONGFORT’s ability to investigate, make or defend legal claims, result in disclosure of personal information about a third party, result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to STRONGFORT or a third party.

What is STRONGFORT’s contact address for privacy questions, complaints or concerns?

If you have any questions, complaints or concerns about our compliance with this policy please contact us at the below details most relevant to you:

Australia & New Zealand: The Privacy Officer

T +61 2 8937 2800

Please email here

When you contact us, please note the name of the paper form, Website or other online resource you used or to which you provided personal information, as well as the nature of any information that you provided. If you are located in Australia, we will use reasonable efforts to respond promptly within 10-20 business days to requests, questions, complaints or concerns you may have regarding our use of personal information about you. If you are located in New Zealand, we will respond no later than 20 business days to requests for access to or correction of your personal information. We will use reasonable efforts to respond to your privacy questions, complaints or concerns.

We may contact you for follow up information and may share your inquiry with other individuals within STRONGFORT or working for STRONGFORT that are responsible for functions related to the subject of your inquiry. Except where required by law, STRONGFORT cannot ensure a response to questions, complaints or concerns regarding topics unrelated to this policy or STRONGFORT’s privacy practices.

How will I know whether STRONGFORT has updated this policy?

STRONGFORT may update this policy periodically and reserves the right to modify, add or remove portions of this privacy statement at its discretion. If STRONGFORT decides to change this policy, we will post the revised policy at our Websites or in some cases, may provide notice of changes by e-mail.

This privacy policy

was last updated in May 2024.