Your data: Key Questions and Answers

It is fundamentally important that you are informed that Galderma Skin Health S.A., a company based in Switzerland, is the Data Controller (please see Question 18 of this Privacy Notice) of your Personal Information. The principles set out in this Privacy Notice apply to all Data Controllers in the Galderma Group.  While Galderma Skin Health S.A. will be the Data Controller access to data will also be given to it Australian related company Galderma Australia Pty Ltd.

We asked ourselves a number of key questions that we believe you would like answered about the Personal Information that you submit to us. These answers will inform you of your rights relating to your Personal Information and the measures that we take to maintain the privacy and security of this Personal Information. We trust you find this information helpful.

If you have any requests concerning your Personal Information or any queries with regard to these practices please contact us at the address given in Question 5 below.

ATTENTION!

We designed this Privacy Notice so that you don't have to read all of it to find an answer to a specific question.

If you want to read all of it – please feel free to do so. It's set out in full below.

Q1 What Personal Information do we collect through this website and how do we collect it?

A: We only collect Personal Information that YOU want to provide to us or that is needed to provide (and improve) our service to you. We collect direct Personal Information such as name, address and e-mail address as well as indirect information such as cookies, connection and system information.

You may want to give us your e-mail address, name, telephone number etc. so that we can provide you with information about Galderma Skin Health or on our products and services; enter you into our surveys; or just keep you updated about exciting developments that you may be interested in.

You can be confident that we take all necessary measures to keep any Personal Information you send to us private and secure.

Q2 How do we keep your Personal Information secure?

A: We take all necessary measures to keep your Personal Information private and secure. Only authorized Galderma Group staff, Third Party companies (i.e. service providers) staff or our business partners' authorised staff (who have contractually agreed to keep all information secure) have access to your Personal Information. All Galderma staff who have access to your Personal Information are required to adhere to applicable privacy principles and all Third Party employees who have access to your Personal Information have signed non-disclosure agreements. In addition, contracts are in place with Third Party companies that have access to your Personal Information, to make sure this information remains secure. To ensure your Personal Information is protected, we maintain a secure IT environment and have the appropriate measures in place to prevent unauthorised access (i.e. hacking).

Please see Question 4 – Who do we disclose your Personal Information to and why

Q3 What purposes do we use your Personal Information for?

A: Your Personal Information will only be used for the purposes for which you provided it to us. It will also be used to administer, support and obtain feedback on the level of our services and to prevent breaches of security, the law or our contract terms.

Q4 Who do we disclose your Personal Information to and why?

A: Galderma will never share your Personal Information with any Third Party business organisation that intends to use it for direct marketing purposes unless you have given us specific permission to do this.

For Galderma's policy on: (i) direct marketing by e-mail; (ii) your right to ask Galderma at any time NOT to contact you by way of direct e-mail marketing; and (iii) also your right to delete your Personal Information from our systems – please see Questions 8 and 5 respectively.

We may share your Personal Information with other companies within the Galderma Group of companies. We may also share your Personal Information with third parties but only in the strictly limited circumstances set out below:

1) We may supply your Personal Information to Third Parties (such as our internet service providers) who help us administer this website. Some of these business partners may be located outside the country where you accessed this website. Please see Question 6 – "Which countries will your Personal Information be sent to and why?" These Third Parties must at all times provide the same levels of security for your Personal Information as Galderma 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.

2) We may also supply your Personal Information to government bodies and law enforcement agencies if: we are required to do so by the requirements of any applicable law; or if in our good faith judgment, such action is reasonably necessary to comply with legal process; to respond to any legal claims or actions; or to protect the rights of the Galderma Group or its customers and the public.

3) We may, in a few limited circumstances, supply your Personal Information to potential acquirers of any relevant Galderma business but provided that (i) we have contractually ensured that this information is kept private and secure; and (ii) that when supplying this Personal Information Galderma complies with the applicable local laws.

Q5 How can you see, check, change or delete the Personal Information you send to us?

A: You have the right to ask us to provide you with all the information we store on you. You may also have your Personal Information deleted, corrected or revised by sending an e-mail to: privacyofficer.au@galderma.com or a letter to: Privacy Officer: Galderma, 4/13B Narabang Way, Belrose NSW 2085, Australia.

Q6 Which countries will your Personal Information be sent to and why?

A: The controller of your data is Galderma is a global company and your Personal Information will be transferred across international borders. Your Personal Information may also be transferred between different companies of the Galderma Group located in different countries. Specifically, it is expected that your personal data will be provided to Galderma Australia Pty Ltd.  We take the appropriate measures to maintain security of the Personal Information both during transit and at the receiving location.

Unless your consent is obtained, your data will only be transferred to countries that have in places laws that protect information in a way that is substantially the same as the Australian Privacy Principles and/or where steps are taken to ensure that the overseas recipient does not breach the Australian Privacy Principles.

The server that makes this website available will be located outside of Australia. The service provider for hosting this website is bound by a contract that ensures a high standard of privacy protection and requires (amongst other provisions) that it acts only on Galderma instructions and implements all technical measures necessary on an ongoing basis to keep your personal information secure.

Q7 COOKIES ("Tracking Technology") – How and why do we use them?

A: We do make use of tracking technology ('Cookies') to gather such Personal Information as browser type and operating system, referring page, path through site, domain of ISP etc. for the purpose of understanding how visitors use this website. Cookies help us tailor this website to your personal needs.

All information obtained through cookies will not be disclosed outside the Galderma Group or designated Third Parties. It will not be used for unsolicited communications.

Cookies located on your computer do not contain your name but an IP address. After the user's session is cancelled the information contained in the cookies is no longer available to us.

Please ensure that your computer setting reflects whether you are happy to accept cookies or not. You can set your browser to warn you before accepting cookies, or you can simply set it to refuse them, although you may not have access to all the features of this website if you do so. See your browser "help" button for how you can do this. You do not need to have cookies on to use or navigate through many parts of this and other Galderma websites. Remember that if you use different computers in different locations you will need to ensure that each browser is adjusted to suit your cookie preferences.

Q8 E Marketing - What is SPAMMING and what is our position on SPAM e-mails?

A: Spamming is where unsolicited e-mails are sent to you containing advertisements or marketing related materials without your consent

We do NOT send SPAM e-mails. Galderma itself uses an anti-SPAM tool to protect our employees from SPAMMING. Sending e-mails without consent is illegal in many countries. We will not use your Personal Information (including your e-mail address) for direct marketing or follow-up communications unless you give us your EXPRESS permission. This is called "OPT-IN" consent.

Also, we do not share your Personal Information with any third party companies who will use your Personal Information for SPAM mails.

This website may give you the opportunity to receive marketing information by e-mail. Every e-mail sent by Galderma will give you the opportunity at any time to stop receiving marketing e-mails.

If for some reason you believe you have received SPAM e-mail from a Galderma Group company please inform us immediately at the address given. For address details please see Question 5 - How can you see, check, change or delete the Personal Information you send to us?

Q9 How long do we keep your Personal Information for?

A: We may store the Personal Information that you send to us via this website in its databases. Your Personal Information will be kept by the Galderma Group only for as long as 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 law(s). This means that we may retain your Personal Information for a reasonable period after you stop using Galderma services or stop using this website. After this period, your Personal Information will be deleted from all systems in the Galderma Group.

We remind you that we have a right to have your Personal Information deleted at any time. Please see Question 5 - How can you see, check, change or delete the Personal Information you send to us (above)?

Q10 What is our policy on children using and communicating with this website?

A: We believe that it is highly important to protect the privacy of children on-line and encourage parents or guardians to spend time on-line with their children to participate in and monitor their e-activities.

We do not intentionally collect Personal Information from children through this website.

Special Note to Parents of Children

We recommend that parents/guardians regularly check and monitor their children's use of e-mail and other online activities.

Please make sure that your child does not give us Personal Information online without asking your permission.

You can, at any point of time, check your child's Personal Information and have it changed or deleted online. Alternatively, you can also ask us to delete any of your child's information by sending us a deletion request form by e-mail/postal mail/ fax to the address given in contact details set out in Question 5 - How can you see, check, change or delete the Personal Information you send to us?

Q11 Do we link to other third party websites and what happens to my Personal Information when this linking happens?

A: We link to other websites to offer you an opportunity to review connected and interesting information related to Galderma Skin Health. These Third Party websites are outside of our control and are not covered by this Privacy Notice. If you access other websites using the links provided, the operators of these websites may collect your Personal Information. Please ensure that you are satisfied with the privacy policies of these Third Party websites before you submit any Personal Information. We try, as far as we can, to ensure that all Third Party linked websites have equivalent measures for protection of your Personal Information, but we cannot be held responsible legally or otherwise for the activities, privacy policies or levels of privacy compliance of these Third Parties.

Q12 What happens to my Personal Information when I e-mail this website to someone else?

A: Some of our websites may provide you with the opportunity to e-mail a website address to another person. For this feature to work, we may need to collect your e-mail address and/or the e-mail addresses of those you send the website to. E-mail addresses collected in this way are not used for any purpose other than to fulfil your request. These e-mail addresses are not stored and are deleted immediately after your request is fulfilled.

Q13 What happens to my Personal Information if I participate in an online survey from Galderma through this website?

A: From time to time, we may ask our website visitors to answer survey questions. Surveys generally will relate to the content of the website, our products and services or categories of products and services. We may ask for topics relevant to our business, age or age ranges, gender, and/or other non-personal information. For the purposes of these surveys, we may add information obtained from cookies to your survey answers but no Personal Information will be requested. The Personal Information collected is not tied to any Personal Information that you may already have given to us. Personal Information gathered from polls and surveys are for our internal use only but aggregated information (not capable of personally identifying anyone) may be shared with others.

Q14 Product reviews

To provide a product review you will be asked to provide a "nickname", your location and email and specify an age range, gender, skin type and information about your use of the product.  We will publish your "nickname", location, age range and gender together with the product review.  We do not recommend using your full name as your nickname unless you wish to be identified publicly as the provider of the product review.  Your email address and other information will be used to contact you regarding the posting of your review, or the issues you have raised in the review.

Q15 What is One-Time Registration?

A: Some Galderma websites include a one-time registration tool. Where a Galderma website requires registration, in order to make that registration process easier, we use a one-time registration tool. With this tool, when you register with our website, this information can be automatically made available to you for registration at other Galderma website(s). Your Personal Information remains protected and we always ask for your express consent or "Opt-In" to receive information from Galderma website(s) before you are added to any mailing list.

Q16 Can we change the terms of this Privacy Notice?

A: We will occasionally make changes and corrections to this Privacy Notice. Please check this Privacy Notice regularly to see the changes and how these may affect you.

Q17 Where can I find more information on the legal issues concerning Galderma websites and my legal rights and responsibilities?

A: Further information regarding Australian privacy law can be found at https://www.oaic.gov.au/. The laws that govern the use of this website are the laws of News South Wales. For mere detailed information please consult the Terms and Conditions of this website available by clicking on this link it directly on this website.

Q18 Which address(es) is(are) available for me to contact you if I have other questions regarding my Personal Information?

A: The address is: privacyofficer.au@galderma.com or a letter to: Privacy Officer: Galderma, 4/13B Narabang Way, Belrose NSW 2085, Australia.

Q19 Which terms have specific legal meanings in this Privacy Notice (they are highlighted for your ease of use with Capital Letters)?

A: "Personal Information” can also be known as “Personal Data” and means any information relating to you as a natural person that is capable of directly or indirectly identifying you. (On websites this is typically at least your e-mail address).

"Processing of Personal Information” means any operation or set of operations which is performed upon your Personal Information whether or not by automatic means including collection, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction (i.e. effectively any activity that Galderma performs on or with the personal information that you send us).

"Data Controller" is the organisation alone or jointly that determines the purposes and means of the Processing of your Personal Information (i.e. the Galderma entity operating this website and collecting your personal information), which here is Galderma Skin Health S.A.

"Third Party / Parties" for the purposes of this Privacy Notice means any company not under control of Galderma through either direct or indirect ownership.

"Galderma" and "Galderma Group" in this Privacy Notice all refer to Galderma S.A., the ultimate parent company, and its subsidiary companies in which Galderma S.A. has control through either direct or indirect ownership, as appropriate to the context.

Q20 IMPORTANT – Why do I have to accept the terms of this Privacy Notice?

A: Galderma is a global company that uses the Internet to collect and process your Personal Information. This naturally involves the Processing and transmission of your Personal Information across borders.

This Privacy Notice provides you with all information necessary (in an easily accessible way) to make an informed choice as to whether to use this website and to send your Personal Information to Galderma or not.

Therefore, by browsing this website and communicating electronically with us, you acknowledge and agree to our Processing of your indirect Personal Information (cookies, connection and system information) in the manner set out in this Privacy Notice.

If you ask us to provide a certain service to you (i.e. a, newsletter or new product details etc.) we will need additional direct Personal Information (name, address and e-mail address) from you. In this case, we will ask you for your express consent to collect and use this Personal Information. This Personal Information will be used only for the purposes for which you gave it to us.

If you have any questions regarding this Privacy Notice please contact us at the address given under Question 5 and we will be pleased to assist you with any additional questions you may have.

Q21 - How do I make a complaint and what is the resolution process

A: If you wish to complain about how we have handled your personal information you should complain to us in writing at this email address privacyofficer.au@galderma.com or this postal address: Privacy Officer, Galderma, 4/13B Narabang Way, Belrose NSW 2085, Australia.  On receiving your complaint we will decide what action (if any) we should take to resolve the complaint.  If we decide that a complaint should be investigated further, the complaint will be handled by a member of our legal team.  We will assess your complaint against the Australian Privacy Principles and this privacy statement.  In most cases we expect the complaint to be resolved in 30 days.  If you are not satisfied with our response you may ask for review by a more senior member of the legal team or you can complain to the Office of the Australian Information Commissioner.

 

Copyright © 2018 Galderma Holding S.A.