Introduction

Novo Nordisk Pharmaceuticals Pty Ltd (ABN 40 002 879 996) and Novo Nordisk Pharmaceuticals Limited (Company No. 481 264) (collectively “Novo Nordisk”) respect and uphold your rights to privacy protection under: the Privacy Act 1988 (Cth); the Privacy Regulations 2013 (Cth); Australian State and Territorial laws governing the use of personal information or health records; the Privacy Act 1993 (New Zealand); New Zealand privacy legislation governing the management of clinical and health information; and, the general law intended to protect your privacy - as amended from time to time. Novo Nordisk is required to comply with the privacy principles that regulate the handling of personal information which are the Australian Privacy Principles in Australia and the New Zealand Privacy Principles in New Zealand (collectively the “Privacy Principles”). In addition to this Privacy Policy, we may on occasion provide you with specific notice about how we use particular information we collect from you.

This Policy details the practices we have adopted to protect your privacy, so that you can feel confident about how we manage the personal information you entrust to us. This policy should be read in conjunction with our Terms of Use. Keeping user identifiable

information secure is a priority for Novo Nordisk. By providing personal information and/or continuing to engage with Novo Nordisk you consent to your personal information being collected, used and disclosed in accordance with this Privacy Policy. Should you wish to withdraw your consent, please refer to the ‘Review, Change and Correction of Personal Information’ section below.

The purpose of this policy is to:

• Clearly communicate the personal information handling practices of Novo Nordisk;
• Enhance the transparency of our business operations; and,
• Give individuals a better and a more complete understanding of thesort of personal information that Novo Nordisk holds, and the way we handle that information.

This Privacy Policy will govern how Novo Nordisk handles your personal and sensitive information and safeguards your privacy.

Novo Nordisk believes that choice is one of the most important privacy principles. You will always have a choice as to what information you provide and we will give you the right to be anonymous in your dealings with us wherever possible. However, if you decide to withhold personal information which is necessary for us to provide a product or service, it may affect our ability to provide you with that product or service.

What information does Novo Nordisk collect about you?

The information we collect about you will vary depending upon our dealings with you, however Novo Nordisk will only ask for information where there is a clear need and it is reasonably necessary for our functions or activities.

Generally, Novo Nordisk collects information for one or more of the following purposes:

• Maintaining a record of enquiries (including medical enquiries) complaints and adverse events reports relating to our products;
• As required by law, collecting, storing and processing reports of adverse events experienced by patients using a Novo Nordisk product. Adverse event information may be transferred to affiliated companies of Novo Nordisk which may be located overseas for the purposes of processing and reporting the adverse event to the respective health authorities as required by law. We may also use that information to contact you in relation to your report or send you product, health or other information which we consider relevant;
• Supplying you with clinical samples of our products;
• Sending you material on our activities and products or developments in pharmaceutical treatments which may be of interest to you and tailoring marketing services to suit your needs;
• Administering conferences, symposia, expert panels, seminars or other meetings or events organised by Novo Nordisk;
• Administering disease awareness/management programs or other similar programs organised by us, which you have agreed to participate in, or be involved with;
• Helping us analyse traffic patterns throughout our website;
• Notifying you of matters required by law (such as product recalls);
• Managing, planning and arranging meetings between you and Novo Nordisk’s sales representatives;
• Reporting obligations under Medicines Australia’s then current Code of Conduct.
• Monitoring our conduct with respect to other regulations or professional conduct and integrity codes;
• Market research;
• Conducting due diligence with respect to our service providers;
• Notifying  you of third party products that we believe may interest you;
• Clinical trials or other research administration in which you have agreed to participate or be involved with.

In addition, Novo Nordisk may gather information about you automatically through your use of our website (e.g. your Internet Protocol (“IP”) address) and how you navigate our website. See also the sections below on “Using our Website” and “About Cookies”.

We will usually only collect your personal information from you or an authorised representative.

Some websites that have links on our website may collect personally identifiable information about you when you access or utilise those links. We do not control the collection or use of such information, and the practices of those websites are not covered by this Privacy Policy.

Use and disclosure of your personal information

Novo Nordisk will only use personal information for purposes which are directly related to one of our business functions or activities and for: the primary purpose for which it was given to us; or, to the extent:

• Indicated to you at the time of supply of the information to us;
• You consented to a secondary use or disclosure;
• You would reasonable expect it to be used at the time of supplying the information to a third party or a publicly available source;
• Required to provide you with a service or goods which you have requested or which relate to those goods or services;
• Required for the ordinary operation of our website or our business (e.g. to send you information about our goods and services) ;
• Required or permitted by law or regulatory practice;
• Expressly permitted under any agreement with you; or
• To lessen a serious threat to a person’s health or safety.

As a general practice , we require that Novo Nordisk’s third party service providers who handle and obtain personal information comply with: this Policy; the relevant Australian and New Zealand Acts and Regulations (as amended from time to time) – and are subject to obligations to treat this information as confidential information.

We do not sell, rent, or trade your personal information with others. Information provided by you may be stored in databases or other systems which are stored overseas including, but not limited to Australia, New Zealand, Denmark and India.

Novo Nordisk may transfer your de-identified personal and health information to an associated company in USA and/or Europe for the specific purpose of reporting adverse events. We will ensure we comply with our obligations under the respective Privacy Principles with respect to that transfer.

We impose obligations on any external organisations with which we share your personal information to maintain the integrity and security of that information.

We may disclose your personal information in the following circumstances:

• Where it is required or authorised by law
• When one or more of our business partners, co-sponsors a service, promotion and/or contest, we may share some or all of the information collected in connection with such a service, promotion and/or contest
• To our agents, contractors or third party service providers that provide financial, administrative or other services in connection with the operation of our business, e.g. financial or legal advisers, mailing houses - some of which may be located outside Australia
• We disclose aggregate data, statistical analyses or demographics relating to users of our website (you cannot be identified from this information), and
• To our parent company located in Denmark for the purpose of administration, safety monitoring of products and to enable us to provide you with better service.

Forms used to collect your information may give more specific details about the way we use your information.

Security of your personal information

We take all reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure. Your information is stored securely whether in an electronic or physical form. For example, only staff needing access to the information are allowed access. Your personal information is stored in secured premises or in electronic databases requiring logins and passwords.

Some information is kept for a number of years to comply with legal requirements. Any personal information that is no longer needed is de-identified or destroyed.

Links ­

Some resources can be accessed with links from www.novonordisk.com.au and www.novonordisk.co.nz  and these links are not maintained by Novo Nordisk and therefore are not subject to Novo Nordisk’s Privacy Policy. Novo Nordisk is not responsible for the content of any such resources. We do not control the collection and use of such information or the practices of those websites. The existence of a link should not be assumed as an endorsement by Novo Nordisk of the content of the linked page.

Government identifiers

In our dealings involving some consumers we use a unique "H" number assigned by the Australian Department of Health and Ageing to each government-approved patient who receives human growth hormone. We are required to use and disclose the H number consistently with the relevant legislative requirements (contained in the National Health (Growth Hormone Program) Special Arrangement issued under the National Health Act) in our capacity as a "responsible person" under those arrangements.

Changes to our Privacy Policy

From time to time, we may change our Privacy Policy. We will post those changes on our website so that our customers will always be aware of what information we collect, how we use it, and under what circumstances we share the information with others. Our website is located at www.novonordisk.com.au or www.novonordisk.co.nz.

Using our website

We collect general usage information about visitors coming to our website. This includes:

• The date and time you access our website
• Which parts within a Novo Nordisk website you visited, and
• If you linked to the Novo Nordisk website from another website, the address of that website.

You cannot be identified from this information.

About Cookies

Sometimes our web servers collect this general information (referred to above) with the help of cookies. A cookie is a small file that a Web site writes to your hard drive when you visit that website. Cookies cannot read information from your hard drive or read information from other cookies.

Review, Change, and Correction of Personal Information

You can always seek access to your personal information and ask us to correct or delete any inaccurate, incomplete or out of date information. Contact us at the contact address below if you want access to, or want to correct, or make a complaint in relation to the personal information we hold about you. One of our representatives will contact you in relation to your request or complaint.

We are required to take reasonable steps to correct information we hold, to ensure it is accurate, up to date, relevant and not misleading, having regard for the purposes for which it is held.

We are required to take reasonable steps to correct faulty information:

• Where we are satisfied, independently of any request, that the personal information we hold is faulty; or,
• Where an individual requests we correct their personal information.

There is no fee for requesting access to your information. However, we may charge you the reasonable cost of processing your request and there may be some legal or administrative reasons to deny access. If we decide to deny access, we will provide you with a reason why.

You may review, change, or correct any personal information including the permitted uses of your personal information by contacting Novo Nordisk at the relevant address below.

Contact details

If you have any questions, concerns or complaints about our privacy policy or practices please contact us:

In Australia:

Novo Nordisk Pharmaceuticals Pty. Ltd.
Attn: Privacy Officer
PO Box 7586
Baulkham Hills BC NSW 2153
AUSTRALIA

In New Zealand:

Novo Nordisk Pharmaceuticals Limited
Attn: Privacy Officer
Level 18, Office 1834, Commercial Bay Tower,
11-19 Customs Street West,
Auckland, 1010,
NEW ZEALAND

© 2019

+ Copyright: Novo Nordisk A/S, 2019

Disclaimer:

Novo Nordisk disclaims any and all liability related to or arising out of use of the information contained in this website.