Privacy Policy

Douglas Australia and New Zealand Privacy Policy

Douglas Pharmaceuticals Ltd and Douglas Pharmaceuticals Australia Pty Ltd (separately and together, ‘Douglas’) are bound by the Privacy Act 1988 (Cth) (‘Australian Act’) and the Privacy Act 2020 (‘New Zealand Act’) (together, ‘Acts’) and will only collect and use personal information in accordance with the Acts and this Policy.

You have the choice not to submit personal information (other than as may be required by law) to us although this may result in us being unable to provide products and services to you or reduce your ability to fully participate in all aspects of our websites or other platforms (together, ‘Sites’).

By providing personal information and/or continuing to engage with Douglas you consent to your personal information being collected, used and disclosed in accordance with this Privacy Policy.

Data We Collect and Use

Douglas may collect personal information about you through all of our interactions with you. Generally, Douglas may keep a record of your name, contact details (i.e. address, telephone number, etc), and when collecting personal information for business purposes your professional details (e.g. qualifications, speciality, areas of interest), details on your practice/business (e.g. size, use of products, prescribing practices) and details of your dealings with us.

When you post data or materials on public forum message boards, chat, profile pages, blogs and other services, you acknowledge that this information may be available to the general public.

By way of example, without limitation, Douglas may collect information about:

Healthcare Professionals (e.g. doctor, nurse, pharmacist etc.) in the course of responding to product queries, meetings with our sales representatives; and complying with our regulatory obligations;
Members of the general public in the course of using our customer or product information services;
Service providers in the course of providing services to Douglas; or completing due diligence questionnaires;
Pharmacy customers in the course of fulfilling orders.

The personal information collected may vary depending on your particular interaction with Douglas but will be limited to that information necessary to record and manage our interaction with you or as permitted or required by law.

In addition, Douglas may gather information about you automatically through your use of our Sites (e.g. your Internet Protocol (‘IP’) address and how you navigate our Sites or device location). See also the section below on cookies and other tools.

From time to time, Douglas may collect or solicit personal information from a third party, from where you would reasonably expect or where you have previously consented to personal information being shared, for Douglas’s own internal use.

Medicines Access Programs and Patient Support Programs

If you are a participant in a Medicines Access Program (including but not limited to Cost-Share Agreements, Compassionate Access Programs or Product Familiarisation Programs) or Patient Support Program, Douglas may collect additional sensitive data and health information which we may receive from you directly, from your health care professional or related third party, including nominated third party service providers engaged by Douglas to deliver the Programs.

Douglas and/or our service providers may use and disclose your personal information as part of your program participation to administer and manage the program. Douglas and/or our service providers may also contact your health care professional to provide and receive information relevant to your participation in a program.

How We Use and Disclose Personal Data

Douglas uses the personal information we collect for the primary purposes for which it is collected, other related purposes or as permitted or required by law including the following purposes:

maintaining a record of medical queries, complaints and adverse event or adverse reaction reports relating to our products and reporting these to the Government or relevant regulatory bodies, such as the Therapeutic Goods Administration or Medsafe, as may be required;
to provide health products or services that have been requested;
to enforce our terms and conditions;
to comply with legal obligations such as notifying you of matters that we may be required by law to notify you of (e.g. product recalls);
to conduct due diligence with respect to our service providers;
managing, planning and arranging meetings between healthcare practitioners and our sales representatives;
monitoring and reviewing our compliance with relevant regulations and codes of conduct in our dealings with you and monitoring the quality, safety and efficacy of our products; and
to gain insights in to how Douglas’s products are prescribed and used in practice.

For any of the above purposes, Douglas may disclose, store or process your personal information to or with:

its affiliates within Australia or New Zealand, in which case your personal information will be collected, used, disclosed, managed and stored in accordance with this policy;
third parties within or outside of Australia or New Zealand. From time to time we may need to engage a service provider in a country outside Australia and New Zealand. We will only do so if we have reasonable grounds to believe that the service provider is required to protect information in a way that offers comparable safeguards to those in the Acts. You hereby authorise Douglas to disclose your personal information to these overseas recipients; and
regulatory authorities, within or outside of Australia or New Zealand, and ethics committees as part of a clinical trial evaluation, monitoring or inspection process.

Douglas might buy or sell companies, subsidiaries or assets and generally, customer information is one of the transferred business assets, particularly if Douglas or substantially all of its assets are acquired. We may disclose personal data to companies that were formerly wholly or partly included in the Douglas family of companies to which we provide services during a transition period following separation.

Generally, we require that third parties who handle or obtain personal information as service providers to Douglas acknowledge the confidentiality of this information, undertake to respect an individual’s right to privacy and comply with the Acts and this Policy.

Security of Personal Information

Douglas takes reasonable precautions to protect your personal information from loss, misuse, alteration disclosure or interference and unauthorised access.

While we endeavour to keep information on Douglas Sites, including the personal information provided by you or on your behalf, secure and confidential, we will not be responsible for any breach of security caused by third parties and do not represent that Douglas Sites are completely secure.

Douglas has directed its staff that personal information must be dealt with in accordance with this Policy and kept secure from unauthorised access or disclosure. Except for the disclosures listed above, we will limit access to personal information to Douglas personnel on a need-to-know basis. We educate our staff about their duty to protect your privacy and provide training regarding privacy obligations.

Cookies and Other Tools

Douglas may use standard technology called cookies on its websites. Cookies are small data files that are downloaded onto your computer when you visit a particular website. Cookies help provide additional functionality to the website or to help us analyse site usage more accurately. We use information collected from cookies to better understand, customise and improve user experience with our websites, services and offerings, as well as to manage our advertising. Also, we may use web analytics services that leverage cookies to help us to understand how visitors engage with and navigate our site (e.g. how and when pages in a site are visited and by how many visitors).

In all cases in which cookies are used, the cookie will not collect personal information except with your explicit permission. Your web browser can be set to allow you to control whether you will accept cookies, reject cookies or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognise you when you return to the website, and some website functionality may be lost.

In addition to Douglas cookies, certain third parties may deliver cookies to your computer for a variety of reasons. For example, we sometimes use various web analytics tools that help us understand how visitors engage with our websites.

For more information about cookies, visit www.aboutcookies.org.

Direct Marketing

With your consent, Douglas may use your personal information to provide you with direct marketing communications about our products, services, promotions, and events that may be of interest to you. These communications may be sent via post, email, SMS, telephone, or other electronic means.

You have the right to opt-out of receiving direct marketing communications from us at any time. If you no longer wish to receive these communications, you can unsubscribe by following the instructions provided in the communication or by contacting Douglas’s Privacy Officer in the details listed below.

We may also disclose your personal information to third party service providers who assist us in delivering our direct marketing communications. These service providers are contractually obligated to handle your personal information in accordance with applicable privacy laws and regulations.

AI and Automated Decision Making

Douglas uses a number of programs and applications which utilise machine learning and other artificial intelligence (AI)-based processes. AI tools are used by Douglas for a variety of functions, including to assist with medical writing, analyse information from calls with healthcare professionals and to provide general assistance to Douglas staff.

Douglas does not generally use AI tools in order to make decisions which may affect your rights or interests, however if we become aware that AI tools are being used for this purpose we will provide you with further information by updating this Policy.

Links

Douglas websites may contain links to other websites that we think may be of interest to you. However, Douglas is not responsible for the privacy practices or the content of such websites. When linking to the other site, you should always check that the website’s privacy policy before providing any personal information.

Accessing and Updating Personal Information Douglas Holds About You

Douglas has appointed a Privacy Officer to oversee Douglas’s management of personal information in accordance with this Policy and the Acts. The Privacy Officer’s contact details are set out below.

If you have questions about Douglas and privacy, wish to provide feedback about this policy, would like to update your personal details held by Douglas, wish to access information held by Douglas about you or wish to make a privacy related complaint please contact Douglas’s Privacy Officer for Australia and New Zealand at:

Email: team.legal@douglas.co.nz
Phone: +64 9 8350660
Postal address: The Privacy Officer, Douglas Pharmaceuticals Australia Pty Ltd or Douglas New Zealand Limited, PO Box 45027, Te Atatu, Auckland 0651, New Zealand

Updates to Our Privacy Policy

From time to time, we may update this Privacy Policy. Any changes will be effective when we post the revised Privacy Policy as per the date listed below. This Privacy Policy was last updated as of the effective date listed below.

You should regularly review this Policy for any modifications or amendments, as your continued use of our Sites, products services or provision of further personal information to use after a modification or amendment of the revised Privacy Policy constitutes your deemed acceptance of the revised Privacy Policy.

Effective date: 1 December 2025