Privacy Policy

Effective Date: 16 November 2020.
This Privacy Policy replaces the Privacy Policy version dated 23 December 2015.

Adherium Limited (ACN 605 352 510) and its affiliates, Adherium (NZ) Limited, Adherium North America, Inc. and Adherium Europe Ltd (“ADR”, “we”, “us”, “our”) respect and are committed to protecting your privacy.

This Privacy Policy explains how we collect, store, disclose, transfer and otherwise process your personal information for the purpose of compliance with applicable data protection laws. We are bound by the Australian Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles. In addition, depending on where we collect or process your personal information, other applicable data protection laws may apply, for example, the New Zealand Privacy Act 1993 for personal information collected or processed in New Zealand, or the General Data Protection Regulation 2016/679 (“GDPR”) for personal data collected from residents of the European Union ("EU") or the United Kingdom ("UK") or processed in the EU or UK. Other data protection laws may also apply.

This Privacy Policy notifies you how we handle your personal information obtained through https://www.adherium.com (“Website”) or when you contact us directly via email, phone, mail or social media. This Policy does not apply if we collect personal information from you under separate terms, for example when you become an employee, contractor, or take part in a usability study. We process personal information of the end users of Hailie® sensors and Hailie® software as described in a separate privacy policy.

In this Privacy Policy, “personal information” means information or opinion that identifies a person directly or indirectly and includes sensitive information. By using this Website or contacting us, you agree to the terms of this Privacy Policy. By providing your personal information to us, you consent to the collection, storage, disclosure, transfer, retention and other processing as described below.

What personal information we collect and how

Depending on how you contact us and what services we provide to you, we may collect different types of personal information.

When you contact us directly to ask for information about our company, services or products, to lodge a complaint, make a privacy-related request, or sign up to a mailing list, purchase our products or services etc., we will collect all or some of the following information directly from you:

  • Your name, preferred title and contact details: physical address, phone or mobile number, email address, etc.;
  • The name of your organisation and role, if applicable;
  • Areas of interest in relation to our products or services;
  • Details confirming your identity: your date of birth, gender, identity documentation such as a passport or driving licence, for example, when you send us a privacy request;
  • Details of your communications with us; or
  • Payment details including bank and credit card details, tax ID number, if payment is required for any services.

If you are a shareholder or a prospective shareholder we will additionally collect information relating to your shareholder status, the number of shares held and history of shares purchased and sold.

If you are a job applicant we will additionally collect your qualifications, gender, nationality, your right to work in the country where the role is based, your CV and cover letter information, your employment history, qualifications, education, criminal and financial checks.

When you access the Website or connect to us from a social network such as Facebook, LinkedIn or Twitter, we use cookies to collect and analyse technical information about user activities, such as:

  • user traffic patterns,
  • IP addresses of your device,
  • browser type and language,
  • operating system information,
  • software and hardware attributes,
  • referring and exit pages and URL,
  • geographic location (state or country) from which you accessed the Website,
  • platform type,
  • the number of clicks,
  • files you download,
  • domain names,
  • landing pages,
  • pages viewed and the order of those pages, the time spent on a page,
  • the terms used in searches on the Website,
  • the time and date you access the Websites,
  • upload or post content,
  • error logs and other similar information.

If your web browser has Do Not Track enabled, we will not track your visit. Refer to Cookies section below, to find out more and how to disable them.

Indirect collection

We also collect personal information from publicly available sources to enable us to contact individuals who may be interested in working with us. We may also collect information about you from our affiliates or regulatory or government authorities.

Information we do not collect

Except as stated above, we do not knowingly and intentionally collect or maintain any information regarding your health, race or ethnic origins, political opinions, religious or philosophical beliefs, professional, trade or union membership, sexual preferences or other sensitive information.

How we use your personal information

For the purposes of this Privacy Policy, to "process" personal information means collect, record, organise, store, adapt, use, transfer, disclose, combine, erase or destroy. To process your personal information, we rely on the following legal bases: performance of a contract, legitimate interest, legal or regulatory obligations or your consent.

We will only use your personal information for the purposes we collected it for and for purposes compatible with the original purpose.

We will only use your personal information for other purposes where you have given your consent.

We may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We use your personal information for the following purposes:

  • Administering our website, enforcing Terms of Use, monitoring security threats, improving performance and providing the best experience when you access the Website;
  • Responding to your inquiries, requests, complaints, including privacy-related requests;
  • Verifying your identity;
  • Managing and administering our relationship with you and your organisation;
  • Internal record-keeping;
  • Providing our services, products or support to you;
  • Improving our products and services;
  • Sending our latest announcements, investor alerts, newsletters, events, services or products or providing occasional marketing or advertising material to you – only if you first opt-in by providing your email and until you opt-out by using “unsubscribe” function;
  • Communicating with you about your job application, assess your suitability for the role and conduct reference checks;
  • Complying with our legal or regulatory and risk management obligations, including establishing, exercising and defending legal claims;
  • Providing regular updates to the shareholders about our performance;
  • Conducting statistical and other analyses about users interacting with our Website or social media accounts;
  • Creating aggregated data sets (see the Aggregated Information section below);
  • Other purposes as required or permitted by law; and
  • As otherwise set out in this Privacy Policy.

What happens if you do not provide personal information

If you don’t provide your personal information when you contact us or you don’t want us to process it, we will not be able to respond to your question, complaint or job application.

Disclosing or sharing your personal information

We respect your right to control who accesses your information. We disclose or share your personal information for the purpose for which it was collected and related purposes or with your consent. We do not sell your personal information to third parties.

We will disclose or share your personal information in the following situations:

  • Affiliated companies: We share the information with our affiliated company when the affiliated company is in the best position to fulfil the services, respond to your query, complaint or a job application.
  • Service providers: We use a number of service providers to whom we disclose your personal information. These include providers that host our website servers, process and host data, provide customer support, provide professional services, manage our human resources information, recruitment, research (including market research) or marketing. To protect your information we enter into legally binding contracts with the service providers. These contracts require them to keep the information confidential, to use the information solely for the purposes of providing the specific services to us and to treat personal information consistently with this Privacy Policy.
  • Transfer of business: We may transfer your information to a third party if some or all of the business of Adherium is transferred to another entity by way of merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control (in whole or in part). In such circumstance, Adherium will contractually require that the new entity will honour this Privacy Policy.
  • Law: When: (i) reasonably necessary to comply with legal process (such as a court order, subpoena or search warrant) or other legal requirements; (ii) disclosure would mitigate Adherium’s liability in an actual or threatened lawsuit; (iii) necessary to protect the legal rights of Adherium’s users, customers, business partners or other interested parties; or (iv) necessary for the prevention or detection of crime (subject in each case to applicable law).
  • Your consent: We may ask for your consent to share your information with other third parties. In any such case, we will make it clear why and how we want to share the information.

Aggregated Information

We will use your information to create aggregated data sets which no longer identify you as a person. We will use aggregated data for any purpose at our sole discretion, for example, statistical modelling of medication adherence behavioural patterns or market segment research. If we transfer aggregated data to third parties, we will make sure there are measures in place to ensure the third party cannot identify you.

Protection of your information

We take great care to make sure that your information is kept safe, but no system or electronic data transmission is completely secure.

We protect your information by using technical and physical security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls, virus scanning tools, data encryption and secure work environments.

If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below. If we become aware of a possible security breach, we will ensure that it is addressed in accordance with applicable laws.

International transfers

When we collect your personal information it may be transferred to our affiliated companies or service providers including where these companies or providers are located outside the jurisdiction you reside in. Regardless of where you live, we take care to ensure your personal information is kept safe and your right to privacy is respected. Before we transfer your information from your country of residence or between other jurisdictions, we will make sure that there are appropriate legal and technical measures in place so that your information is kept private and secure in accordance with the laws of your country of residence.

Adherium companies have offices in Australia, New Zealand, the United Kingdom and the USA.

This Website, https://www.adherium.com, is hosted in New Zealand.

We store personal information on secure servers in Australia and the USA.

We will only transfer your personal information from the jurisdiction in which you reside or provide the data:

  1. If the information is “personal data” (as defined in the GDPR) of EU and UK residents: on the basis of the European Commission’s adequacy determination or, standard contractual clauses, or where there are appropriate safeguards in place; or
  2. Other personal information: if the overseas recipient is bound by the laws or a binding scheme that are/is substantially similar to the laws the data subject can enforce; on the basis of standard contractual clauses, data processing agreements, or where there are other appropriate safeguards in place.

How long do we keep your information?

If you deactivate your account, your information is retained on our secure servers for as long as permitted or required under applicable law.

Your Rights: Accessing, Modifying and Erasing your information

You can access all information we store about you by asking us for a copy of it at privacy@adherium.com.

We take care to ensure that your personal information is accurate and up-to-date. However, if any information we hold is incorrect, incomplete or inaccurate, you can send us a request to correct it by contacting us at privacy@adherium.com.

If you are a resident of the EU or the UK or if we process your personal data in the EU or UK, you also have the following rights:

  • You can ask us to restrict processing of that information while we verify whether it is accurate.
  • You can ask us to erase your personal data.
  • In certain circumstances, you have a right to object to us using your personal data to having your personal information processed: (a) if our legitimate interest use impacts on your fundamental rights and freedoms, (b) if processing is for direct marketing purposes or (c) if processing is for statistical analysis purposes. Please note, if you withdraw your consent to Adherium processing your personal information, this will not affect the lawfulness of any processing done prior to you withdrawing consent.

Please send your requests in writing to privacy@adherium.com.

This section does not limit or exclude other rights that you may have as the data subject under the applicable data protection laws.

We work hard to respond to all requests in a timely manner, according to the requirements of the applicable data protection laws.

In some circumstances and in accordance with applicable laws, we may refuse certain requests, for example, we will decline requests that are vexatious or technically infeasible. In such cases, we will provide you with our reasons for the decision.

If you are not satisfied with our handling of our request, refer to How to make a complaint section for information on how to lodge a complaint.

We reserve the right to verify your identity before any request relating to your personal information is processed by us.

Data Portability

Where it is technically feasible for us to do so and you have the legal right to make the request, you can request a copy of any personal information that you have provided us, in a structured, commonly-used and machine-readable format, so you can transmit it to another data controller, by emailing privacy@adherium.com. Please note, we will not disclose any derivative information (for example, algorithmic results) or information which may compromise any of our intellectual property or confidential business information.

Automated Processing

If we use automated processing of your personal information to give you feedback on your use of the Website, we will do so for information purposes only and not to make any decisions which could produce a legal effect or significantly affect you.

Third Party Websites/Apps

Our Website may contain links to websites or applications offered by third parties that we do not control. Any information you provide on third party sites is governed by their privacy policies, not ours. We are not responsible for the information that you provide to such third parties.

Minors

This website is not intended for or directed to children under 13 years of age. If you are a child, please don’t access this Website or otherwise contact us. We do not knowingly collect any information from minors unless we have received verifiable consent from a parent or legal guardian. If we become aware that a user is a minor and has provided personal information without the consent of a parent or legal guardian, we will delete such information as required by law. If you know of a minor user whose information may have been collected without consent from a parent or legal guardian, please email us at privacy@adherium.com.

Cookies

By using our sites and apps, you agree to us storing and accessing cookies and similar technologies on your device.

What are cookies

Cookies are simple text files which are sent to and stored on your device when you visit a website or use an app.
A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier.
A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using the Website.

Some cookies are deleted when you close the browser on your device (session cookies). Other cookies remain on your device until their expiry or removal (persistent cookies). Some cookies relate to the functionality of the website and improve your user experience (functional cookies). Other cookies allow us to collect statistics (aggregated and anonymous) on the use of the website by our visitors or customers (analytical cookies). Some cookies may be essential for us to provide certain interactive functions or to ensure online environment.

What cookies do we use and why

Adherium uses cookies to improve and help personalize users’ experience with our Websites. For example, we use functional cookies to make logging into our account a little easier and to track some operational features of our Website. This includes things like your authentication information so you don't have to log in every time, your language and time zone settings so you can pick up where you left off when you come back to the site.

We also use analytical cookies.

Cookies that we commonly use are listed below. This list is not exhaustive but describes the main reasons we typically set cookies. As we adopt additional technologies, we may gather information through other methods.

We use the following cookies on our Website:

Cookie  Description Duration Type

ASP.NET_SessionId

This cookie is used in sites developed with Microsoft.Net. When a user starts browsing a unique session ID is created, which keeps track of all the information regarding that session. This information is stored in the web server and it is identified via a GUID. The GUID is essential for any ASP.NET site to function properly.

Session time

Necessary

_ga

This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site's analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.

2 years

Analytics

_gid

This cookie is installed by Google Analytics. The cookie is used to store information on how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number of visitors, the source where they have come from, and the pages visited in an anonymous form.

1 day

Analytics

_gat_gtag_UA_118287238_1

Google uses this cookie to distinguish users.

1 minute

Analytics

How to manage cookies

If you want to manage your cookie settings in your browser, select the ‘help’ section of your browser (e.g., Google Chrome, Mozilla Firefox, Apple Safari, Internet Explorer) for more information. Your browser will allow you to change your cookie preferences.

Changes to our Privacy Policy

We review our privacy practices regularly. We may update this Privacy Policy from time to time. We will provide you with advance notice of material revisions to this Privacy Policy. We will not make revisions that have a retroactive effect unless we are legally required to do so or to protect other users. Your continued use of the Website after the effective date constitutes your acceptance of this Privacy Policy, as amended. As of the effective date, the amended Privacy Policy supersedes all previous versions of or agreements, notices or statements about this Privacy Policy.

You can confirm you are looking at our latest Privacy Policy by checking here or you can request previous versions at privacy@adherium.com.

How to contact us

If you have any questions or concerns about our Privacy Policy or if you would like to make a complaint about the manner in which your personal information has been collected or handled by us, please contact us by email at privacy@adherium.com or in writing to:

  • Adherium (NZ) Ltd, PO Box 106612, Auckland 1143, New Zealand or,
  • if you are an Australian resident, to Adherium Limited, PO Box 1149, Thornbury VIC 3071.

We will respond to all communications as soon as reasonably possible. If you want to give us any feedback about how we have handled your question or request, please let us know because we are always trying to improve.

Additional information for EU and UK residents

For compliance with data protection laws in the EU and in the UK:

  • Adherium (NZ) Limited is the data controller responsible for the personal information processed in connection with this Website.
  • Adherium (NZ) Ltd has appointed Adherium Europe Ltd as its EU representative and data subjects based in the EU or in the UK may alternatively contact us in writing at Adherium Europe Ltd, BDO LLP, 2nd Floor, 31 Chertsey Street, Guildford, Surrey, United Kingdom, GU1 4HD.
  • Our Data Protection Officer is Paulina Luczynska at privacy@adherium.com.

How to make a complaint

If you are not satisfied with our response to your question or concern, you can make a complaint to the relevant privacy regulator or data protection authority in your region (see below).

Australia: Office of the Australian Information Commissioner: https://www.oaic.gov.au/about-us/contact-us/

New Zealand: Office of the Privacy Commissioner: https://www.privacy.org.nz/about-us/contact/

UK: Information Commissioner’s Office: https://ico.org.uk/global/contact-us/

EU: please refer to this website for a list of the contact details of the Data Protection Authority for your country: https://edpb.europa.eu/about-edpb/board/members_en

Elsewhere: we can assist you in identifying the appropriate regulator in your region. Please contact us at privacy@adherium.com.