Privacy Policy

Introduction

Apiam Animal Health Limited ACN 604 961 024 and each of its subsidiaries (together “Apiam”, “our”, “we” or “us”) take your privacy and security very seriously.

This policy explains the personal information management practices of Apiam. Personal information means information that identifies you as an individual, or from which your identity can reasonably be ascertained.

This policy describes how we collect, store, use and disclose personal information and explains your rights to access and correct that information or make a complaint about the handling of your personal information (regardless of the form of the information and whether the information is true or not).

This policy generally does not apply to employee records held by Apiam relating to current or former employees where exempt under applicable privacy laws. Separate policies govern employee information handling.

What Type of Personal Information Do We Collect?

The type of personal information we collect will depend on the reason for collection. Generally, the types of personal information we collect will include name, date of birth, contact details such as your address, email address and telephone number, and records of communication with us.

We collect information relating to:

Veterinary Clients and/or Retail Customers

• Information about your pet or animal ownership details; insurance details (if applicable) for the treatment of your pet or animal; details of the products and services you have purchased from us or which you have
• Enquiries about, together with any additional information necessary to deliver those products and services and to respond to your enquiries
• Marketing preferences, including the type of marketing materials you wish to receive and the method of delivery (email, SMS, direct mail, or other)
• Responses to customer satisfaction, service development, quality control and research surveys and similar activities
• Any additional information relating to you that you provide to us directly through our websites or indirectly through the use of our websites or online presence, through our representatives or otherwise; and information you provide to us through our customer surveys or visits by our representatives from time to time
• We may also be required to collect your personal information under State and Territory veterinary surgeons’ legislation
  
  

Job Applicants

Employment and academic histories and the names of referees. We will collect this information directly from organisations that provide recruitment-related services to us, and from third parties who provide job applications with professional or personal references.

Students

Personal data from students is collected for the purpose of facilitation of placements. We will collect this information directly from education providers or directly from students seeking placement or work experience.

Shareholders

Personal data from shareholders is collected for purposes related to their shareholding, including for the purposes of issuing or transacting in shares, paying dividends, regulatory reporting and shareholder communications. Such data may include a shareholder’s name, address, shareholding details, tax file number, and bank account details.

Shareholder data is collected on behalf of Apiam by the external manager of our share register. From time to time this data may be provided to other external service providers for the purposes of paying distributions or mailing shareholder communications, or to the extent permitted by legislation to authorised securities brokers, persons inspecting the register, bidders for Apiam’s securities, or certain regulatory bodies including the Australian Taxation Office.

Other Individuals

We may also collect information, including names and contact details, about:

• People involved in or through an organisation that we support
• Our suppliers (this information is collected for business-related purposes but contains some limited personal information such as contact details of the people that we liaise with)
• People who correspond with us, including through our website, in which case we may keep a copy of that correspondence and relevant contact details
• People who request information updates about us through our mailing list

Sensitive Information

Sensitive information is a subset of personal information that is subject to more stringent protection. It includes information about a person’s race, ethnic origin, health, political views or religious beliefs (among other things). We do not generally collect sensitive information, however note that it may be collected incidentally depending on the context in which you deal with us. We will handle all sensitive information collected in accordance with our obligations under the Privacy Act 1988 (Cth) (“Privacy Act”).

Website Analytics

Our website may use cookies, analytical tools, pixels and similar technologies to understand website usage, personalise content and support marketing activities. Cookies are an industry standard and most major websites use them. A cookie is a small text file that our site may place on our computer as a tool to remember your preferences. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of the Apiam website.

Our website may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other sites.

Our website uses Google Analytics, a service that transmits website traffic data to Google servers. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage.

By using our website, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy.

How We Collect and Hold Personal Information

Where it is reasonable and practicable to do so, we collect personal information directly from you when you correspond or register your details with us, when you present your pet or animal for treatment at one of our clinics or provide feedback to us.

Depending on the nature of our interaction with you, we may collect personal information from third parties — for example, information about job applications is collected in the manner set out above; when new veterinary practices join the Apiam group; and from organisations with whom we have an affiliation.

Apiam may also collect personal information about individual veterinary surgeons (for example where other veterinary surgeons are also involved in the care of an animal), contractors and other individuals who interact with us. This information is generally collected for administration and management purposes.

We hold personal information in hard copy (paper) or electronic form. If you provide information to us electronically, we retain this information in our computer systems and databases. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.

Apiam uses several physical, administrative, personnel and technical measures to protect your information. For example, access to your personal information is restricted to authorised credentials, and copies of correspondences are stored for record keeping and back up purposes only accessible only by authorised personnel.

Why We Collect, Hold and Use Personal Information

We may use personal information for the primary purpose for which it is collected (e.g. the provision of our veterinary services) or for purposes related to the primary purpose where it would be reasonably expected that we would use the information in such a way, or in other limited circumstances as set out in the Privacy Act.

We collect, hold and use your personal information to:

• Provide safe and effective veterinary care to your pet or animal
• Provide products and services to you and to send communications requested by you
• Answer enquiries and provide information or advice about existing and new products or services
• Communicate with you about upcoming appointments, health checks, vaccination schedules and other related veterinary care matters
• Manage, monitor, plan and evaluate our services
• Support safety and quality assurance and improvement activities
• Test and maintain information technology systems
• Support product and service development, quality control and research to improve the way Apiam and its service providers provide products and services to us and you
• Seek your feedback in relation to customer satisfaction and our relationship with you and perform research and statistical analysis using such feedback
• Correspond with people who have contacted us, and deal with feedback
• Recruit and assess potential employees
• Provide services to shareholders in relation to their holding of Apiam securities
• Conduct marketing (including direct marketing), planning, product or service development, quality control and research purposes by Apiam and its related bodies corporate — you may opt out of receiving direct marketing communications at any time using the unsubscribe function in electronic communications or by contacting us directly
• Maintain and update our records
• Comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country
• Answer your questions, provide you with information or advice (including general pet health advice) or consider and respond to requests or complaints made by you

Overseas Disclosure of Personal Information

We may disclose your personal information to third party suppliers, service providers and business partners that access or store data from overseas locations. Personal data may be stored or processed in countries including jurisdictions in which our cloud and technology service providers operate.

In particular, personal information may be transferred to, stored in, or accessed from the United States of America and the United Kingdom, where certain of our cloud, software and technology service providers operate their systems and infrastructure.

We take reasonable steps to ensure that overseas recipients of personal information handle that information in a manner consistent with applicable privacy laws and our obligations under the Privacy Act 1988 (Cth).

Accessing and Correcting Personal Information

You can request access to your personal information held by us, or request that it be corrected, by contacting us at the address below.

Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). There may be instances where we cannot grant you access to the personal information we hold — for example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request that we amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.

Destruction of Personal Information

Apiam takes reasonable steps to destroy or permanently de-identify your personal information where it is no longer required. Personal information which forms part of our veterinary surgeons’ treatment records must be maintained in accordance with legislative and professional requirements.

You can request for your personal information and data to be deleted, by contacting us on the address below.

Complaints About Handling of Personal Information

If you have any questions or concerns about this Privacy Policy or how your personal information has been handled by Apiam, you may contact us at any time. Matters relating to this policy will be received by the Privacy Officer (company General Counsel). The contact details for the Apiam Privacy Officer are set out below under “Contacting Us”.

We will consider and respond to your complaint within a 20 day period. If you are not satisfied with our response to a complaint, or you consider that Apiam may have breached the Australian Privacy Principles or the Privacy Act, you are entitled to make a complaint to the Office of the Australian Information Commissioner.

The Office of the Australian Information Commissioner can be contacted by telephone at 1300 363 992. Full contact details for the Office of the Australian Information Commissioner can be found online at www.oaic.gov.au.

Notifiable Data Breaches

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorized access, modification and disclosure. If we become aware of a suspected data breach involving personal information, we will promptly investigate the incident and assess whether the breach is likely to result in serious harm to any individual whose personal information is involved.

Where we have reasonable grounds to believe that an eligible data breach has occurred, we will comply with our obligations under the Notifiable Data Breaches Scheme and generally within the timeframes prescribed by the Privacy Act 1988 (Cth). If you believe that your personal information may have been affected by a data breach involving us, please contact us using the details set out below.

Changes to This Policy

We reserve the right, at our discretion, to modify or remove portions of this Privacy Policy at any time. This Privacy Policy is in addition to any other terms and conditions applicable to the Apiam website. Any updated versions of this Privacy Policy will be posted on our website and will be effective upon posting. Please review it regularly.

Contacting Us

You may contact us in relation to this Privacy Policy or your personal information as follows: