Privacy Policy

1. Introduction

   1. The Aspen APAC Group, comprising Aspen Asia Pacific Pty Ltd (ABN 75 146 444 484), Apple SG Bidco Pte. Ltd. (UEN 202556887K) and its related companies as set out at the end of this policy (“Aspen”, “we”, “our” or “us”) acknowledge and respect the privacy of individuals. 
   2. We are committed to protecting your privacy and complying with the Australian Privacy Act 1988 (“AU Privacy Act”), the New Zealand Privacy Act 2020 (“NZ Privacy Act”), the Singapore Personal Data Protection Act 2012 (“SG PDPA”), the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) (“HK PDPO”) and other privacy laws and regulations that apply to us.
   3. This policy sets out the way in which we will collect, use, disclose and hold your personal data or personal information (“personal information”), and your privacy rights.

2. What personal information do we collect and hold, and how and why do we collect it?

   1. Aspen may collect and hold your personal information for the purpose of conducting our business functions and activities, including, without limitation:
      1. to deliver products, services or information;
      2. to assist you with matters or queries, including in relation to our products and services, such as responding to medical or product related inquiries, investigating and managing product related complaints or managing product safety related matters;
      3. to improve, and better understand your preferences in respect of, our products and services and business processes and operations;
      4. to fulfil our legal and regulatory obligations (including obligations to report adverse events and other pharmacovigilance or product safety matters to applicable regulators), participate in legal and regulatory processes (such as investigations and disputes), exercise our rights, or as otherwise required by law;
      5. for marketing and research purposes, including direct marketing purposes (where permitted under applicable laws) such as sending you offers or information on products, events or services that we consider may be of interest to you (see section ‘Your Privacy Rights” below for further information about this);
      6. facilitating corporate transactions such as business sales, mergers and acquisitions, including any related assessment, transitional and business integration activities; or 
      7. protecting the safety and security of our people, premises, systems and assets. 
   2. Examples of personal information we collect and hold includes, without limitation, (i) your name, your professional qualifications, address, telephone number, facsimile number and email address, (ii) details of your interactions or activity with us (eg communications, enquiries, complaints, transactions and activity relating to our business), (iii) your preferences, interests and opinions (eg preferences about communications with us), and (iv) images and recordings (eg any CCTV footage on our sites and recordings of our telephone calls with you obtained in accordance with applicable laws). 
   3. Aspen will not collect and hold sensitive information (such as information about racial or ethnic origins, political or religious beliefs, or health information) except with your consent or where you have provided it voluntarily or where required or permitted by law. We may collect and hold sensitive information such as your or your child's health information where you have provided it to us in the context of communicating feedback on, or to report an issue or adverse event related to, one of our products.
   4. Personal information is usually collected directly from you, including, without limitation, when you: (i) interact with us over the phone, in person or online; (ii) participate in surveys or questionnaires; (iii) attend one of our events; (iv) subscribe to our mailing list; or (v) attend our sites (eg through CCTV). 
   5. Occasionally, where it is unreasonable or impractical to do so, it may be collected from third parties or publicly available sources, including, without limitation, third parties described under the section ‘How and why do we use and disclose personal information’ below. 
   6. Providing personal data is generally voluntary, except where we are required by law to collect it. We will inform you (in accordance with our legal obligations under applicable law) at the point of collection whether providing personal data is mandatory under applicable law. 
   7. You may choose not to provide any personal information to Aspen, however, Aspen may not be able to provide products or services to you or otherwise interact with you. Where possible, we will give you the option to interact with us anonymously or by using a pseudonym.
   8. If you provide us with personal information about another individual, you are responsible for ensuring that they are made aware of this policy.
   9. See below sections ‘Clickstream Data’ and ‘Cookies’ for more information about our how and why we collect and hold your information.

3. How and why do we use and disclose personal information?

   1. Aspen may use and disclose your personal information for a range of functions and activities. These include the above-stated purposes (see section ‘What personal information do we collect and hold, and how and why do we collect it?’ above) as permitted or required by law. Before using your personal information for direct marketing, we will inform you of the types of personal information to be used and obtain your consent where required by applicable law. We will not use or disclose your personal information for other purposes unless permitted or required by applicable law. 
   2. Aspen may disclose personal information to third parties, including, without limitation, (i)  our suppliers, contractors and professional advisers who help us provide our products and services and otherwise administer our business (such as providers of technology, accounting, legal, financial, insurance or research services), (ii) our joint promoters for marketing and research purposes, (iii) our affiliated companies,(iv) law enforcement and government agencies, courts and tribunals, (v) your authorised representatives (vi) our commercial partners, including our partner companies who hold the marketing authorisation or registration for the relevant product, to enable those partner companies to fulfil their legal or regulatory obligations regarding pharmacovigilance reporting or other matters, or (vii) other third parties listed under section ‘What personal information do we collect and hold, and how and why do we collect it?’ above.
   3. We may transfer your personal data to, or otherwise access or make accessible your personal data from, countries outside your home jurisdiction, including countries that may not offer the same level of data protection as your home jurisdiction. These countries may include Australia, Taiwan, Malaysia, Philippines, Singapore, New Zealand, Vietnam and the People’s Republic of China (including Hong Kong). In such cases, we will implement appropriate safeguards in accordance with our legal obligations under applicable law, such as standard contractual clauses, to protect your personal data.
   4. See below sections ‘Clickstream Data’ and ‘Cookies’ for more information about our how and why we use and disclose your information.

4. How do we hold and protect personal information?

   1. We may hold your personal information in physical or digital form. In some cases, we may use third party hosting or storage service providers (including those with cloud storage facilities located outside of your home country) to store your information.
   2. In any event, Aspen will take reasonable steps to protect personal information from misuse, interference or loss and unauthorised access, modification or disclosure. These steps may include security assessments, measures to restrict access to personal information to only authorised personnel, and requiring service providers to comply with binding confidentiality obligations.
   3. We retain your personal information only for as long as we need to, including to provide our products and services, satisfy our accounting or reporting requirements, to comply with our legal obligations, or to establish, exercise or defend legal claims. Retention periods vary depending on the nature of the personal information. You may request deletion of your personal data in accordance with your right to erasure below (see section ‘Your Privacy Rights’ below).

5. Clickstream data

   1. Each time you visit a website operated by Aspen (including product related websites), our server collects some information, known as click-stream data , including the type of browser and system you are using; the address of the site you have come from and move to after your visit; the date and time of your visit; and your server's IP address. Although this data is mostly anonymous, it is possible that under certain circumstances, we may connect it to you (including as set out below).
   2. Aspen may collect this information for statistical purposes to find out how our website is used and navigated, including the number of hits, the frequency and duration of visits, or most popular session times. We may use this information to evaluate and improve our website performance or to identify individuals whom may threaten the security or integrity of the website.

6. Cookies

   1. A cookie is a piece of information that our web server may send to your machine when you visit our website. The cookie is stored on and recognises your machine, but does not otherwise identify you or give us any information about your device.
   2. A cookie helps us to recognise you when you re-visit our website and to co-ordinate your access to different pages on the website. We use cookies to learn more about the way you interact with our content and help us improve your experience of using our website.
   3. With most internet browsers, you can erase cookies from your device, block all cookies, or receive a warning before a cookie is stored. If you want to do this, refer to your browser instructions or help screen to learn more. If you reject or limit the use of cookies, you will still be able to access our website but please note that some of its functions may not work as well as if cookies were fully enabled.

7. Links to other sites

   1. Aspen may provide links to other sites operated by third parties on our websites. If you use these links, you will leave our website and we make no representations or warranties in relation to the privacy practices of these third parties or their sites, and we are not responsible for any of these third parties or their sites, including their content or their usage of your personal information. Third parties are responsible for informing you about their own privacy practices and we advise that you check the privacy policies on their sites.

8. Your privacy rights

   1. Access, correction and deletion
      1. Aspen will comply with our obligations under applicable laws to ensure that your personal information accurate, complete, up-to-date, relevant and not misleading.
      2. Please keep us informed of any changes to your personal data to help keep our records up-to-date.
      3. You can access and request correction of any personal information that we hold about you at any time, in accordance with your rights under applicable laws. You may also request that we delete your personal information at any time in accordance with your rights under applicable laws. Any such requests should be made directly by contacting us (see section ‘Contact Us’ below for details). Please note that there are some exceptions under applicable law to your right to gain access to or deletion or correction of your information.
      4. If we say “no” to your request, we’ll tell you why in writing. Aspen may charge a fee for reasonable costs incurred in providing such access, and will advise of the amount of the fee before access is provided.
      5. If you request a correction to your personal information that Aspen is not willing to make, where available under applicable law, you may have the right to request that a statement of correction be attached to your information.
   2. Enquiries and complaints
      1. Please contact us if you have a complaint or enquiry regarding Aspen's compliance with this policy or any applicable privacy laws (see section ‘Contact Us’ below). Aspen will consider and respond to a complaint or enquiry within a reasonable time frame. Note we may require proof of your identity and further details of your request, and may need to engage or consult with other parties in order to investigate and deal with your complaint or enquiry. We will keep records of your request and any resolution.
      2. We encourage you to contact us first so that we may attempt to resolve your complaint or enquiry. However, it will not always be possible to resolve a complaint or enquiry to everyone’s satisfaction. If you are not satisfied with our response to your complaint or enquiry, you may submit a complaint to your local or national privacy or data protection authority.
   3. Direct marketing
      1. You may opt-out of receiving marketing communications from us at any time by following the instructions to “unsubscribe'' set out in the relevant communication or by contacting us using the details below (see section ‘Contact Us’ below).
   4. Withdrawal of consent
      1. Please note that if you withdraw your consent (where you are entitled to do so under applicable laws), Aspen may not be able to continue providing our products or services to you, or administer our contractual relationship. Depending on the nature of your request, this may result in the termination of your agreements with Aspen, and may constitute a breach of your contractual obligations. In such cases, our legal rights and remedies are explicitly reserved.

9. Updates to this policy

   We may update this privacy policy periodically, including when our data handling practices change or in order to comply with legal or regulatory requirements. We encourage you to check our website from time to time to view our current privacy policy. You may also request the current or previous versions of this policy from us (see section ‘Contact Us’ below).

10. Contact us
    

    Aspen APAC

    Privacy Officer

    privacy@aspenpharmacare.com.au 

    02 8436 8300

This policy applies to Aspen Asia Pacific Pty Ltd (ABN 75 146 444 484) of 34-36 Chandos Street, St Leonards NSW 2065, Australia, Apple SG Bidco Pte. Ltd (UEN 202556887K) of 9 Raffles Place, #26-01 Republic Plaza, Singapore 048619 and the following related companies:

• Aspen Pharmacare Australia Pty Ltd (ACN 51 096 236 985) of 34-36 Chandos Street, St Leonards NSW 2065, Australia 
• Aspen Pharma Pty Ltd (ACN 004 118 594) of 34-36 Chandos Street, St Leonards NSW 2065, Australia 
• ENT Technologies Pty Ltd (ACN 103 249 207) of 34-36 Chandos Street, St Leonards NSW 2065, Australia 
• Aspen Pharmacare Asia Limited (CRN 3142166) of Suite 3001, 30th Floor, Oxford House, 979 King’s Road, Hong Kong
• Aspen Philippines Inc (registration no. CS201117485) of Unit 1001-1002, 10th Floor, Trade and Financial Tower, 7th Avenue cor. 32nd Street, Bonifacio Global City, Taguig City, Metro Manila, Philippines 1634 
• Aspen Medical Products Malaysia Sdn Bhd (registration no. 1004761-W) of Unit 1302A, Level 13A, Uptown 1, 1 Jalan SS21/58, Damansara Uptown, 47400 Petaling Jaya, Selangor, Malaysia
• Aspen Healthcare Taiwan Limited (registration no. 53957116) of Suite A, 20th Floor, No 207, Section 2, Dunhua South Road, Taipei 106, Taiwan
• Representative Office of Aspen Pharmacare Asia Limited in Ho Chi Minh City of Unit 006A, 4th Floor, Centec Tower, No.72-74, Nguyen Thi Minh Khai Street, Xuan Hoa Ward, Ho Chi Minh City, Vietnam

Last updated: June 2026