Privacy Policy

1. Introduction

Innovia Group (ABN 56 688 008 380) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, hold, use, disclose and protect personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).

This Policy applies to information collected through our website at innoviagroup.com.au, through email and telephone communications, and in the course of our business as an Australian / New Zealand medical device manufacturer and distributor.

By using our website or providing personal information to us, you acknowledge that you have read and understood this Policy.

2. About us

Innovia Group is an Australian-owned medical device manufacturer and distributor based in Sydney, New South Wales. We design and manufacture medical products, and distribute global medical technologies to healthcare providers across Australia and New Zealand.

3. Personal information we collect

We may collect the following types of personal information:

• Identity and contact information, including your first and last name, job title or role, employer or organisation, business address, email address and telephone number.
• Enquiry information you submit through our website forms, including hospital or organisation name, country or region, product category of interest, enquiry type and any message content you provide.
• Professional information, including your role within a healthcare or manufacturing organisation (for example, surgeon, clinician, procurement, manufacturer representative).
• Correspondence and communications you exchange with us by email, phone or other channels.
• Technical information collected automatically when you visit our website, including IP address, browser type and version, device type, operating system, referring URL, pages visited, time spent on pages and other usage data.
• Cookie and tracking data, as described in section 9 below.

We generally do not seek to collect sensitive information (as defined in the Privacy Act, including health information). If sensitive information is provided to us in the course of a clinical or commercial enquiry, we will only collect, use and disclose it where you have consented or where collection is otherwise permitted by law.

4. How we collect personal information

We collect personal information in the following ways:

• Directly from you when you complete an enquiry form on our website, subscribe to updates, contact us by email or telephone, attend an event we host or exhibit at, or otherwise interact with us.
• Automatically when you browse our website, through cookies, server logs and similar technologies.
• From third parties such as your employer, business partners, referees, publicly available sources (for example, LinkedIn or professional directories) and our service providers, where it is reasonable and practicable to do so.

Where it is reasonable and practicable, we will collect your personal information directly from you. If we receive personal information about you from a third party that we did not request, we will deal with that information in accordance with APP 4.

5. Why we collect, hold, use and disclose personal information

We collect, hold, use and disclose personal information for purposes including:

• Responding to enquiries submitted through our healthcare provider and manufacturer enquiry forms.
• Providing information, quotations, samples, demonstrations, training and support relating to our products.
• Supplying, supporting and servicing medical devices, including post-sale technical and service support.
• Managing our relationships with healthcare providers, hospitals, clinicians, manufacturers, distributors and other business partners.
• Meeting our regulatory and reporting obligations, including those under the Therapeutic Goods Act 1989 (Cth), Therapeutic Goods Administration (TGA) requirements and the TGA Advertising Code.
• Vigilance, post-market surveillance, complaint handling and product recall activities relating to medical devices.
• Conducting market research, analytics and business development.
• Sending you marketing communications, updates and newsletters about medical device innovations, clinical insights and industry developments (where you have consented or where otherwise permitted by law).
• Improving our website, products and services.
• Meeting our legal, regulatory and contractual obligations, and protecting our legal rights.

We will only use or disclose your personal information for the primary purpose for which it was collected, for a related secondary purpose you would reasonably expect, or where you have consented or the use or disclosure is otherwise permitted or required by law.

6. Disclosure of personal information

We may disclose your personal information to:

• Our employees, contractors and related entities, on a need-to-know basis.
• Manufacturers and suppliers whose products we distribute, where disclosure is necessary to process your enquiry, fulfil an order or provide product support.
• Service providers who assist us with website hosting, IT and cloud services, email and customer relationship management, analytics, marketing, logistics and freight, payment processing, professional advice (legal, accounting, audit) and similar functions.
• Regulatory authorities and government agencies, including the TGA, where required or permitted by law.
• Courts, tribunals and law enforcement agencies, where required or permitted by law.
• Any person to whom you have consented to the disclosure.

We do not sell your personal information to third parties.

7. Direct marketing

We may use your contact details to send you marketing communications about our products, services, events and industry updates, where this is permitted by the Privacy Act and the Spam Act 2003 (Cth).

Every commercial electronic message we send will include a functional unsubscribe facility. You can opt out of marketing communications at any time by using that unsubscribe facility, or by contacting us using the details in section 13. We will action your request within a reasonable period.

8. Overseas disclosure

Some of our service providers, manufacturer partners and related entities are located outside Australia. As a result, we may disclose your personal information to recipients located in countries including (but not limited to) New Zealand, the United States, the United Kingdom, the European Union, China and other jurisdictions where our manufacturer partners and service providers operate.

Before disclosing personal information overseas, we take reasonable steps to ensure the overseas recipient handles your personal information in a manner consistent with the APPs, except where an exception under APP 8.2 applies.

9. Cookies and website analytics

Our website uses cookies and similar tracking technologies to distinguish you from other users, remember your preferences and analyse website performance.

Cookies are small text files placed on your device when you visit a website. We may use both session cookies (which are deleted when you close your browser) and persistent cookies (which remain on your device for a set period).

We may also use third-party analytics tools (such as Google Analytics) to help us understand how visitors use our website. These tools may collect information sent by your device or our website and may set their own cookies.

Most web browsers allow you to control cookies through their settings. If you disable cookies, some parts of our website may not function correctly. For more information, please see our Cookie Notice.

10. Storage and security of personal information

We hold personal information in both electronic and, where relevant, hard copy form. Electronic information is generally stored on secure servers operated by us or our service providers, which may be located in Australia or overseas.

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure, including through access controls, secure storage, encryption where appropriate, staff training and contractual protections with service providers.

No method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

We will retain personal information only for as long as is necessary to fulfil the purposes for which it was collected, or as required by law (including our recordkeeping obligations under therapeutic goods legislation). When personal information is no longer required, we will take reasonable steps to destroy or de-identify it.

11. Access to and correction of your personal information

You have the right to request access to the personal information we hold about you, and to request that we correct any personal information that is inaccurate, out of date, incomplete, irrelevant or misleading.

To make a request, please contact us using the details in section 13. We will respond to your request within a reasonable period (generally within 30 days). We do not charge a fee for making an access or correction request, although we may charge a reasonable fee to cover our costs of providing access in certain circumstances.

In some circumstances, we may be permitted by law to refuse access to or correction of your personal information. If we refuse, we will give you written reasons and information about how you may complain about the refusal.

12. Complaints

If you believe we have breached the Privacy Act or the APPs, or you have a concern about how we have handled your personal information, please contact us in the first instance using the details in section 13. Please include sufficient detail to allow us to investigate your complaint.

We will acknowledge your complaint promptly and aim to provide a substantive response within 30 days. If we are unable to resolve your complaint to your satisfaction, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

Office of the Australian Information Commissioner
GPO Box 5288, Sydney NSW 2001
Phone: 1300 363 992
Website: www.oaic.gov.au

13. How to contact us

If you have any questions about this Privacy Policy, or would like to make a request or complaint regarding your personal information, please contact our Privacy Officer using the details below:

Privacy Officer
Innovia Group
36/2 Chaplin Drive, Lane Cove NSW 2066, Australia
Email: info@innoviagroup.com.au
Phone: +61 2 8313 5478

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements or for other operational reasons. The current version will always be available on our website, and the effective date at the top of this Policy will be updated accordingly. We encourage you to review this Policy periodically.

15. Governing law

This Privacy Policy is governed by the laws of New South Wales, Australia. Any dispute arising in connection with this Policy or our handling of personal information will be subject to the non-exclusive jurisdiction of the courts of New South Wales and the courts competent to hear appeals from those courts.