Privacy Policy

  1. About Hugel and this Privacy Policy

    1. Croma Pharma Pty Ltd trading as Hugel Aesthetics (Hugel, we or us) is a supplier of high-quality aesthetic treatments, including pharmaceuticals and medical devices which are included on the Australian Register of Therapeutic Goods and certain products which are still in development or the process of receiving approvals in Australia (Products).
    2. This Privacy Policy explains how we manage the personal (including sensitive) information that we collect, hold, use and disclose and how to contact us if you have any further queries about our management of your personal (including sensitive) information. This Privacy Policy applies to you only to the extent that the collection and handling of your personal (including sensitive) information is subject to the Privacy Act 1988 (Cth) (Privacy Act).

  2. Background

    1. Where the collection or handling of your personal information by us is subject to the Privacy Act, we must comply with the requirements of that Act. The Privacy Act regulates the manner in which personal information is handled throughout its life cycle, from collection to use and disclosure, storage, accessibility and disposal.
    2. Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
    3. Special provisions apply to the collection of personal information which is sensitive information. This includes health information and information about a person’s race, ethnic origin, political opinions, membership of political, professional or trade associations, religious or philosophical belief, sexual preferences and criminal history.

  3. What personal (including sensitive) information do we collect?

    1. In the course of our business, we may collect personal (including sensitive) information about you that is necessary for us to perform our functions and activities.
    2. If you are a healthcare professional, we may collect personal information about you such as:
      1. identifying and contact information (such as name, email address and telephone numbers);
      2. your Australian Health Practitioner Regulation Agency registration number;
      3. your clinic and delivery address details;
      4. any memberships you have with a professional or trade association;
      5. transaction details relating to purchases you have made with us;
      6. bank account and/or credit card details;
      7. details about the products you use and prefer (including our Products and those of our competitors) and your years of injecting experience;
      8. details of any conferences and educational events that you attend; and
      9. any dietary requirements.
    3. We typically only collect de-identified information in relation to patients who use our Products (for example, through pharmacovigilance reporting).


  4. How do we collect personal (including sensitive) information?

    1. In the course of our business, we may collect your personal (including sensitive) information in a number ways including when you:
      1. input your personal information into our website, including to access any healthcare practitioner specific information;
      2. complete an application form to create a customer account with us;
      3. purchase a Product;
      4. attend a conference or educational event;
      5. provide us with feedback;
      6. make an inquiry or a complaint; and
      7. otherwise communicate with us (either verbally or in writing).
    2. We typically collect your personal (including sensitive) information directly from you. We may also collect personal (including sensitive) information about you from third parties such as from:
      1. payment gateways relating to payments made through third party providers;
      2. our contracted suppliers;
      3. recruitment agencies; and
      4. educational event organisers.


  5. Why do we collect, hold, use and disclose your personal (including sensitive) information?

    1. In general, we collect, hold, use and disclose personal (including sensitive) information for the following purposes:
      1. to provide you with our Products;
      2. to invoice and process any fees payable in relation to Products rendered;
      3. to help us better understand the needs of our customers and their patients so that we can better develop products and services for you;
      4. to manage our relationship with you and to contact you for follow up purposes;
      5. to develop, manage and improve our educational events and conferences;
      6. to market our Products;
      7. to verify and update personal (including sensitive) information held by us;
      8. to review, develop and improve our functions and activities and business processes;
      9. to review and address complaints;
      10. to comply with legal or regulatory obligations including with respect to pharmacovigilance and adverse event reporting; and
      11. for other purposes required or authorised by or under law, including purposes for which you have provided your express or implied consent.
    2. Our functions and activities may change from time to time.
    3. If you provide your email address, telephone and/or mobile phone number, you also consent to us using your email address, telephone and/or mobile phone number to contact you (including by telephone call, SMS or email) for any of the above purposes.


  6. To whom may we disclose your personal (including sensitive) information?

    In order to carry out the above purposes, we may disclose your personal (including sensitive) information to third parties including:

    1. persons or organisations we engage to assist us in carrying out our functions and activities such as transport/logistics service providers, educational event organisers and marketing service providers;
    2. our related bodies corporate;
    3. government agencies and regulatory bodies, or as required, permitted or authorised by law; and
    4. parties involved in a prospective or actual transfer of our assets or business.


  7. What happens if you don’t provide your personal (including sensitive) information to us?

    If you do not provide the personal (including sensitive) information that we request, we may be unable to provide the Products that you request of us, provide training or education services to you, or provide information about the Products to you.

  8. How do we hold your personal (including sensitive) information and manage the data quality and security of your personal (including sensitive) information?

    1. We store your personal (including sensitive) information electronically on cloud based servers located in Australia with access only available by password.
    2. We aim to store your personal (including sensitive) information securely and have a range of security controls in place (including physical, technical and procedural safeguards) designed to protect your personal (including sensitive) information.
    3. To the extent required by the Privacy Act, we take reasonable steps to:
      1. make sure that the personal (including sensitive) information that we collect, hold, use and disclose is accurate, complete and up to date; and
      2. protect the personal (including sensitive) information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure.


  9. Do we transfer personal (including sensitive) information overseas?

    We may disclose your personal (including sensitive) information overseas, including to our related bodies corporate and service providers in the United States of America and South Korea.

  10. Marketing

    1. If you are a healthcare practitioner, we may use your personal (including sensitive) information to contact you (including by telephone call, SMS, email or mail) in relation to products, services or other offers we think may be of interest to you. This may include products, services or other offers of Hugel or third parties with whom we have a relationship.
    2. You may opt-out of receiving marketing information from us at any time by contacting us using the contact details which appear below.
    3. We do not use personal information of patients or non-healthcare practitioner consumers for marketing purposes.


  11. How can you access or correct the personal (including sensitive) information that we hold about you?

    1. Please contact us if you would like to seek access to or request that we correct the personal (including sensitive) information we hold about you:
      1. By mail: Level 26, 1 Bligh St, Sydney NSW 2000
      2. By telephone: 1800 276 622
      3. By email: infoaustralia@hugel-aesthetics.com
    2. We will generally provide you with access to your personal (including sensitive) information if practicable, and will take reasonable steps to amend any personal (including sensitive) information about you which is inaccurate or out of date. In some circumstances and in accordance with the Privacy Act, we may not permit you access to your personal (including sensitive) information, or may refuse to correct your personal (including sensitive) information, in which case we will provide you reasons for this decision.


  12. How we handle complaints

    1. If you have any concerns or complaints about the manner in which we have collected or handled your personal (including sensitive) information, please advise us of your concern or complaint in writing and send it to our Customer Service team using the email address or mailing address set out above. Your concern or complaint will be considered or investigated and we will endeavour to respond to your complaint within 30 days.
    2. It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response, you may contact the Office of Australian Information Commissioner who may investigate your complaint further.


  13. Further information

    Further information about the application of the Privacy Act can be found at the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.

  14. Changes to our Privacy Policy

This Privacy Policy is effective from 17 May 2023. As this Privacy Policy is updated from time to time, to obtain a copy of the latest version at any time, you should visit our website at www.hugel-aesthetics.com.au or contact our Customer Service team using the email address or mailing address set out above.