Disclaimer & Privacy Policy

This policy applies to Commercial Eyes Pty Ltd (ABN 28 098 247 691) (“Commercial Eyes”, “our”, “we”, “us”) handling, including collection, use, disclosure and storage, of your personal information arising out of, or connected with, our interactions with you, including all personal information collected through ourwebsite (www.commercialeyes.com.au), and in connection with the management of pharmacovigilance cases (including the handling and management of health and medical information on behalf of our pharmaceutical and healthcare clients and customers) (“Privacy Policy”).

As an Australian entity, Commercial Eyes Pty Ltd is bound by the Privacy Act 1988 (Cth) (“Privacy Act”) and Australian Privacy Principles (“APPs”), as well as applicable health privacy laws, which sets out a number of principles concerning the privacy of individuals, including how we collect, use, disclose, store, handle and protect your personal and health information.

Commercial Eyes is also part of ProductLife Group (https://www.productlifegroup.com/) a multinational organisation with subsidiaries, partners and clients located around the world (“PLG”). In certain instances, Commercial Eyes may handle your personal information with, including disclosing your personal information to, members of PLG, as further described below.

As an Australian individual, we hope that this Privacy Policy will help you make an informed decision about sharing personal information with us.

If you are a resident of, or are located, outside of Australia, please see the PLG privacy policy located at (https://www.productlifegroup.com/) for more information on how PLG handles your personal information in other locations.

What is personal information?

In this Privacy Policy, ‘personal information’ has the meaning set out in the Privacy Act. In general terms, personal information is information (whether fact or opinion) about an individual who is identified or reasonably identifiable from that information or other information combined with that information.

Some types of personal information are classified as ‘sensitive information’ and/or ‘health information’, which are subject to additional protection under the Privacy Act. Sensitive information may include information about your racial origin and health status, and health information may include information about a health-related service you have had or will receive, including test results and appointment details, as well medical information disclosed in an adverse health event report (as defined below).

How do we collect your personal information?

We collect your personal information directly from you, including when you:

are navigating our website;
seek customer support;
contact us directly about and/or report adverse health events (as defined below) (we may also record and store phone calls, including the personal and health information provided on the call for quality management and staff training purposes, to improve the service we provide to you, for complaints handling and for general call monitoring and feedback purposes. These recordings are not intended to be used for other purposes, except where required or permitted by law. For example, we may be required to disclose call recordings if compelled by a court process or formal notice from a government regulator);
request medical or other information; and
apply to work with us or are engaged by us as a contractor.

Where it is reasonable and practicable to do so, we will only collect personal information about you directly from you.

We may however collect personal information about you from our partners or customers, including our pharmaceutical and healthcare clients who provide your personal information to us, so that they can provide their services to you.

We may also collect your information from other third parties (such as mutual contacts, or from your referees during the recruitment process if you apply for a job with us) and from public domain sources, where applicable.

Whilst using our website, you may be directed to a third-party website or service. We are not responsible for the privacy practices of such third parties. Please visit their website and review their privacy policies to determine how they may collect and/or handle your personal information.

What personal information do we collect?

The types of personal information we collect about you will depend on the purpose for which the personal information is collected. This can include:

in the case of our partners, clients and customers, where you are a relationship contact: your name, address, email address and telephone number(s);
where you access our website, technical information, such as web browser type, Internet service provider, referring/exit pages, date/time stamps, IP address, time zone, some of which is collected automatically arising from your use of our website;
where you access our customer support features: your name, username and password;
where you contact us about management of any adverse health events[SFL1] [WZ2] [G3]  (defined below): the contact details of the person who notified us of the undesirable health event, your alphanumeric code or ‘pseudonym’, details of your sensitive health and medical information relevant to the undesirable health event, where disclosed to us;
where you are a patient of one of our partners, clients or customers: your personal information, including sensitive health and health-related information as further set out below, may be disclosed to, or collected by, us in calls or other recorded communications (where you provide your consent to do so), including the metadata from such recorded calls and the health-related information set out below;
where you are a prospective employee or contractor: information contained in your application or résumé, recorded during any interview, or obtained through any pre-employment checks, and government-issued identifiers such as tax file numbers; and
where you are requesting medical information:
your name, postal address, email address and telephone number;
professional data, such as your speciality (if you are a healthcare professional); and
title of request, product concerned, response given, and date and status of request.

Are you a professional reporting an adverse event?

We need to collect, use, disclose and store the following information:

your name, postal address, e-mail address, telephone number, fax number; and

job title and/or role.

Are you a patient exposed to an adverse event?

We provide health vigilance management activities (e.g. related to pharmacovigilance – reporting information about possible adverse events or side effects occurring when taking medication) (an ”adverse health event”) and other medical information management activities on behalf of our partners, clients and customers.

As such, when you report an adverse health event to us, you are identified by an alphanumeric code, a “pseudonym”, in order to protect the confidentiality of your identity.

However, when you notify us of an adverse health event, we must collect the following sensitive and/or health information about you to meet our and our clients’ legal and regulatory obligations:

identification data: name/initials, date of birth, gender; ethnicity; and

health information: data relating to the adverse health event (e.g., what happened, when it started/stopped, action taken), data relating to the product relating to the adverse event report, health information related to pathologies and associated treatments (treatments administered, test results, personal and family history, other medicines/conditions).

We may collect other sensitive and/or health information about you where they are relevant and necessary to the assessment of an adverse health event. Such information may include your professional life (current or previous occupation), lifestyle habits (tobacco, alcohol and drug consumption), behavior and lifestyle (addiction, sex life, etc.), racial or ethnic origin, and whether you are pregnant or breast-feeding.

Can you choose not to disclose your personal information?

You do not have to identify yourself or provide any personal information if you contact us. You can also notify us that you wish to deal with us using a pseudonym.

If we cannot collect personal information about you or if you use a pseudonym, we may not be able to provide you with the information or assistance you require. For example, we will not be able to send you information you have requested if you have not provided us with a valid email address or telephone number. However, we will be able to provide you with assistance in relation to reporting an adverse event if you use a pseudonym, as outlined above.

Sharing of your personal information

We disclose your personal information to third parties in connection with the purposes described above. Your personal information may be disclosed to:

our employees and staff, contractors and third-party service providers who assist us in performing our business functions and activities (e.g. persons responsible for vigilance and medical information, authorised personnel in charge of claims management, cloud service providers, data storage providers, telecommunications providers and IT support services providers);
any of our PLG members, including Commercial Eyes affiliates (the latter meaning any natural or legal person who directly or indirectly controls, is controlled by, or is under common control with Commercial Eyes – for this purpose, the terms ‘control’, ‘controlled’ and ‘controlled by’ mean the ownership and control of more than fifty per cent (50%) of the outstanding voting securities or interests in the capital or profits of any natural or legal person, or the right to direct or control the management or affairs of any natural or legal person by contract or similar arrangement) involved in the management of adverse events or medical information management;
third parties to whom you have authorised us to disclose your information, or to whom it is necessary to disclose your information, for example:
pharmaceutical and healthcare companies, including healthcare professionals concerned by or related to a report of an adverse health event;
the laboratory holding the marketing authorisation or sponsor of a clinical trial in which you are participating;
the operating laboratory and, where applicable, the person responsible for pharmacovigilance;
National, European or foreign public bodies responsible for pharmacovigilance in the course of their duties; and
laboratories whose products may be implicated;
legal counsels, auditors and consultants in the context of their attributed missions;
legal and administrative authorities, in accordance with applicable laws; and
our clients, customers and other third-parties as notified to you.

We may also hire third parties to provide services, including IT-related services, on our behalf, including ensuring the security of your personal information, the provision of software dedicated to the management of adverse events or medical information management tools, data hosting and back-up, telephony management including call connections and call recordings, customer support, transaction processing or customer freight shipping.

Those companies will be permitted to obtain only the personal information they need to deliver the services for which they have been contracted. Commercial Eyes takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the collection, use, disclosure, storage and protection of your personal information.

Do we transfer your data overseas?

As we are part of the PLG multi-national organisation, your personal information may be used, disclosed and stored offshore. This may include disclosure to our third-party service and data storage providers located offshore, including France, Europe.

Except where an exception applies under the Privacy Act or other applicable legislation, we will take commercially reasonable steps to require that overseas recipients to whom we disclose personal information handle your personal information in a manner that is at least equivalent to obligations under the Privacy Act and the Australian Privacy Principles including in relation to the collection, use, disclosure, storage and protection of your personal information.

How long do we keep your personal information?

Generally, we will retain your personal information for the period necessary for the purposes for which your personal information was collected (as outlined in this Privacy Policy) unless a longer retention period is required or authorised by law, including where it is reasonably necessary for us to comply with our legal obligations, to resolve any disclosed dispute and/or defend any proceedings.

When personal information is no longer required, we will take reasonable steps to remove and delete the personal information from our systems, or de-identify or anonymise the personal information so that it no longer identifies you.

How Commercial Eyes uses your personal information

We use and disclose your personal information for the purposes collected, including managing our business and providing our products and services (directly or indirectly) to you, including to:
provide products and services to our customers, clients and partners, including pharmaceutical and healthcare companies, and our affiliates and/or other members of the PLG;
receive goods or services from third parties including our partners and suppliers;
enable the proper operation and functionality of our services, including:
management of adverse health events;
reporting undesirable health events to applicable competent authorities and regulators in line with the notified legal obligations of our partners, clients and customers; and
responding to legitimate requests for medical and health information;
verify your identity (e.g., if you request access to the personal information we hold about you);
consider you for a job or other relationship with us;
communicate with you, and to address any issues or complaints that we or you may have regarding our relationship, or the products and/or services we provide to you (directly or indirectly through our partners, clients or customers), including for the purposes of record keeping of enquiries, feedback or complaints;
prevent, detect and investigate suspicious, fraudulent, criminal or other activity that may cause you, us or others harm, including in relation to our products and services;
comply with our legal obligations such as notifying you of matters that we may be required by law to do so;
identify opportunities to improve our products and services;
gain insights about you so that we can serve you better, understand your preferences and interests, personalise your experience and/or enhance products and services you are offered and receive;
for direct marketing purposes (unless you have opted-out of doing so); and
contact you lawfully for various purposes relating to our products and services, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.

We may also use or disclose your personal information for administrative, marketing (including direct marketing), planning, product or service development, quality control, survey and research purposes and for any other purposes to which you have consented, or as otherwise permitted or required by law.

How do we store and secure your personal information?

We use secure methods to store your personal information, including call recordings and/or transcripts, in electronic record keeping format and within secure databases.
 
We do not combine or link personal information we hold about you with other personal information that we collect about you from third party sources.
 
We have implemented reasonable and appropriate technical and organisational measures to protect the security, integrity, confidentiality and availability of your personal information.
 
No automated decision-making
 
While using our products and/or services, you are not subject to any exclusive automatic decision-making process – including profiling – that would have a legal effect or similarly significant impact on you.

What are your rights and how can you exercise them?

Accessing Your Personal Information and asking for rectification

You have a right to access your personal information (including to obtain a copy of your call recording and/or transcript) that we hold about you by contacting us at [email protected]. We will provide access to such information in accordance with the Privacy Act and related health privacy laws, subject to any exceptions that may apply which allow us to refuse your request for access.

Commercial Eyes reserves the right to charge an administration fee for searching for, and providing access to, your personal information on a per request basis but we will let you know in advance if that is the case.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it by contacting us at [email protected]. Where we agree that the information needs to be corrected, we will update it and confirm a record of the update to you. If we do not agree, you can request that we make a record of your correction request with the relevant information.

You can also ask us to notify any third parties, to whom we provided incorrect information to, about the correction and ask them to rectify their records. We are not responsible for the records held by any third party, including the accuracy of such records.

Lodging a question or complaint

If you wish to lodge a question or complaint about our collection, use, disclosure or handling of your personal information, please contact us using the ‘Contacting us’ details set out below.

Commercial Eyes shall act on such request as per the following steps. We will:

acknowledge receipt of your request promptly;
investigate the matter internally; and
respond to you as soon as possible and take reasonable steps to respond within 30 days (this period may be extended by two further months where necessary and notified to you, taking into account the complexity and volume of the request).

Contacting us

Commercial Eyes welcomes your comments and feedback. If you have any questions about this Privacy Policy and would like further information, if you would like to access or correct any personal information held about you, or if you wish to lodge a complaint, please contact us below at:

Call:                +61 3 9251 0777 (Monday to Friday during business hours)
Post:               Attn: Privacy Policy
                        Commercial Eyes Pty Ltd
                        Level 5, 447 Collins St
                        Melbourne VIC 3000
                        AUSTRALIA
E-mail:           [email protected]

Office of the Australian Information Commissioner

If you have raised a complaint with us and you are dissatisfied with the outcome or have further concerns about the way we handle your personal information, under the Privacy Act, you may complain to the Information Commissioner at the Office of the Australian Information Commissioner, whose contact details are set out below:

Call:                1300 363 992
Post:               Office of the Australian Information Commissioner
                        GPO Box 5218
                        Sydney NSW 2001
Online:           www.oaic.gov.au
Email:             [email protected]

Changes to this Policy

We may change or update this Privacy Policy from time to time to keep up-to-date with legal requirements and the way we operate our business. An up-to-date version of this Privacy Policy is available at any time on this page.

You are responsible for reviewing this Privacy Policy periodically and informing yourself of any changes. We suggest that you check back regularly. If we make significant changes to our Privacy Policy, we will seek to inform you by notice via our website.

Last update: 29 January 2026