Collection, Use and Disclosure of Personal Information
Information about Patients
If you contact Pulmonx regarding your experience in using one of our products, including to report an adverse event (‘side effect’) or a defect or quality issue with the Pulmonx product you received, we may ask you for specific facts, including patient initials, age, and gender, and prescribing physician. We may use the information you provide in submitting reports to regulatory agencies as required by law (e.g., the U.S. Federal Food and Drug Administration, the European Medicines Agency, the Australian Therapeutic Goods Administration and the New Zealand Medicines and Medical Devices Safety Authority). We also may use the information to contact the prescribing physician to follow up regarding an adverse event (‘side effect’) involving the use of our product.
You should know that we may disclose your personal information to third parties performing work on our behalf, such as our call centre operators and other entities that assist us in responding to and processing your enquiries and product experience reports. These third parties may be located outside of Australia. We may also disclose your personal information to our related affiliates in the United States of America, Canada, and countries in Europe, Latin America and Asia-Pacific, who assist us in responding to your enquiries.
Information about Healthcare Professionals and their staff
If you are a healthcare professional we may collect personal information about you in order to conduct research and development activities, such as clinical trials or;
- Inform you of our events, products, new products and product recalls;
- Fulfil our statutory pharmacovigilance reporting obligations;
- Register you for accredited educational activities;
- Organise your travel for our events and third-party educational events sponsored by us;
- Improve our products and services and marketing activities, including conducting market research;
- Manage our relationship with you; and
This personal information includes such things as your name, contact details, speciality and qualifications, professional association membership number, details of your hospital or medical and consulting room, whether you are a member of a Pulmonx advisory board or an advisory board of a similar organisation. If you attend one of our events and/or third-party educational events sponsored by us and we arrange your travel, we may also collect your passport details and airline frequent flyer numbers.
We may collect this personal information from you (such as when you register for one of the events) or your representatives, as well as customer relationship management companies and marketing agencies.
For the purposes referred to above, we may disclose your personal information to customer relationship management companies, third-party event organisers, third party suppliers who assist us in providing our products and services (such as booking your travel and analysing personal information to improve sales targeting and recommendations), market research agencies, and others where required or authorised by law. If you are attending an international event, these services providers may be located in the country in which the event is located.
We also collect personal information regarding investigators and their staff involved in clinical trials. This information will be retained by Pulmonx Australia in a database. The database is held by Pulmonx Australia’s parent company (Pulmonx Inc. in Redwood City, California, U.S.) and accessible worldwide by Pulmonx. Pulmonx may use the database for purposes including but not limited to matching investigators to suitable trials, monitoring trial progress, and assessing administration and conduct of trial sites. Pulmonx may also share with clinical research organisations worldwide data held in the database regarding investigators where Pulmonx engages such organisations to assist in the conduct and management of a trial. Further, we may use this information to comply with our legal and regulatory obligations, including where required, disclosure to regulatory agencies (e.g., the U.S. Federal Food and Drug Administration, the European Medicines Agency, the Australian Therapeutic Goods Administration and the New Zealand Medicines and Medical Devices Safety Authority).
We may also disclose your personal information to third parties outside of Australia who provide us with technical support and assist us in enhancing our systems. In such cases, Pulmonx Australia will comply with applicable laws to which Pulmonx Australia is subject to ensure that your information is protected.
If you are a healthcare professional who provides information to us through our website, you should also read the section below.
Information about users of our website
All users of our website
We retain a record of the IP address of your computer. We will only be able to link a particular IP address to you personally if you have provided us personally identifying information whilst using our website. We may use the IP address of your computer to maintain communications with you as you move about our website and personalise website content.
- to customise your website experience by anticipating the information and services that may be of interest to you;
- to improve the functioning of our website by monitoring traffic in popular areas and to modify the services and information we provide to meet customer demand; and
- for our business purposes, including the operation of our website, as well as research and product analyses to help us better market our products.
Individuals that register to use our online information and services
If you choose to register to use our online information and services, we may also collect and use the personal information you give us (such as your name and contact details) to send you an e-mail confirming your registration and to respond to your questions. Upon your request, we may also send you e-mails with information that we think may be of interest to you, including information about our product and services.
We use contact forms to collect information enabling us to provide our services to you.
When you submit a contact form, we may ask for contact information including your name, email address, phone number (optional), and GP’s contact details so that we can reply to your inquiry. In some circumstances we may contact your GP using the details you have provided to provide general information about Pulmonx’s products to your GP / provide information relating to your referral and treatment to your GP.
Individuals that participate in our online interactive services
If you choose to participate in our online interactive services (including health questionnaires and care management tools), we will collect the personal information you choose to disclose (which may include health information) and analyse it to discover new facts that could help us better understand how our products are used in coping with the diseases for which they are marketed. Although the information you provide through these interactive services may not identify you, we may link it with other information you provide us elsewhere on our website which does identify you. We may combine this information with that from other website users to create summary data that we will use for our business purposes, including research and analysis to improve our products and help us better market our products.
Cookies and other tools
Pulmonx and its business partners, in common with many website operators, may use standard technology called cookies on its websites. Cookies are small data files that are downloaded onto your computer when you visit a particular website. Cookies help provide additional functionality to the website or to help us analyse site usage more accurately. We use information collected from cookies to better understand, customise and improve user experience with our websites, services and offerings, as well as to manage our advertising. For instance, our server may set a cookie that keeps you from having to enter a password more than once during a visit to one of our sites. Also, we may use web analytics services that leverage cookies to help us to understand how visitors engage with and navigate our site (e.g. how and when pages in a site are visited and by how many visitors).
We are also able to offer our visitors a more customised, relevant experience on our sites using cookies by delivering content and functionality based on your preferences and interests. If you have provided us with personal information (e.g. through a registration or a request for certain materials), we may associate this personal information with information gathered through cookies. This allows us to offer increased personalisation and functionality.
In all cases in which cookies are used, the cookie will not collect personal information except with your explicit permission. Your web browser can be set to allow you to control whether you will accept cookies, reject cookies or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognise you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies.
In addition, we may use other tracking systems like pixel-tags. Pixel tags, sometimes called web beacons, are similar in function to cookies but because of their insignificant size, they are not visible. However, they are used to pass certain information to our servers to personalise our websites and to track your usage across other Pulmonx websites. In addition, we may also use pixel tags in our HTML based emails.
For more information about cookies, visit www.aboutcookies.org.
Information about other individuals
If you communicate with or request information from Pulmonx personnel, they will have your e-mail address as well as any personal facts you choose to include in your communication.
We have relationships with different vendors and suppliers who help us design and maintain our computer systems and security, respond to e-mail and customer inquiries, analyse our data and create special promotions. We will not authorise our vendors and suppliers to use our customer information for any purposes unrelated to our contractual relationship with them.
Links to Other Websites
Pulmonx Australia’s website features links to other websites that we believe you might find useful and informative. Please be aware, however, that we do not endorse or recommend these websites’ content or services, and we are not responsible for the privacy practices of these other websites. We encourage you to be aware of and read the privacy statement of each website you visit. Remember, the statements in this Privacy Statement apply solely to information collected by Pulmonx Australia and Pulmonx Inc.
Our Children’s Policy
Pulmonx Australia’s website content and services are intended for adult users over the age of 15. The website is not designed to attract child users. If we learn that an under-15 user has volunteered personal information (including health information) on our website, or that a provider has volunteered information about a patient who is identified as younger than 15, we will delete such information from our active databases in accordance with our deletion practices, which is described in the section titled, ‘How We Hold and Protect Personal Information’ except as required to fulfil our pharmacovigilance reporting obligations.
Your Privacy Choices (including access and correction of personal information and Privacy Complaints)
- Online collection opt-in: When you access any interactive tool or service on our website, you will be asked to affirmatively choose (“opt-in”) to provide the requested information. You may always choose not to provide the requested information.
- Accept Cookies: Your browser software can be set to reject all cookies. However, if you reject our cookies, certain areas of our website’s functions may not work properly. To find out more about cookies, and how you can decline to accept them, please refer to your Internet browser’s instructions or help option.
- Access and Correct/Update Personal Information: You have a right to request to access or correct/update your personal information (including your health information). You may make such a request at any time, by contacting our Privacy Officer on the details set out at the end of this Privacy Statement. We will provide you with access to the information we hold about you, and/or correct/update that information unless there is an exception that applies under the Australian Privacy Principles. In particular, we may not be able to amend your personal information if it was provided to us by a health care professional, or a consumer regarding an adverse event.
- Remove Personal Information: You may request that Pulmonx delete/erase previously provided personal information (including health information) by contacting our Privacy Officer on the details set out at the end of this Privacy Statement. Legal requirements in some countries may prevent us from deleting certain personal information. In particular, we may not comply with a consumer’s request to delete information that was provided to us by a health care professional or a consumer regarding an adverse event.
It is not technologically possible to remove from our servers each and every record of your information. The need to back-up our systems to protect information from inadvertent loss means that a copy of information about you (including your health-related interests) may exist in a non-erasable form that will be difficult or impossible for us to locate.
Nevertheless, when permitted by law, Pulmonx will delete your personal information (including health information) stored in the databases Pulmonx actively uses for research and daily business activities or stored in other readily searchable media. In addition, we will use reasonable efforts not to disclose any personal information stored in a non-erasable format after receiving your request for removal, except as required by law.
- Make a Privacy Complaint. If you wish to make a complaint about our handling of your personal information, please contact our Privacy Officer on the details set out at the end of this Privacy Statement. You will be asked to submit your complaint in writing. We will respond to your complaint as soon as practicable. If you are a participant in a clinical trial, your complaint may be referred to the principal investigator for the clinical trial.
If you are not satisfied with our response to your complaint, you may also contact the Office of the Australian Information Commissioner as follows:
How we hold and Protect Personal Information
We hold your personal information in a combination of hard copy and electronic files. Electronic files are stored in servers that are operated and maintained by Pulmonx and third parties under contract with Pulmonx
We want your personal information to remain as secure as reasonably possible. To help ensure the integrity and confidentiality of the personal information (including health information) you provide to us, we may use encryption practices. As an added security precaution, all personal information (including health information) is kept physically behind firewalls and other network security devices to prevent intruders from gaining access.
If you have any questions or comments about this Privacy Statement, or wish to access or correct your personal information or make a privacy complaint, please contact our Privacy Officer at:
Attn: Privacy Officer
Pulmonx Australia Pty Ltd
Suite 5, Level 6, 65 York Street,
Sydney NSW 2000
Tel: +61 1300 785 666
The Privacy Statement is effective at August 2018
We may change the terms of this Privacy Statement at any time by posting revisions to our website. We will let you know of any changes to this Statement by posting a notification on our website.