Privacy Policy

1. About this Privacy Policy

Respien Pty Ltd (ABN 67 134 154 680) (Respien, we, us or our) is an Australian clinical-stage biotechnology company developing therapies for chronic respiratory diseases.

Respien respects your privacy and is committed to handling personal information responsibly and transparently.

This Privacy Policy explains how we collect, hold, use and disclose personal information, including information collected through:

• our website;
• website forms and email communications;
• telephone and other direct enquiries;
• investor, partnering and business development communications;
• media and professional enquiries;
• recruitment activities;
• events, presentations and mailing lists;
• our social media channels;
• interactions with suppliers, advisers, researchers, healthcare professionals and other stakeholders; and
• other interactions with Respien.

We handle personal information in accordance with the Privacy Act 1988 (Cth), including the Australian Privacy Principles, where those requirements apply to us.

Specific privacy notices or consent forms may apply to clinical trials, research studies, healthcare activities or other programs. Those notices should be read together with this Privacy Policy. If there is any inconsistency, the more specific notice will apply to the relevant activity.

2. What is personal information?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.

Depending on how you interact with us, the personal information we collect may include:

• your name;
• your job title, employer and professional qualifications;
• your email address, telephone number and postal address;
• information included in correspondence, enquiries or forms you submit;
• information about your relationship or interactions with Respien;
• records of meetings, telephone calls and other communications;
• your communication and subscription preferences;
• information contained in a job application, résumé or professional profile;
• information relating to suppliers, advisers, investors, potential partners and other business contacts;
• publicly available professional information; and
• technical information collected when you use our website.

3. Sensitive information

Sensitive information is a category of personal information that includes health information, genetic information and certain other information given additional protection under Australian privacy law.

Respien’s general website is not intended to collect health information or provide individual medical advice.

Please do not submit medical records, detailed health information, adverse event information or other sensitive information through a general website contact form unless it is necessary for your enquiry.

Where we collect sensitive information, we will generally do so with your consent or where otherwise permitted or required by law.

Clinical trial participants and research participants will ordinarily receive separate information explaining how information relating to the relevant trial or study will be collected, used and protected.

4. How we collect personal information

We generally collect personal information directly from you when you:

• submit a form through our website;
• contact us by email, telephone or another communication channel;
• subscribe to updates or communications;
• attend a meeting, presentation, conference or event;
• engage with us through social media;
• apply for a role with Respien;
• provide services to, or conduct business with, Respien;
• communicate with us regarding a potential investment, partnership, licence, collaboration or other business opportunity; or
• otherwise provide information to us.

We may also collect personal information from:

• your employer or organisation;
• professional advisers, service providers or business partners;
• recruitment agencies and referees;
• publicly available sources, including professional directories, company websites and professional networking platforms;
• conference organisers and industry associations;
• healthcare, scientific and research organisations, where permitted; and
• third parties where you have authorised the disclosure or where collection is otherwise permitted by law.

If you provide us with personal information about another person, you should ensure that you are authorised to do so and, where appropriate, make them aware of this Privacy Policy.

5. Information collected through our website

When you visit our website, our systems and those of our service providers may automatically collect technical information such as:

• your internet protocol address;
• browser type and version;
• device type and operating system;
• approximate geographic location;
• referring website;
• pages viewed and links selected;
• dates and times of access;
• session duration; and
• website performance, error and security information.

This information may be collected through server logs, cookies, pixels, tags, analytics services and similar technologies.

Some technical information may be personal information when it identifies you or can reasonably be linked with other information about you.

6. Cookies and similar technologies

Cookies are small data files stored on your device when you visit a website.

We may use cookies and similar technologies to:

• operate and secure the website;
• remember preferences;
• understand how visitors use the website;
• monitor website performance;
• identify and resolve technical issues;
• measure the effectiveness of communications; and
• improve the website and user experience.

The website may use third-party services, such as website hosting, analytics, embedded video, content delivery, security or social media services. These providers may place or access cookies or collect technical information in accordance with their own privacy policies.

For example, embedded videos may allow the relevant video-hosting provider to collect information about your device and interaction with the video. Social media links and embedded content may similarly allow the relevant platform to collect information.

You can usually control or disable cookies through your browser settings. Disabling some cookies may affect the operation or functionality of the website.

Where required, we may use a cookie-management tool to provide further information and choices regarding non-essential cookies.

7. Why we collect and use personal information

We may collect, hold, use and disclose personal information to:

• respond to questions, requests and enquiries;
• communicate with you;
• provide information about Respien, our research, development programs and corporate activities;
• manage investor, partnering, licensing, collaboration and business development activities;
• manage relationships with researchers, healthcare professionals, advisers, suppliers and other stakeholders;
• organise meetings, events and presentations;
• assess employment applications and manage recruitment;
• maintain business and professional records;
• administer contracts and business arrangements;
• operate, secure, maintain and improve our website and systems;
• perform analytics and understand engagement with our communications;
• protect our legal rights and manage risks;
• prevent, identify and investigate fraud, misuse or security incidents;
• comply with legal, regulatory, reporting and governance obligations; and
• carry out other purposes disclosed to you at the time information is collected.

We may also use personal information for a related purpose that you would reasonably expect, where permitted by law.

8. Marketing and company communications

We may send you news, company updates, event invitations or other communications where:

• you have consented to receive them;
• consent can reasonably be inferred from our relationship with you; or
• the communication is otherwise permitted by law.

You can unsubscribe from marketing communications at any time by using the unsubscribe facility included in the communication or contacting us.

We may still send non-marketing communications where necessary, including responses to your enquiries and communications relating to an existing business relationship.

Submitting a general enquiry does not automatically mean that you will be added to a marketing list.

9. When we disclose personal information

We may disclose personal information to:

• our directors, officers, employees and contractors;
• related or affiliated entities;
• website hosting, information technology, analytics, cybersecurity and data-storage providers;
• email, communications, customer relationship management and collaboration-platform providers;
• professional advisers, including legal, accounting, financial, insurance and corporate advisers;
• research institutions, clinical research organisations and scientific collaborators, where relevant and appropriately authorised;
• recruitment agencies and service providers;
• event organisers and communications providers;
• prospective or actual investors, licensees, collaborators, transaction counterparties or funding partners, subject to appropriate confidentiality and legal arrangements;
• government agencies, regulators, courts and law-enforcement bodies;
• parties involved in a proposed or actual corporate transaction, restructuring, financing, merger, acquisition or sale; and
• other parties where you have consented or where disclosure is permitted or required by law.

We do not sell personal information.

10. Overseas disclosures

Some of our service providers, advisers, collaborators, research partners and potential commercial partners may be located outside Australia or may store or process information using systems located overseas.

The countries in which recipients or data-storage facilities may be located can vary depending on the services and collaborations we use. These countries may include the United States, the United Kingdom, countries in the European Economic Area and other jurisdictions in which our service providers, advisers or partners operate.

Where required, we take reasonable steps to ensure that overseas recipients handle personal information appropriately and in accordance with applicable Australian privacy requirements.

However, overseas privacy laws may differ from Australian privacy laws.

For more information about relevant overseas disclosures, please contact us using the details below.

11. Data security

We take reasonable technical, organisational and physical measures to protect personal information from:

• misuse;
• interference;
• loss;
• unauthorised access;
• unauthorised modification; and
• unauthorised disclosure.

These measures may include access controls, secure systems, password protection, staff and contractor confidentiality obligations, service-provider assessments and procedures for managing security incidents.

No internet transmission, electronic system or method of storage is completely secure. We cannot guarantee the absolute security of information transmitted electronically.

12. Data breaches

We maintain processes for responding to suspected or actual data breaches.

Where a data breach is likely to result in serious harm and the requirements of the Notifiable Data Breaches scheme are met, we will notify affected individuals and the Office of the Australian Information Commissioner as required by law.

13. Retention and destruction

We retain personal information only for as long as reasonably necessary for:

• the purpose for which it was collected;
• a related business or operational purpose;
• legal, regulatory, insurance, governance or record-keeping requirements;
• managing disputes or potential legal claims; or
• other purposes permitted by law.

When personal information is no longer required, we take reasonable steps to securely delete, destroy or de-identify it, subject to legal and operational requirements.

14. Remaining anonymous

Where lawful and practicable, you may interact with us anonymously or using a pseudonym.

In some circumstances, however, we may need your identity or contact information to respond to an enquiry, assess a request, enter into a business arrangement or comply with legal obligations.

15. Access to and correction of personal information

You may request access to personal information we hold about you or ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading.

To make a request, contact us using the details below. We may need to verify your identity before processing the request.

We will respond within a reasonable period. In some circumstances permitted by law, we may refuse access or correction. If this occurs, we will generally explain the reasons for the decision and the available complaint mechanisms.

We do not ordinarily charge for making an access or correction request. We may charge reasonable administrative costs where permitted by law and will inform you beforehand.

16. Recruitment information

If you apply for employment or another role with Respien, we may collect information including:

• your employment and education history;
• professional qualifications;
• résumé and application information;
• references;
• work eligibility;
• interview notes; and
• information relevant to assessing your suitability for the role.

We may disclose recruitment information to recruitment providers, referees, advisers and service providers involved in the recruitment process.

If your application is unsuccessful, we may retain your information for a reasonable period to manage our recruitment records or consider you for future opportunities, unless you ask us not to.

17. Third-party websites and services

Our website may contain links to websites or services operated by third parties.

Respien is not responsible for the privacy practices, security or content of third-party websites or services. We encourage you to review the applicable third party’s privacy policy before providing personal information.

18. Children and young people

Our website is intended for a general corporate, scientific and professional audience and is not directed specifically to children.

We do not knowingly seek to collect personal information from children through the general website. A parent, guardian or authorised representative should contact us if they believe a child has provided personal information to us without appropriate consent.

Separate consent, ethics and privacy requirements may apply where children or young people participate in an authorised clinical trial or research activity.

19. Complaints

If you have a concern or complaint about how we have handled your personal information, please contact us using the details below.

Please provide sufficient information for us to understand and investigate your concern. We will acknowledge and respond to your complaint within a reasonable period.

If you are not satisfied with our response, you may be entitled to contact the Office of the Australian Information Commissioner.

20. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time to reflect changes to our activities, systems, services or legal obligations.

The current version will be published on our website with its effective date. We encourage you to review this Privacy Policy periodically.

21. Contact us

For questions, access or correction requests, privacy complaints or further information, please contact:

Privacy Officer
Respien Pty Ltd
ABN 67 134 154 680
Email: info@respien.com
Postal address: Level 10, 30 Collins Street, Melbourne, Victoria, Australia 3000

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