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Privacy Notice to Healthcare Professionals

Last updated: 16 April 2020

 

  1. Background

This privacy notice (“Notice”) sets out how Tillotts Pharma AG and its wholly-owned affiliates[1] (“Tillotts”, “Tillotts Group” or “we”) wishes to provide you with information on how we handle your personal data and to obtain your consent for specific purposes as outlined below.

  1. What types of personal data are collected and why

a. Customer relationship management

We maintain a customer relationship management system where we may store personal data about you:

Contact Information”: This category of personal data encompasses e.g. your name, address, phone/fax/mobile-number, e-mail or other online contact information. We receive Contact Information from personal contacts with you or from commercial address traders as well as from publicly available sources, e.g. websites. We use your Contact Information in order to promote our products and services or deliver urgent medical information regarding our products.

Information about your interests”: Aiming at continuously improving your experience with our products and services, we also document and analyze our personal contacts with you, e.g. when we show you tablet-based materials. For this purpose, we document which topics have been shown to you, for how long and in which order as well as your reaction to individual topics. We may also document data on your medical practice, including numbers of patients, patient categories, participation in clinical studies and training activities, as well as your prescribing of medicines and data regarding your professional experience or professional activities gathered from public sources.

b. Market research studies

We work together with fully independent market research agencies, who, on our behalf, conduct market research studies globally, focused on our scientific interests and products. We may share your Contact Information with these market research agencies in order to conduct market research studies that are specific to our customers.

c. Deliver electronic marketing/medical communications

We may use your Contact Information to communicate with you through phone calls, direct mail, e-mail or other electronic communication (e.g., fax, chats on websites, text messages, messenger messages or remote detailing/incl. customer services on demand) in order to deliver marketing/medical communications containing information about services, products or events related to your medical interest. However, marketing/medical communications via e-mail or other electronic communications (“Electronic Marketing/Medical Communications”) as well as via phone calls are subject to you providing your consent.

d. Analyses of your use of our Electronic Marketing/Medical Communications

In order to customize our Electronic Marketing/Medical Communications to meet your needs and preferences and subject to you providing your consent, we may analyze your use of our Electronic Marketing/Medical Communications, for example whether you opened and how you used our Electronic Marketing/Medical Communication (e.g. which links you clicked). 

  1. Data processing

Information related to you may be made available to third parties who work with Tillotts, such as third parties providing logistical or administrative services. In all such cases, Tillotts will ensure that such third party is bound to ensure a level of protection appropriate to the personal data and consistent with applicable law.

  1. Legal basis for collection and processing

If not stated otherwise elsewhere in this Notice, we collect and process your personal data for certain legitimate business interests which include the purposes set forth under Section “What types of personal data are collected and why” above.

In addition, we are legally obliged to make sure that your personal data is accurate and, where necessary, kept up-to-date.

Whenever we process your personal data for our legitimate business interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under applicable data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). If you have any concerns about the processing of your personal data, you have the right to object to processing that is based on our legitimate business interests. For more information on your rights, please see Section “Your Data Protection Rights” below.

  1. Retention of personal data

We will keep your personal data for only as long as needed to meet the purpose of the processing and in line with applicable legal, regulatory or other requirements. If we have no longer any legitimate business need to process your personal data, we will delete your personal data. Statutory retention periods remain unaffected.

  1. Transfer of personal data

We transfer or give access to your personal data to third parties in the following circumstances:

a. We use specialized service providers that help us providing our services. Such service providers are carefully selected and regularly monitored by us. Based on respective data processing agreements, they will only process personal data upon our instructions and strictly in accordance with our directives.

b. We may share your Contact Information with fully independent market research agencies as described above in under Section “What types of personal data are collected and why” above.

c. We may transfer your above-referenced personal data within the Tillotts Group depending which Tillotts entity needs to be involved in managing a service or communication towards you. However, any Tillotts entity will only directly deliver corresponding marketing communications via e-mail or other electronic communications to you if you provide your consent.

d. Your data may in part also be transferred and processed in countries outside Switzerland and the European Economic Area (“EEA”), which may have a lower data protection level. In such cases, we will ensure that a sufficient level of protection is provided for your data, e.g. by concluding specific agreements with the respective data importer.

  1. Security

We use appropriate technical and organisational measures to protect your personal data. The measures we use are designed to provide a level of security commensurate with the risks related to the processing your personal data.

  1. Your data protection rights

You have the following data protection rights:

  • You may access, correct, update or request deletion of your personal data.
  • You may object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data.
  • You can also withdraw your consent at any time if we have collected and processed your personal data with your consent. Withdrawing your consent has no impact on the legality of the processing we performed prior to your withdrawal nor does it impact the processing of your personal data if a legal basis other than your consent exists.
  • You have the right to complain to a data protection authority about our collection and use of your personal data.

You may contact Tillotts at any time with a request to exercise your data protection rights, at no cost to you, at the postal address of the local Tillotts entity, or by email.

You will receive a response to your request in accordance with applicable data protection laws.

[1] Affiliates include: Tillotts Pharma AB (Sweden), Tillotts Pharma GmbH (Germany), Tillotts Pharma UK Ltd., Tillotts Pharma Limited (Ireland), Tillotts Pharma Spain S.L.U., Tillotts Pharma France S.A.S., Tillotts Pharma Czech s.r.o.