Privacy notice for HCPs

Santen Pharmaceuticals Co. LTD and its Affiliates (hereinafter “Santen”) is strongly committed to protecting your privacy, and will make efforts to protect your personal data (“Personal Data”) in accordance with this Privacy Notice (“Notice”) which applies to the Personal Data that it collects and processes about health care professionals and employees/representatives of healthcare organizations.

Data Controller and Data Protection Officer (“DPO”)

Each Santen entity is acting as a Data Controller for the purposes of this Notice when processing Your Personal Data. You can find more information on Santen affiliates in Europe and worldwide as well as their establishment and contact details here:
https://www.santen.eu/contact.

Santen Privacy EMEA Office and the designated Data Protection Officer (DPO) are responsible for supervising and monitoring Santen’s compliance with applicable data protection laws and regulations when processing your Personal Data.

Santen Privacy EMEA Office and the appointed DPO can be contacted via email at: privacy-emea@santen.com.

Personal Data Santen collects and source

Santen collects and processes Personal Data about you. The types of Personal Data Santen collects depend on your relationship with Santen as well as applicable laws, but may include the following categories of information:

• Basic personal details such as identity and contact information;
• Educational and professional details such as qualifications and organisational or institutional affiliations;
• Payments related information, where necessary.

This information may come directly from you or from public or third-party information sources.

To better understand and address your interests, and to ensure that the Personal Data that Santen maintains and processes about you is accurate, Santen may correct or add to any Personal Data you provided directly to Santen with Personal Data relating to you that Santen receives from other third-party sources.

Lawfulness of processing

Santen processes Personal Data based on one or more of the following legal grounds:

• In certain cases, Santen may ask for your consent to collect and process your Personal Data. Should you choose to provide your consent, you may later withdraw your consent without giving any reason by contacting us as described in the “How to Reach Us” section. Please note that the withdrawal of consent will not affect processing by Santen which has already occurred up to the date of withdrawal.
• In other instances, the processing of your Personal Data may be necessary in order to comply with an applicable law or regulation or for the performance of a contract to which you are subject. You may not be able to opt-out of this processing, or your choice to opt-out may impact our ability to perform a contractual obligation otherwise owed to you.
• In still other instances, Santen may process your Personal Data based on Santen’s legitimate interests in communicating with you about our products and services, about scientific research and/or about educational opportunities. You have the right to opt-out of all such processing of your Personal Data. You may do so by contacting us as described in the “How to Reach Us” section.

How Santen uses the Personal Data

Santen processes Personal Data about you for one or more of the following purposes:

• To perform Santen’s obligations under a contract to which you are a party;
• To comply with applicable laws or regulations 
• To publicly disclose any transfers of value made to you, as a Health Care Professional, as required by law or in order to comply with applicable industry standards (further information relating to this purpose is available here: https://www.santen.eu/data-privacy/disclosures-of-transfers-of-value); 
• To carry out promotional activities to you, subject to other applicable regulatory provisions (e.g. e-Privacy Directive); 
• To provide to you, on your request, medical and scientific information (further information relating this purpose is available here: https://www.santen.eu/data-privacy/handling-of-medical-information); 
• To handle adverse events reports or quality complaints (further information relating to this purpose is available here: https://www.santen.eu/data-privacy/handling-of-medical-information); 
• To send to you invitations to promotional or scientific events;
• To invite you to share with Santen your professional insights, surveys and market research data; and/or
• To collect and analyse your interests and professional insights to improve our profile of you as an HCP to provide you with targeted advertising and further enhance the business relationship we have with you (this profile may include your age and gender, ethnicity, medical specialty, prescription habits and others

The information provided above will be shared via Santen e-communications channels e.g. send you customized or non-customized email and internet communications or to contact you at your office or mobile telephone number (by call or messages), by fax, by the post or through Santen’s social media.

Santen shall use your Personal Data only for the purposes specified in this section; processing of your Personal Data for any other purpose will be carried out only through prior notification and your specific consent to processing such Personal Data for any possible secondary use or for further purposes.

With whom Santen shares your Personal Data

Santen may transmit Personal Data about you to other Santen affiliates worldwide. These affiliates may in turn transmit Personal Data about you to other Santen affiliates. Santen may also contract with third parties (third party service providers) to perform wholly or partly activities or functions related to the purposes specified above on behalf of Santen that involve the use of Personal Data about you. In such cases, Santen will require these third parties to comply with applicable data protection laws or regulations and Santen policies to protect the confidentiality and security of the Personal Data that is shared with them. These third parties will be required to agree that they will not use or disclose Personal Data about you except as necessary to provide services to us or perform services on our behalf, or as necessary to comply with applicable laws or regulations.

Moreover, all of Santen’s affiliates and third-party data processors acting for and on behalf of Santen are required to treat Personal Data in a manner consistent with applicable data protection laws and internal company policies including this Notice.

Some of Santen’s group companies and/or third-party service providers may be located in countries outside of the European Union and/or the European Economic Area (“EEA”), whose laws may not afford your Personal Data the same level of data protection as the one afforded inside the EU/EEA. Where your Personal Data will be transferred to third countries, Santen will ensure that all adequate safeguards are in place and that all applicable laws and regulations are complied with in connection with such cross-border data transfers; in particular by adopting in its contractual arrangements the execution of standard contractual clauses for cross-border data transfers for Controllers and Processors, as approved by the EU Commission or the competent data protection national supervisory authority, as well as by implementing appropriate technical and organisational security measures to ensure the security of the processing.

In the event Santen decides to reorganise or divest our business through sale, merger, or acquisition, Santen may share Personal Data about you with actual or prospective purchasers. Santen will require any actual or prospective purchasers to treat this Personal Data in a manner consistent with this Notice.

In addition, for the aforementioned purposes, Santen transfers some of your Personal Data, according to a strict criterion of relevance, to authorities as well as to other external governmental bodies, having the power to execute checks and investigations towards Santen in fulfilment of legal obligations or regulations. These authorities and institutions will act as independent data controllers of their respective processing operations.

To obtain a full list of Santen’s data processors and categories of data controllers as well as additional information regarding the safeguards Santen has in place for cross-border transfers of Personal Data, please contact us using the information provided in the “How to Reach Us” section.

How Santen protects your Personal Data

Santen will take reasonable and appropriate physical, administrative and technical safeguards to protect the processing of your Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. In this perspective, the data may be used only by Santen’s personnel who need it because of their job or hierarchical position, with confidentiality obligations, which have been assigned a specific role and which have been given appropriate operating instructions.

Your rights and how to exercise them

Individuals in the EU have certain data subject rights which may be subject to limitations and/or restrictions. These rights include the right to: (i) request access to and rectification or erasure of their Personal Data; (ii) restrict processing, or to object to processing of their Personal Data; and (iii) the right to data portability. If you wish to exercise one of the above-mentioned rights, please refer to the “How to Reach Us” section below.

You also have the right to ask Santen not to process your Personal Data for marketing purposes. Santen will usually inform you (before collecting your data) if it intends to use your data for such purposes or if it intends to disclose your information to any third party for such purposes. You can exercise the right to prevent such processing by informing Santen at any time that you do not wish to receive such marketing. Where you wish to exercise this right please refer to the “How to Reach Us” section below.

If you do not receive a (timely) response from Santen or if you are not satisfied with our response to you, you also have the right to lodge a complaint about the processing of your Personal Data with the appropriate national Data Protection Authority; a list of the national Data Protection Authorities in Europe and their contact details can be found here:
https://edpb.europa.eu/about-edpb/board/members_en

How long Santen retains Personal Data

Personal data will only be stored as long as necessary to fulfil the purposes and respective obligations related to such data, for which it was collected, subject to local laws and regulations and legitimate business needs in accordance with Santen internal policies.
However, as these purposes and obligations vary from one processing situation to another, Santen provides more information on such storage periods in the topic specific privacy notices. Once Personal Data is no longer necessary, Santen deletes it or anonymizes it as soon as possible.

How to reach us

For the access, rectification, deletion and restriction of processing and to exercise the right of withdrawal or any other right about the processing of your Personal Data, or if you feel that any of your rights relating to the collection or use of your Personal Data have been violated, you may contact our Privacy EMEA Office by email at: privacy-emea@santen.com

Last updated: April 3rd, 2019.