PRIVACY NOTICE FOR THANK YOU APP
INTRODUCTION
This Privacy Notice describes our practices in connection with the data collected through the “THANK YOU APP” (the “App”). .
The App is a mobile phone application for iPhone and Android devices (“Mobile Device”) created for hospital personnel, particularly those working in an intensive care unit IICU), and developed by Pfizer Inc., USA (“Pfizer” “our”, “we” or “us).The App aims to motivate ICU staff to follow protocols and exhibit a positive behaviour that can drive a reduction in the rates of hospital acquired Infections. The App also has an educational component, where the user will be able to respond to quizzes reinforcing concepts related to adequate management of infections in the ICU.
PERSONAL DATA
“Personal Data” is data that identifies you as an individual or relates to an identifiable individual. We collect Personal Data in various ways through the App, including through registrations, and automatically when you use the App.
We may request Personal Data when you use the App, including:
- Name
- Contact information (email address)
- National ID number or Medical Identification Number
We may also collect Personal Data from other sources, including data companies, publicly accessible databases and joint marketing partners. If you elect to connect your social media account to the App to enable social sharing, certain Personal Data from your social media account will be shared with us, which may include Personal Data that is part of your profile or your friends’ profiles. In addition, we may receive Personal Data from other third parties to confirm contact or financial details or to better understand your interests by associating demographic data with the Personal Data you have provided.
When you are asked to provide Personal Data, you can decline. But if you choose not to provide Personal Data that is necessary to provide requested services, we may not be able to provide you with those services.
If you provide or permit us to collect any Personal Data relating to another person, you are telling us that you have the authority to share that data and to permit us to use the data as described in this Privacy Notice.
HOW WE USE PERSONAL DATA
We use Personal Data in order to:
- Provide the App’s functionality and fulfill your requests when we have a contractual relationship or a legitimate interest in doing so, including:
- To provide customer service to you.
- To respond to your inquiries and fulfill your requests, such as to send you notifications and PIN or password resets.
- To send administrative information to you, such as information regarding the App and changes to our terms, conditions, and policies, as well as marketing communications that we believe may be of interest to you.
- To allow you to send messages to another person, such as a colleague.
- Provide personalized services when we have your consent or a legitimate interest in providing you with information of interest to you, including:
- To better understand you and personalize our interactions with you.
- To analyse or predict our users’ preferences in order to identify aggregated trend reports on how Pfizer digital content is used.
- To analyze or predict your preferences in order to improve our interactions with you, i.e., to deliver you the content, products and offers (via the App, emails, or digital tools) that we believe will be relevant to your professional interests.
- Engage with you as an HCP, when we have a contractual relationship or a legitimate interest in doing so, including:
- To interact with you based on your professional expertise and opinion by digital or other means.
- To involve you in programs/panels of healthcare professionals.
- To reach out to you for your professional expertise, for example, in the context of surveys relating to products or services of a Pfizer entity or its business partner.
- To seek your views on products and services promoted by us, an affiliate or business partner for development and improvement purposes.
- Operate our business to comply with our legal obligations and to meet our legitimate interests in maintaining our business, including:
- To conduct data analysis and audits.
- To identify usage trends in the use of our Apps and analyze the effectiveness of our communications.
- To detect, prevent, and investigate fraud, including (cyber) security monitoring and prevention.
- To develop new products and services.
- To enhance, improve, or modify our products and services.
- To validate your ability to access or use certain products or services.
- To better understand how our products and services impact you and those for whom you care.
- To track and respond to concerns, including engaging in regulatory monitoring and reporting obligations related to adverse events, product complaints, and patient safety.
- To operate and expand our business activities.
HOW WE DISCLOSE PERSONAL DATA
We disclose Personal Data as follows:
- To other Pfizer companies for the purposes described in this Privacy Notice.
- To our third-party service providers, to provide services such as data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
- To other companies with which we collaborate regarding particular products or services, such as our co-promote partners for products that we jointly develop and/or market.
- When you post data or materials on message boards, chat, profile pages, blogs and other services.
- If you elect to share data or materials through the App, please be aware that anything you post will be available to other App users and the general public. We urge you to be careful when deciding to disclose any data or materials through the App or to link your social media account.
- If you use the App to send a message or disclose any data (including using social sharing functionalities), the message or data will be available to others (e.g., other App users, your friends associated with your social media account, your social media account provider, and/or the general public).
We also use and disclose your Personal Data as we believe to be necessary or appropriate:
- To comply with applicable law and our regulatory monitoring and reporting obligations (which may include laws outside your country of residence), to respond to requests from public and government authorities (which may include authorities outside your country of residence), to cooperate with law enforcement, or for other legal reasons.
- To enforce our terms and conditions.
- To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
In addition, we may use, disclose or transfer Personal Data to a third party in connection with any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
We may aggregate the Personal Data that you and other App users provide. Provided the aggregated data does not personally identify you or any other individual, we may use and disclose such aggregated data for any purpose.
DATA COLLECTED AUTONATICALLY
We use tracking technologies to recognize you as you use or return to the App so that we can understand how the App is used, optimize user engagement with the App and customize and enhance your experience. We may also use the data collected to deliver personalized services to you. These technologies collect certain data automatically, such as:
- Data about your device, such as your screen resolution, operating system, device manufacturer and model, and language. We use this data to ensure that the App functions properly.
- Data about your use of the App, including content viewed, features used and the dates and times of your interactions with the App. We use this data to understand how users engage with the App and to customize and improve the App experience.
Analytics information is collected through a tool for mobile apps, proprietary Adobe inc. which is embedded in the App to measure user interactions. We use this aggregate information for statistical analytics purposes only, which helps us to better understand and optimize general user engagement with the App. For more information, please go to https://www.adobe.com/privacy.html.
We may collect your IP address, which is automatically assigned to your device by your Internet Service Provider. An IP address may be logged when you access the App, along with the time of the visit. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the App. We may also derive your approximate location (on a city or region level) from your IP address.
LOCATION DATA
We collect the physical location of your device by using, for example, satellite, cell phone tower, GPS or WiFi signals. We use your device’s physical location to provide you with location-based services and content. You may be able to allow or deny such collection and/or use through your device settings or the App’s privacy controls.
MARKETING CONTROLS
If you no longer want to receive marketing communications from us, contact us as indicated in the Contact Us section below. In your request, please provide your name, the types of marketing communications that you no longer wish to receive, and the addresses to which they are sent. If you opt out of receiving marketing communications from us, we may still send you important administrative messages, from which you cannot opt out.
INDIVIDUAL RIGHTS
- You may stop all collection of data by the App by uninstalling the App.
- You may stop the receipt of push notifications through your device settings.
- If you would like to request to review, correct, update, suppress, restrict or delete Personal Data that you have provided to us through the App, or if you would like to request to receive an electronic copy of such Personal Data for purposes of transmitting it to another company, you may contact us at Contact Us. We will respond to your request consistent with applicable law. You may also be able to update your profile through the App.
In your request, please tell us what Personal Data you would like to have changed, whether you would like to have it suppressed from our database, or otherwise let us know what limitations you would like to put on our use of it. For your protection, we may only implement requests with respect to the Personal Data associated with the email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain Personal Data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
You may have a right to lodge a complaint with a data protection authority competent for your habitual residence, place of work, or place of alleged infringement. Please click here for contact information for such authorities. [Link is to http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.]
DATA SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect your Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.
If you choose to share reports or other messages generated by the App with others electronically, you are advised to first check the security features of your email or other applicable communications features on your device, as they do not operate within the App.
RETENTION PERIOD
We will retain your Personal Data for as long as needed or permitted in light of the purpose(s) for which it was obtained and as outlined in this Privacy Notice. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the App to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to the enforcement of the App Terms of Use, applicable statutes of limitations, litigation or regulatory investigations).
CROSS-BORDER TRANSFER
The data we collect through the App may be stored and processed in any country where we have facilities or in which we engage service providers, including in the United States and where our affiliates operate.
Some non-European Economic Area (“EEA”) countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here [link is to the EU Commissioner’s adequacy list at http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm]). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as by ensuring that the recipient is bound by EU Standard Contractual Clauses, to protect your Personal Data. You may obtain a copy of these measures by contacting us as indicated in the Contact Us section below.
THIRD-PARTY SERVICES
This Privacy Notice does not address, and we are not responsible for, the data collection, use, disclosure or security practices, or other practices, of any third party, including any third party operating a service to which the App links. The inclusion of a link within the App does not imply our endorsement of the linked service.
USE BY MINORS
The App is not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Data from such individuals.
UPDATES
From time to time, we will update this Privacy Notice. Any changes will become effective when we post the revised Privacy Notice in the App. This Privacy Notice was last updated as of the “Last Updated” date shown above.
CONTACT US
The company responsible for collection, use, and disclosure of your Personal Data under this Privacy Notice is
Pfizer Australia Pty Ltd,
Level 17,
151 Clarence Street
Sydney, NSW, 2000
If you have questions about this Privacy Notice, or if you would like to request to exercise any individual rights, please contact us at PrivacyAus@pfizer.com, or write to the following address:
Level 17,
151 Clarence Street
Sydney, NSW, 200
You may also contact our data protection officer responsible for your country or region, if applicable. To find their contact information, visit DPO.Pfizer.com.