PFIZER EEA WEBSITE PRIVACY NOTICE
This Privacy Notice (“Privacy Notice”) describes the data that we collect about you on the website from which you linked (“Site”); how we use and disclose that data; how we protect it; and the choices you may make with respect to it. We encourage you to review our Privacy Notice and click on the available links or select “read more” if you want additional information on a particular topic.
We process your data in an appropriate and lawful manner, in accordance with the Data Protection Act (Chapter 586 of the Laws of Malta), as may be amended or replaced from time to time, and the General Data Protection Regulation (Regulation (EU) 2016/679).
If you are a healthcare professional (“HCP”), please also see our HCP Privacy Notice for additional information about how we process personal data about you.
“Personal Data” is data that identifies you as an individual or relates to an identifiable individual. We collect Personal Data in various ways on our Sites, including through registrations, applications, surveys, in connection with your inquiries, and automatically when you browse our Sites.
We may request basic Personal Data when you use a Site; if you are an HCP, we may request additional Personal Data.
→ Personal Data that we may request includes:
- Contact details (postal address, telephone numbers, email address)
- Your preferred language
- Your interests (such as health conditions and topics about which you request information through the Site or indicate interest)
→ If you are an HCP, we also may request additional data related to our professional interaction with you:
- Professional biography/credentials
- Data related to your licensures, specialties, professional affiliations, publications, credentials, and other professional achievements
- Adverse event data
- Data related to your use of our products, your interactions with us, and services for those you care for
We may also collect Personal Data from other sources, including data companies, publicly accessible databases, joint marketing partners, social media platforms and other third parties.
→ If you elect to connect your social media account to the Site 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.
→ 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 may decline. But if you choose not to provide data that is necessary to for us to provide requested services, we may not be able to provide you 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 Site functionality and fulfill your requests when we have a contractual relationship or a legitimate interest.
→ Site functionality and fulfilling your requests includes:
- To provide customer service to you.
- To respond to your inquiries and fulfill your requests and complete your transactions.
- To send administrative information to you, such as changes to our terms, conditions and policies, as well as marketing communications that we believe may be of interest to you.
- To facilitate social sharing functionality.
- To allow you to send messages to another person, such as a colleague, caregiver or friend or patient.
- Provide personalized services when we have your consent or a legitimate interest in providing you with information of interest to you.
- Provide personalized services when we have your consent or a legitimate interest in providing you with information of interest to you.
→ Personalized services include:
- 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 our Site, 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.
→ Engaging with you as a health care professional includes:
- 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 collaborate with you on medical events, publications, or advisory meetings.
- To seek your views on products and services promoted by us, an affiliate or business partner for development and improvement purposes.
- Allow you to participate in special programs, activities, events, or promotions as part of our contractual relationship with you or where we have a legitimate interest.
→ In these cases, we may use your Personal Data in additional ways disclosed as part of these special program, activites, events or promotions.
- Operate our business to comply with our legal obligations and to meet our legitimate interests in maintaining our business.
→ Our business activities include:
- To conduct data analysis and audits.
- To identify usage trends in the use of our Sites and analyze the effectiveness of our communications.
- To detect, prevent, investigate fraud and including (cyber) security monitoring and prevention.
- To develop, enhance, improve or modify our products and services.
- To validate your ability to acess 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.
We may aggregate the Personal Data that you and other Site users provide. If we do, we may use and disclose such aggregated data for any purpose. Aggregated data does not personally identify you or any other individual.
HOW WE SHARE AND DISCLOSE PERSONAL DATA
We disclose Personal Data as follows:
- To other Pfizer companies for the purposes described in this Privacy Notice. [need someone IN BT to look into how we link to this]
- To our third party service providers, to provide services such as website hosting, 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. These may include 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 our Site, please be aware of the following:
- Anything you post will be available to other Site users and the general public.
- Be careful when deciding to disclose any data or materials through the Site or to link your social media account.
- When using the Site to send a message or disclose any data or materials (including using social sharing functionalities), the message, data or materials will be available to others (e.g., other Site 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).
DATA COLLECTED AUTOMATICALLY
When you visit the Site, we collect data automatically through your browser or device, through your use of the Site, or using cookies and similar technologies. Please refer to our Cookie Notice for additional information about these practices.
If you no longer want to receive marketing communications from us, contact us as indicated in the Contact Us section, or on some Sites update your preferences in your profile or account. In your request, please provide your name and the addresses where you no longer wish to be contacted. If you opt out of receiving marketing communications from us, we may still send you important administrative messages, from which you cannot opt out.
You have the following rights in relation to your personal data:
- Right to information: You have the right to ask us for the personal data (about you) that is being processed and the rationale for such processing.
- Right to access: You have the right to access your personal data that is being processed, to review and also to request copies of such personal data.
- Right to rectification: You have the right to ask for modifications to your personal data in case the data is not up to date or accurate.
- Right to withdraw consent: You have a right to withdraw a previously given consent for processing of your personal data.
- Right to object: You have a right to object to the processing of your personal data while we are relying on a legitimate interest (or those of a third party) in the event that processing will impact your fundamental rights and freedoms.
- Right to object to automated processing: You have a right not to be subject to a decision based solely on automated processing (including profiling) if these decisions produce legal effects or similarly significantly affects you. However, automated processing may be undertaken if this is necessary to enter into or perform a contract between the data subject and the controller or it is authorised by the EU or Member State law to which the controller is subject (and lays down suitable measures to safeguard the data subject’s rights, freedom and legitimate interests) or it is based on the data subject’s express consent.
- Right to be forgotten/erasure: You have a right to ask for the deletion of your data where the professional relationship has ended. It is important to note however that in certain cases we may be entitled to decline your request especially in instances where your data is needed to comply with a legal obligation which requires processing by Union or Member State law to which we are subject; or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; or for the establishment, exercise or defence of legal claims.
- Right for data portability: You have a right to ask for transfer of your personal data back to you or transferred to another controller. When doing so, the personal data must be provided or transferred in a machine-readable electronic format.
On some Sites, you have the opportunity to update your profile through the Site.
If you would like to request to review, correct, update, suppress, restrict or delete Personal Data that you have provided to us through the Site, 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 as indicated in the Contact Us section. We will respond to your request consistent with applicable law.
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 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.
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.
The data we collect through the Site may be stored and processed in any country where we have facilities or in which we engage service providers, including in the U.S. and where our affiliates operate.
Some non-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. 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.
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 Site links. The inclusion of a link within the Site does not imply our endorsement of the linked service.
USE BY MINORS
The Site is not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Data from such individuals. If you are under the relevant age of consent in your jurisdiction, you will need your parent’s or legal guardian’s permission to use the Site. Please consult with your parent or legal guardian before using the Site.
If you are providing us with Personal Data of individuals under the age of sixteen (16), you represent that you have the appropriate authority to do so, and that you can demonstrate such authority to Pfizer upon request.
From time to time, we will update this Privacy Notice. Any changes will become effective when we post the revised Privacy Notice on the Site. This Privacy Notice was last updated as of the “Last Updated” date shown above.
The company acting as the Data Controller by the current relevant data protection laws and regulations, and which is responsible for the collection, use and disclosure of your Personal Data under this Privacy Notice is:
PFIZER HELLAS SA INDUSTRIAL AND COMMERCIAL COMPANY OF PHARMACEUTICAL, CHEMICAL PRODUCTS AND FEED.
243 Mesogeion Avenue, Neo Psychiko Athens Greece, 154 51
If you have questions about this Privacy Notice, or if you would like to request to exercise any individual rights, please contact us to the above-mentioned address respectively.
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.
LODGING A COMPLAINT WITH A REGULATOR
You may lodge a complaint with the competent supervisory authority on data protection matters, the Office of the Information and Data Protection Commissioner (https://idpc.org.mt/en/Pages/Home.aspx).
Cookies are a standard feature of websites that allow us to store small amounts of data on your computer about your visit to our Site. Cookies help us learn which areas of the Site are useful and which areas need improvement.
You can find information about cookies that we use and change your settings for cookies and similar technologies by clicking on the Cookie Consent Tool in the lower right corner of each page of our Site. In addition, you can refuse or accept cookies from the Site at any time by activating the settings on your browser. Information about the procedure to follow in order to enable or disable cookies can be found on your Internet browser provider’s website via your help screen. Please refer to http://www.allaboutcookies.org/manage-cookies/index.html for information on commonly used browsers. Please be aware that if cookies are disabled, your experience on the Site may be diminished, and not all features of the Site may operate as intended.
We may also use technologies similar to cookies, such as:
Pixel Tags. Pixel tags (also known as web beacons and clear GIFs) are used to, among other things, track the actions of users of the Site, measure the success of our marketing campaigns, and compile statistics about usage of the Site and response rates.
Adobe Flash. Flash Local Shared Objects (also known as Flash cookies) (“Flash LSOs”) and other technologies are used to, among other things, collect and store information about your use of the Site. For your options with respect to Flash LSOs, please visit this page. [Link “page” to http://www.macromedia.com/support/documentation/en/flashplayer/help/inde... ] Please note that setting the Flash player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
Google Analytics. Google Analytics is a service provided by Google, Inc. (“Google”). We use Google Analytics to collect anonymized statistics in order to improve the Site.
Learn more about Google Analytics and privacy. You can selectively disable Google Analytics by installing the opt-out component provided by Google on your browser. For more information, please refer to the links below:
Browser or Device Information. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Site you are using. We use this information to ensure that the Site functions properly.
To the extent any Personal Data is collected through cookies or similar technologies, the other sections of this Privacy Notice apply.