UK HCP Privacy Notice

INTRODUCTION

This Privacy Notice for Health Care Professionals ("HCP Privacy Notice" or "Privacy Notice") describes how Pfizer Limited and its subsidiaries and affiliated entities ("Pfizer", "us", "we", or "our") collect, use, disclose, and retain Personal Data about you as a healthcare professional ("HCP" or "you") when you interact with us in a business-related capacity in the United Kingdom. This Privacy Notice also describes the rights that you may have regarding our processing of your Personal Data under applicable local law.

We encourage you to review this HCP Privacy Notice and click on the available links or select "Learn More" if you want additional details on a particular topic. For information regarding our privacy practices involving Personal Data when you are not interacting with us in a business-related capacity, please also see the privacy notice posted on the website or application that you are using.

PERSONAL DATA WE COLLECT AND DISCLOSE

"Personal Data" is data that identifies you as an individual or can be reasonably linked to you. Personal Data that we may collect includes:

• Name, Contact Information, and Identifiers
  
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  This includes your alias, telephone number, email address, physical address, online identifier, Internet Protocol address, account logins, or other similar identifiers.

• Financial and Banking Records
  
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  This includes information that you provide to us to pay you for services and reimburse you for travel, accommodation, and out-of-pocket expenses.

• Protected Classifications
  
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  This includes characteristics of protected classifications under applicable law such as race, colour, sex, gender, age, national origin, disability, and citizenship status.

• Commercial Information
  
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  This includes health care topics about which you request information from us, your response to our survey questions, and your meeting and travel preferences.

• Usage Data
  
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  This includes internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement.

• Audio/Visual Information
  
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  This includes professional photographs as well as your image and voice for both online and recorded events (e.g., image, voice, other personal data contained in voicemail, meetings and conversations chats, meeting whiteboards, recordings, transcriptions of meetings, transcript edits, polls and Questions and Answers (Q&A), shared files, etc.).

• Professional/Employment-Related Information
  
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  This includes data related to your licensures, specialties, professional affiliations (e.g., memberships in medical societies or HCP networks), publications, credentials, and other professional achievements.

• Education Information
  
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  This includes information about your education background (e.g., where you attended school, your degree information).

• Sensitive Information
  
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  This includes your passport number or other similar government identifier, and your account login credentials and passwords.

• Profiles and Inferences
  
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  This includes inferences drawn to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, or aptitudes.

• Information You Otherwise Submit to Us
  
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  During your interaction with us, if you submit any information to us online or offline, directly or via third parties' platforms, we will receive this information.

During your business relationship with Pfizer, we may collect the categories of Personal Data described above directly from you, automatically through your use of our online products and services, and from third parties:

Information We Collect Directly from You. We collect Personal Data you choose to provide, e.g., when we meet with you; when you participate in our programs, activities, industry events, or trade shows; or in connection with your inquiries and communications with us. For example, you may choose to provide information relating to your specialties and professional affiliations.

Information We Collect Automatically. We automatically collect Personal Data when you access online products or services that Pfizer or our third party offers, such as the information described above as "Usage Data." We may also collect your personal data via technologies and/or automated methods of personal data processing such as artificial intelligence technologies, including but not limited to image recognition, speech recognition, transcription, and natural language processing, etc., to the extent permitted under applicable local law. We will only collect and use your personal data through technologies and/or automated methods of personal data processing for the purposes described in this Notice.

Information We Collect from Other Sources. We may collect Personal Data about you from third parties, such as data companies providing information services in the healthcare sector; publicly accessible sources of professional information; and joint marketing partners. For example, we may use such third-party information to confirm contact or financial information or to verify your license, to the extent permitted under applicable local law.

HOW WE USE PERSONAL DATA

We may use Personal Data to:

• Interact and engage with you when we have a contractual relationship or a legitimate interest.
  
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  Interacting and engaging with you includes:

  • Answering your inquiries and requests.
  • Communicating with you about your interaction with us.
  • Providing our products and services to you, including providing our online platforms and tools.
  • Creating and maintaining Pfizer’s database of health care providers to identify and, if applicable, engaging with you (by digital or other means) as a scientific expert or a key opinion leader in various health care fields based on your professional expertise and opinions, and where applicable, your past interactions with us, such as:
    • inviting you to attend congresses/panels, HCP professional meetings and educational activities; and
    • reaching out to you for your professional expertise by communicating information about our products through our professional representatives or in the context of surveys relating to pharmaceutical products or services.
• Operate our business to comply with our legal obligations, for statistical purposes or to meet our legitimate interests in maintaining our business.
  
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  Operating our business includes:

  • Verifying your eligibility to access certain products, services, and data that may be provided only to licensed HCPs or otherwise conducting background checks to ensure we are not precluded from working with you.
  • Conducting training and ensuring quality control.
  • Managing the contractual terms and conditions that govern our relationship with you (e.g., medical events face-to-face or online, publications, advisory meetings, etc.). 
  • Where applicable, paying you for defined or agreed upon services or reimbursing your expenses, planning calls, meetings, trips, and other related interactions with you, sending administrative information to you, such as, but not limited to SMS regarding the logistical details of the meeting, and documenting our interactions with you.
• Improve our services when we have a contractual relationship or a legitimate interest.
  
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  Improving our services includes:

  • Analysing your preferences to improve our interactions with you, i.e., to deliver you the content, products, and offers (via our HCP-directed sites, emails, or digital tools) that we believe will be relevant to your professional interests.
  • Analysing or predicting your preferences to identify aggregated trends to develop, improve or modify our products, services, and business activities.
  • Analysing your professional interests and area(s) of expertise to optimize our internal resources allocation in the context of the scientific information activity, as well as to improve the quality of the interactions with you.
• Provide marketing and promotional communications when we have a contractual relationship, your consent or a legitimate interest.
  
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  Providing marketing and promotional communications includes:

  • Sending you news and newsletters, event updates, and to communicate with you about scientific and health matters (by digital means or otherwise).
  • Tailor the content and information that we send or display to you to your professional area and interests, and to otherwise personalize your experience when you interact with us.

  Where needed under applicable law, we will obtain your consent (or as otherwise required by law) before processing your Personal Data, including for cookies and similar technologies and marketing messaging.

• Comply with legal obligations and protect us and others.
  
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  Complying with legal obligations and protecting us and others includes:

  • Complying with our regulatory monitoring and reporting obligations, including those related to adverse events, product complaints, and product safety.
  • Exercising and protecting our rights, privacy, safety, or property, or those of our affiliates, you, or others.
  • Detecting, preventing, or investigating misconduct.
  • Complying with anti-corruption and transparency obligations.
  • Complying with law enforcement or government authority requests and participating in compliance audits.

We may aggregate or anonymize data about you and use it for any purpose, including product and service development and improvement activities. To the extent we anonymize any data originally based on Personal Data, we will maintain and use such data only in anonymized form and will not attempt to reidentify the data.

In certain instances, and consistent with applicable law, we may use automated or AI-enabled tools to process your Personal Data for the purposes described above.

Please note that unless otherwise indicated, by 'legitimate interest' we mean the interest in conducting and managing our business to enable us to provide the best products and services, or to provide the information you are requesting from us. When we process personal information to meet our legitimate interests, we ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you by contacting us at the details below.

HOW WE DISCLOSE PERSONAL DATA

We disclose Personal Data as follows:

• Affiliates.
  
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  We may disclose Personal Data we collect about you to other Pfizer companies for the purposes described in this Privacy Notice.

• Service Providers.
  
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  We may disclose Personal Data we collect about you to service providers, contractors, and agents who perform functions and business operations on our behalf, for the purposes set forth above. For example, we engage service providers to help us with customer service and support, auditing, email and SMS, data analytics, web hosting and development, fulfilment, and data technology and related infrastructure that allows us to organize and stream online conferences. We may also disclose your information to data companies that provide information services in the healthcare sector to help us confirm that your data remains up-to-date and accurate.

• Business Partners.
  
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  We may disclose Personal Data we collect about you to our business partners, including companies with which we collaborate regarding joint development, distribution, or marketing of particular products or services, as well as companies such as travel agencies which provide services to you in connection with Pfizer hosted/sponsored events. These companies will process your Personal Data in accordance with their privacy policies.

• Business Transfers.
  
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  If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer Personal Data we have collected about you to the other company to prepare, complete, and implement the business transfer. As part of the business transfer process, we may disclose certain of your information to lenders, auditors, and third-party advisors, including attorneys and consultants. We may also disclose your information to companies that were formerly wholly or partly included in the Pfizer group to whom we provide services during a transition period following separation.

• To The Public.
  
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  We may disclose Personal Data we have collected about you publicly, such as public disclosures of transfers of value that you receive from any Pfizer company according to the Association of British Pharmaceutical Industry (ABPI) Code of Practice and local law (such as payment of professional fees, travel accommodations, and out-of-pocket expenses).

  
  We disclose this data pursuant to our legitimate interests. The publication of this data serves multiple legitimate interests of society, including patients, health care systems, the pharmaceutical industry, and to you as an HCP by:

  • Instilling public confidence in the integrity and independence of HCPs.
  • Helping safeguard public health by promoting HCP accountability to patients for decisions about their treatment.
  • Demonstrating a commitment to continual education of HCPs which helps provide better care to patients.
• In Response to Legal Process.
  
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  We may disclose Personal Data we have collected about you where we believe necessary to comply with a regulatory requirement, judicial proceeding, court order, government request, or other legal process served on us.

• To Protect Us and Others.
  
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  We may disclose Personal Data we collect about you where we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety, rights, or property of our customers, the public, Pfizer and our affiliates, violations of this Privacy Notice, or as evidence in litigation in which we are involved.

COOKIES & SIMILAR TECHNOLOGIES

Cookies are a standard feature of websites that allow us to store small amounts of data on your computer about your visit to our sites for HCPs. Cookies help us learn which areas of our sites are useful and which areas need improvement.

Depending on the site, 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. In addition, you can refuse or accept cookies from our sites at any time by activating the settings on your browser. Information about the procedure to follow 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 our sites may be diminished, and not all features may operate as intended.

We may also use technologies similar to cookies, such as:

• Pixel Tags.
  
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  Pixel tags (also known as web beacons and clear GIFs) are used to, among other things, track the actions of users of our HCP-directed sites, measure the success of our marketing campaigns, and compile statistics about usage of our sites and response rates.

• Adobe Flash.
  
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  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 our HCP-directed sites. For your options with respect to Flash LSOs, please visit this page. 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.
  
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  Google Analytics is a service provided by Google, Inc. ("Google"). We use Google Analytics to collect anonymized statistics to improve our HCP-directed sites. 

  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:

  • Google Analytics Opt-out Browser Add-on
  • Google Analytics Support
  • My Google Account
• Email tracking tools.
  
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  Email tracking tools are used to, among other things, collect information about when you open emails and attachments, so that we can share content with you that you may find interesting or relevant.

• Browser or Device Information.
  
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  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 our sites function properly.

To the extent any Personal Data is collected through cookies or similar technologies, the other sections of this Privacy Notice apply.

CROSS BORDER TRANSFERS

The Personal Data we collect about you may be transferred to, 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 for the purposes described above.

RETENTION PERIOD

We will retain your Personal Data for the time necessary for the purpose(s) for which it was obtained and as outlined in this Privacy Notice. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you;
• Whether there is a legal obligation to which we are subject;
• Whether retention is advisable considering our legal position in, for example, the enforcement of applicable contractual agreements or statutes of limitations, litigation, or regulatory investigations; and
• Whether the local regulations require.

INDIVIDUAL RIGHTS

Depending on where you live and subject to certain exceptions, you may have the right to exercise certain rights involving Personal Data we hold about you:

• You can ask us for a copy of the Personal Data we hold about you.
• You can inform us of any changes to your Personal Data, or you can ask us to correct any of the Personal Data we hold about you.
• You can make a complaint to us if you have concerns about the way we have handled your Personal Data.
• In certain situations, you can ask us to delete Personal Data we hold about you.
• In certain situations, you can ask us to restrict the processing of the Personal Data we hold about you or object to particular ways in which we are using your Personal Data.
• In certain situations, you can also ask us to send the Personal Data you've given us to a third party.

If you would like to request to access, correct, or delete Personal Data that you have provided to us, restrict/object to our processing of your Personal Data, make a complaint 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 or visit www.pfizer.com/individualrights. We will respond to your request consistent with applicable data protection law.

We will further verify and respond to your request consistent with applicable law, considering the type and sensitivity of the Personal Data subject to the request. We may need to request additional Personal Data from you, such as your date of birth or government identifier, to protect against fraudulent or spoofed requests. Please note that we may need to retain certain Personal Data for recordkeeping purposes or to complete any transactions that you began prior to requesting a change or deletion.

DATA SECURITY

We use organizational, technical, and administrative measures designed to protect your Personal Data from unauthorized access or use. No such measure is ever 100% effective though, so we do not guarantee that your Personal Data will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such data.

DATA OF MINORS

Our services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Data from such individuals. If you are providing us with Personal Data of individuals under the age of eighteen (18), you represent that you have the appropriate authority to do so, and that you can demonstrate such authority to Pfizer upon request.

UPDATES

From time to time, we will update this Privacy Notice. Any changes will become effective when we post the revised Privacy Notice. This Privacy Notice was last updated as of the "Last Updated" date shown above. We will notify you of substantial changes to this Privacy Notice as appropriate under applicable law.

CONTACT US

The data controller responsible for the processing of your Personal Data under this Privacy Notice is Pfizer Limited, Walton Oaks, Dorking Road, Tadworth, Surrey KT20 7NS.

If you have questions about this Privacy Notice, please contact us at DataProtectionUK@Pfizer.com. If you would like to request to exercise any individual rights, please contact us at the address above or visit www.pfizer.com/individualrights.

LODGING A COMPLAINT WITH A REGULATOR

You may lodge a complaint with the data protection authority for the UK at: Information Commissioner's Office.