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EEA HCP PRIVACY NOTICE
INTRODUCTION
This EEA Privacy Notice for Health Care Professionals (“HCP Privacy Notice” or “Privacy Notice”) describes the Personal Data that the EEA Pfizer companies named in the Contact Us section below (hereinafter, “Pfizer”, “us” or “we”) collect about you as a healthcare professional (“HCP”) when we interact with you; how we use that data; how we protect it; and the choices you may make with respect to your Personal Data. 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.
If you are interacting with us online, please also see the privacy notice posted on the website or application that you are using.
PERSONAL DATA
“Personal Data” is data that identifies you as an individual or relates to an identifiable individual. We will collect Personal Data when we meet with you, when you participate in our programs, activities, industry events, trade shows, or in connection with your inquiries and communications with us. We also collect Personal Data from data companies providing information services in the healthcare sector, publicly accessible sources of professional information, and joint marketing partners.
Personal data that we can collect include:
- Name
- Contact information (postal address, telephone numbers, email address, fax number)
- Your preferred language
- Professional photo
- Your interests (e.g. on health topics about which you request information from us)
- Professional biography with information on training, admissions, specializations, professional connections (e.g. memberships in medical specialist societies or professional networks), publications, references and other professional achievements
- Data related to your use of our products, your interactions with us, your preferred way of communicating with us and services for the people you care for.
- Financial and banking information that you provide to us in order to pay you for services and to reimburse you for fees, travel expenses, accommodation and expenses
- ID number, passport number, tax identification number
- Travel booking preferences
When you are asked to provide Personal Data, you may decline. But if you choose not to provide data that is necessary for us to provide requested services or perform our contractual obligations we may not be able to provide you those services or perform those contractual obligations.
If you provide or permit us to collect any Personal Data relating to another person, including adverse event data, 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 EEA HCP Privacy Notice.
HOW WE USE PERSONAL DATA
We use Personal Data in order to:
- Interact and engage with you when we have a contractual relationship or a legitimate interest.
Interacting with and contacting you includes:
- Answering your inquiries.
- Enforcement of the contractual terms that regulate our relationship with you (e.g. medical events, publications, consultations, etc.) and, if necessary, payment for defined or agreed services or reimbursement of your expenses, planning visits, meetings, trips and other related interactions with You, sending you administrative information and documenting our interactions with you.
- Creation and maintenance of the Pfizer Healthcare Professional Database to identify you (by digital or other means) as a scientific expert or opinion leader in various areas of health care and, where appropriate, to contact you based on your expertise and opinions and, if applicable, your previous interactions with us, such as B .:
- Invitation to congresses / committees, specialist conferences and training activities
- Establishing contact based on your technical expertise to provide information about our products through our specialist speakers or as part of surveys on 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.
The management of our business activities includes:
- Compliance with our statutory monitoring and reporting obligations, including those relating to adverse events, product complaints and product safety.
- Verifying your eligibility to use certain products, offers, services and information that may only be made available to approved healthcare professionals, or other background checks, to ensure that we are not prohibited from working with you.
- Implementation of training courses and quality assurance.
- Recognize, prevent or investigate misconduct.
- Compliance with anti-corruption and transparency obligations.
- Analyze or predict the preferences of healthcare professionals to identify aggregated trends in developing, improving or modifying our products, services and business activities.
- Protect the rights, privacy, safety or property of Pfizer and / or our partners, you or others.
- Provide you with marketing and promotional communications on scientific/health matters (by digital means or otherwise), which may be personalized to your professional area and interests when we have your consent or a legitimate interest.
HOW WE DISCLOSE PERSONAL DATA
We disclose Personal Data as follows:
- To other Pfizer companies (visit here for a list of our companies) for the purposes described in this EEA HCP Privacy Notice.
- To our third party service providers, to provide services such as data analysis, data technology and related infrastructure provision, customer service, auditing and other services.
- To data companies providing information services in the healthcare sector to ensure your data remains up to date and accurate.
- To other companies with which we collaborate regarding joint development, distribution and/or marketing of particular products or services.
- To comply with a regulatory requirement, judicial proceeding, court order, government request, or legal process served on us.
- To take legal action or otherwise protect the safety, rights, or property of our customers, the public, Pfizer and our affiliates.
- To prepare, complete and implement 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).
DISCLOSURES OF TRANSFER OF VALUE
A Pfizer company in the country of your professional practice will make public disclosures of the transfers of value that you receive from any Pfizer company according to the EFPIA Transparency Code of Conduct and/or applicable local law (such as payment of professional fees, travel, accommodations and out of pocket expenses).
Unless otherwise required by law, we will disclose your identity, the location and country of your professional activity, and the date, type and amount of payment you will receive from Pfizer. Your ID or social security number will only be published if required by law. This information is published on our website and / or on the website of the local EFPIA representative of the pharmaceutical industry. If required by law, the disclosure will also be made on the relevant government websites. The data will be available for 3 years after their publication (unless another legal period applies in your country).
We pass on this data on the basis of consent, law or legitimate interests.
The publication of this information serves a wide range of legitimate interests of society, including patients, health systems, the pharmaceutical industry, and you as a healthcare professional by:
- Strengthening the public's trust in the integrity and independence of healthcare professionals.
- Contribute to the protection of public health by promoting accountability of healthcare professionals to patients for their decisions about their treatment.
- Demonstrate commitment to ongoing professional development education that will help improve patient care.
INDIVIDUAL RIGHTS
If you would like to request to review, correct, update, suppress, restrict, object or delete Personal Data that you have provided to us, withdraw a consent 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.
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.
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 Site 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 Site Terms of Use, applicable statutes of limitations, litigation or regulatory investigations).
CROSS BORDER TRANSFERS
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.
To obtain a copy of these measures please visit here.
DATA OF 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.
UPDATES
From time to time, we will update this EEA HCP 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.
CONTACT US
The company responsible for collection, use and disclosure of your Personal Data under this Privacy Notice is
Pfizer Pharma GmbH
Friedrichstraße 110, 10117 Berlin
If you have questions about this Privacy Notice, please contact us at info@pfizer.de.
If you would like to request to exercise any individual rights, please contact us at www.pfizer.com/individualrightsgdpr, info@pfizer.de or write to the following address:
Pfizer Pharma GmbH
Rechtsabteilung
Friedrichstraße 110, 10117 Berlin
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 a data protection authority competent for your country or region or place of alleged infringement. Please click visit here for contact information for such authorities.