EEA HCP Privacy Notice

 

HCP PRIVACY NOTICE EUROPEAN – ECONOMIC AREA (EEA)

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.

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 may collect includes:

• Name
• UIN
• Contact information (postal address, telephone numbers, email address, fax number) and other contact details
• Your preferred language
• Professional photograph
• Your interests (such as in health care topics about which you request information from us)
• Professional biography including data related to your education, previous professional experience, licensures, specialties, work place, job positions, professional affiliations (e.g., memberships in medical societies or HCP networks), publications, credentials, and other professional achievements
• Data related to your use of our products, your interactions with us, your preferred method of communications with us, and services for those you care for
• Financial and banking data that you provide to us to pay you for services and provide reimbursement for professional fees, travel and accommodation
• National ID number, passport number, tax identification number
• Travel 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 and engaging with you includes:

• Responding to your inquiries and your requests,
• Enforcing the contractual terms and conditions that govern our relationship with you (e.g., medical events, publications, advisory meetings, etc.) and, 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, and documenting our interactions with you,
• 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
  • 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.

Operating our business includes:

• Complying with our regulatory monitoring and reporting obligations, including those related to adverse events, product complaints and product safety,
• 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,
• Detecting, preventing, or investigating misconduct,
• Entering into agreements between you and Pfizer, Complying with anti-corruption and transparency obligations,

• Analyzing or predicting HCP preferences in order to identify aggregated trends to develop, improve or modify our products, services and business activities,
• 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,
• For communication and maintaining other contacts,
• Protecting our rights, privacy, safety or property, and/or that of our affiliates, you or others.

HOW WE DISCLOSE PERSONAL DATA

We disclose Personal Data as follows:

• To other Pfizer companies (visit https://selfservehosteu.pfizer.com/legal-entities 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 and accommodations).

Unless otherwise required by law, we will disclose your identity, city and country of professional practice and the date, nature and amount of value that you receive from Pfizer. Your ID or social security number will only be published if required by local law. These disclosures will be published on our websites and/or EFPIA local pharmaceutical industry association websites. When legally required, disclosure will also occur on relevant government websites. The data, once published, will be available for 3 years (unless another legal period applies in your country).

We disclose this data pursuant to consent, law or 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.

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 our products, services or contents 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 applicable contract terms, applicable statutes of limitations, litigation or regulatory investigations).

CROSS BORDER TRANSFERS

The data we collect 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 at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en). 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 https://privacycenter.pfizer.com/et/estonia.

DATA OF MINORS

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 EEA HCP Privacy Notice. Any changes will become effective when we post the revised Privacy Notice at privacycenter.pfizer.com. 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 Luxembourg SARL Estonian branch

A.H. Tammsaare tee 47

Tallinn 11316

Estonia

If you have questions about this Privacy Notice, or if you would like to request to exercise any individual rights, please write to the following address:

Pfizer Luxembourg SARL Estonian branch

A.H. Tammsaare tee 47

Tallinn 11316

Estonia

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 visit http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 for contact information for such authorities.