PFIZER EEA PRIVACY NOTICE
PATIENTS’ TESTIMONIALS OR SERVICES
This Privacy Notice applies to Personal Data that you, as a patient, voluntarily choose to provide to Pfizer in the EEA, when you agree to act as a patient consultant, participate in an advisory board, speak at a congress event or otherwise provide us with testimonials. Personal Data is information that identifies you as an individual or relates to a directly or indirectly identifiable individual.
WHICH PERSONAL DATA WE COLLECT AND FROM WHICH SOURCES
In the above-mentioned context, we collect the following types of Personal Data provided by you or generated as a result of your free and voluntary interaction with Pfizer:
- Your name and contact information (postal address, telephone numbers, email address, social media accounts).
- Your association with any patient association, if applicable.
- Information related to your contractual relationship with Pfizer, if applicable (such as your membership to an advisory board or your participation in a congress).
- Information related to your health conditions and lifestyle or experiences with illness or disease and/or with a particular Pfizer product or service, including testimonials.
- Your image, voice or likeness, if applicable.
If you provide any information relating to another identifiable person, you are telling us that you have the authority to share that information and to permit us to use the information as described in this Privacy Notice.
HOW WE USE PERSONAL DATA
We use Personal Data to
- Enforce and administer the contractual terms and conditions that govern our relationship with you (e.g., advisory board meetings, attendance to scientific congresses, testimonials, publications etc.). Where applicable, this includes:
- Paying you for defined or agreed upon services or reimbursing your expenses.
- Coordinating your consulting activities, testimony or speaking engagements (planning calls, meetings, trips and other related interactions with you).
- Sending administrative information to you.
- Documenting our interactions with you.
- 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 legal and regulatory obligations around reporting side effects, product complaints and patient safety associated with our products. As part of this, we may contact you if we require further information about the adverse event or complaint that you have reported.
- Verifying your eligibility or otherwise conducting background checks to ensure we are not precluded from working with you.
- Protecting our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- Aggregating the information that you and other individuals provide (in order that the information does not directly or indirectly identify you or any other individual).
Processing of your health-related personal data will be based on your consent, except where we are required to use that Personal Data to comply with a legal or regulatory obligation, such as when you report an adverse event. If we use Personal Data based on your consent, you may withdraw your consent at any time.
HOW WE DISCLOSE PERSONAL DATA
We disclose Personal Data as follows:
- When you speak at a pharmaceutical conference or congress, your information will be shared with the attendees. Personal Data you provide through speaking engagements, testimony or other consulting activities also may be included in future Pfizer online and offline publications.
- If your speech in a conference or congress or your testimony is recorded (recording will be subject to your consent), the audiovisual recording and photo material of your speech shall be used for the following activities:
- For internal use within the Pfizer organization for the purposes of training/informing, educational meetings.
- For external use in Pfizer external communications and channels publicly available to educate healthcare professionals and patients, including but not limited to scientific media .
- Photos and film footage will not be used to promote medicines.
- 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).
- To other Pfizer companies (list available at https://selfservehosteu.pfizer.com/legal-entities) for the purposes described in this Privacy Notice
- To our third party service providers to provide services, such as information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
If you would like to request to review, correct, restrict, delete, or object to the processing of Personal Data that you have provided to us, 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. Please note that our ability to fulfil your request will be limited if it prevents us from complying with our legal or regulatory duties.
We seek to use reasonable organizational, technical and administrative measures to protect your Personal Data. Unfortunately, we cannot guarantee Personal Data to be 100% secure.
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; (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 any applicable terms or agreements, applicable statutes of limitations, litigation, or regulatory investigations).
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-o...). 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.
The companies responsible for collection, use and disclosure of your Personal Data under this Privacy Notice is Pfizer AB, with address Vetenskapsvägen 10, 191 90 Sollentuna, Sweden. If you have any questions about this Privacy Notice or if you would to request to exercise any individual rights, please contact:
Pfizer AB, at [email protected], or write to the following address:
Pfizer, Vetenskapsvägen 10, 191 90 Sollentuna, Sweden
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 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 see http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 for contact information for such authorities.