UK Medical Information, Product Complaints, and Drug Safety Privacy Notice

INTRODUCTION

This Medical Information, Product Complaints, and Drug Safety Privacy Notice ("Privacy Notice") describes how Pfizer Limited and its subsidiaries and affiliated entities ("Pfizer", "us" or "we") collect, use, disclose, and retain Personal Data about you in the UK in connection with medical information inquiries, product complaints, or product safety reports, such was when you voluntarily choose to provide to our Medical Information, Product Complaint, or Drug Safety representatives and when you contact us by phone, email, facsimile, postal mail, webforms, or livechat to inquire about medical information, raise complaints, or report adverse events regarding our products. 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 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 in your capacity as a health care professional (HCP), please also see our HCP Privacy Notice for additional information regarding our privacy practices.

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 name, telephone number, email address, physical address, online identifier, Internet Protocol address, account logins, or other similar identifiers.
Purchase History and Tendencies

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This includes records of products or services you may have considered or obtained.
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 Pfizer's systems.
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, we will receive this information.

If you are a patient, Personal data we may collect also includes sensitive information.

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This includes certain characteristics of protected classifications (e.g., your gender and age) and information that may reveal details about your physical or mental health.

If you are a health care professional, Personal Data that we may collect also includes professional information.

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This includes data related to your licensures and specialties.

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

Information We Collect Directly from You. We collect Personal Data you choose to provide as part of your interaction with us.

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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 certain services or information, we may not be able to provide you those services or information.

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.

Information We Collect Automatically. We automatically collect Personal Data when you access online services that Pfizer offers in connection with its medical information, product complaint, or product safety programs, such as the information described above as "Usage Data."

Information We Collect from Other Sources. We may collect Personal Data about you from third parties, such as health care provider or other individuals reporting information about your experience as a patient using Pfizer's products.

HOW WE USE PERSONAL DATA

We may use Personal Data to:

Interact and engage with you when we have a contractual relationship, a legitimate interest or to comply with our legal obligations.
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Interacting and engaging with you includes:
- Respond to your inquiries and provide you with customer service, including tracking and responding to concerns in connection with our medical information, product complaint, or product safety programs.
- Contacting you to obtain further information about the adverse event or complaint you have reported.
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 health care professionals.
- Conducting training and ensuring quality control.
- Operating and expanding our business activities.
Improve our products and services when we have a contractual relationship or a legitimate interest.
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Improving our products and services includes:
- Developing, enhancing, or modifying our products and services.
- Better understanding how our products and services impact you and those for whom you care.
- Analysing or predicting health care professional's preferences to identify trends to develop, improve, or modify our products, services, and business activities.
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 reporting side effects, products complaints, and patient safety associated with our products.
- 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. 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 we collaborate with for the purposes set forth above. For example, we engage service providers to help us with customer service and support, email and SMS, data analytics, web hosting and development, fulfilment, and data technology and related infrastructure.
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.
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 (such as those related to drug safety or adverse event reporting), judicial proceeding, court order, government request, or other legal process served on us.
To Comply with our Legal Obligations and 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 use of our online services. Cookies help us learn which areas of these online services are useful and which areas need improvement.

Depending on the system, 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 websites 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 online services 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 online services, measure the success of our marketing campaigns, and compile statistics about usage of our online services 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 online services. 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 online services.
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.

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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 online service you are using. We use this information to ensure that our online services 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 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.

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Countries your data may be transferred to may not have laws that provide the same level of protection for your Personal Data as laws within the country in which you initially provided the information. Where this is the case, we will put appropriate safeguards in place to make sure that these transfers comply with applicable law, such as by ensuring that the recipient is bound by legally recognized Standard Contractual Clauses, to protect your Personal Data.

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; and
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.

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

If you are under the age of eighteen (18), we will collect your Personal Data in accordance with permission granted by your parent or legal guardian or as otherwise permitted under applicable law. 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 0NS.

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 a data protection authority for the UK at: Information Commissioner's Office.