Italy

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” or “you”) 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.

Learn More

Personal Data that we may collect includes:

Name;
Contact information (postal address, telephone numbers, email address, fax number)
Your preferred language;
Professional photograph, as well as your image and voice for both online and recorded and transcripts of your meeting contributions;
Your interests (such as in health care topics about which you request information from us);
Professional biography including data related to your education, licensures, specialties, workplace, professional affiliations (e.g., memberships in medical societies or HCP networks), publications, credentials, and other professional achievements;
Data related to your interest in the content we display in the context of our scientific information activity, 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, accommodation and out of pocket expenses;
National ID number, passport number, tax identification number;
Travel preferences and possible special needs.

We may receive Personal Data from third parties that have collected it in compliance with applicable data protection laws to confirm contact or financial details or to better understand your interests.

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 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, on the basis of our legitimate interest or your consent.

Learn More

Interacting and engaging with you includes:

Answering to your inquiries and your requests.
Enforcing the contractual terms and conditions that govern our relationship with you (e.g., medical events face-to-face or online, 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, such as, but not limited to SMS regarding the logistical details of the meeting, 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.

Learn More

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.
Complying with anti-corruption and transparency obligations.
Analysing your preferences in order to improve our interactions with you, i.e., to deliver you the content, products and offers (via our Site, emails or digital tools) that we believe will be relevant to your professional interests.
Analysing or predicting Your preferences in order to identify aggregated trends to develop, improve or modify our products, services and business activities.
Analysing your professional interests and area of expertise on the basis of our legitimate interest 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.
Analysing your professional interests, including your interest in the content we display in the context of our scientific information activity, on the basis of our legitimate interest to improve our communication materials, streamline our internal workflow and to improve the quality of the visits to you.
Exercising and protecting our rights, privacy, safety or property, and/or those of our affiliates, You or others.

Provide you with marketing and promotional communications on scientific/health materials (by digital means or otherwise), which may be personalized to your professional area and interests when we have your consent.

Please note that unless otherwise indicated, by ‘legitimate interest’ we mean our interest in conducting and managing our business to enable us to provide you the best products and services, to provide you the information you are requesting from us, or to improve our internal organization and efficiently allocate our resources.

When we process Personal Data to meet our legitimate interests, we ensure that our legitimate interests are not overridden by your interests, 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 process your Personal Data on the basis of our legitimate interest where our interests are overridden by the impact on you (unless we have your consent or another legal basis under Regulation (EU) 2016/679).

You can obtain further information about how we assess our legitimate interests against any potential impact on you by contacting us as indicated under Section “Contact Us” below.

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 Privacy Notice.
To our third-party service providers, to provide services such as data analysis, data technology and related infrastructure provision such as but not limited to applications that allow us to organize and stream online conferences, customer service, auditing and other services.
To specialized 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).To companies that were formerly wholly or partly included in the Pfizer group to whom we provide services during a transition period following separation.

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).

Learn More

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

You have the right to exercise your rights as data subject, in accordance to Regulation (EU) 2016/679.

If you would like to request to access, 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. In particular, you have the right to object at any time to the processing of your Personal Data we process on the basis of our legitimate interest, subject to our right to demonstrate the existence of compelling legitimate grounds for processing which override the interests, rights and freedoms of the data subject. We will respond to your request consistent with applicable data protection 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, and in accordance with applicable data protection law.

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 the time strictly necessary 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 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.

UPDATES

From time to time, we will update this 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. We will notify you of substantial changes occurred in this Privacy Notice.

CONTACT US

The data controller responsible for the processing of your Personal Data under this Privacy Notice is Pfizer S.r.l. with its registered office in Latina, Via Isonzo n. 71 and its administrative offices in Rome, Via Valbondione n. 113.

If you have questions about this Privacy Notice, please contact us at gdpritaly@pfizer.com.

If you would like to request to exercise any individual rights, please contact us at www.pfizer.com/individualrightsgdpr, or write to the following address: gdpritaly@pfizer.com

You may also contact our data protection officer responsible for your country or region, if applicable, at privacy.officer@pfizer.com. 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.

COOKIES

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

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

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

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

Adobe Flash. 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 the Site. 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. Google Analytics is a service provided by Google, Inc. (“Google”). We use Google Analytics to collect anonymized statistics in order to improve the Site.

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. 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 the Site functions properly.

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