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.

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Personal Data that we may collect includes:

Name
Contact information (postal address, telephone numbers, email address, fax number)
Your peferred language
Professional photograph
Your interests (such as in health care topics about which you request informationfrom us)
Professional biography including data related to your education, licensures, specialties, 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, accomodation and out of pocket expenses
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.

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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.
- Complying with anti-corruption and transparency obligations.
- Analysing or predicting HCP preferences in order to identify aggregated trends to develop, improve or modify our products, services and business activities.
- Protecting our rights, privacy, safety or property, and/or that of our affiliates, 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, accomodations and out of pocket expenses).

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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.

CROSS BORDER TRANSFERS

The data we collect through the Site may be stored and processed in any country where we have facilities or where we maintain relationships with service providers, including in the US and where our affiliates are employed.

Some non-EEA countries are recognized by the European Commission as countries that use a data protection level equivalent to EEA standards (the full list of these countries is available here ). For transfers from the EEA to countries that are not considered adequate by the European Commission, we have implemented adequate measures, such as ensuring that the recipient is bound by EU standard contractual clauses, to protect your Personal Data. You can obtain a copy of these measures by contacting us as indicated in the Contact us section.

For a copy of these measures, go to here https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en

USE BY MINORS

The Site is not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from those individuals. If you are younger than the permitted age in your jurisdiction, you require permission from your parents or guardian to use the Site. Consult your parents or guardian before using the Site.

If you provide us with Personal Data of persons younger than sixteen (16), you thereby indicate that you have the appropriate authority to do so and that you can prove that authority at the request of Pfizer.

UPDATES

We update this Privacy Statement from time to time. Changes take effect the moment we publish the revised Privacy Statement on the Site. This Privacy Statement was last updated on the "Last Updated" date above.

CONTACT US

The company responsible for collection, use and disclosure of your Personal Data under this Privacy Notice is

Pfizer bv or Upjohn Netherlands B.V. or PF Consumer Healthcare bv

Postbus 37, 2900 AA Capelle aan den IJssel

If you have questions about this Privacy Notice, please contact us at [privacyNL@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:

Pfizer, t.a.v. Privacy afdeling, 2900 AA Capelle aan den Ijssel

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 infringment. Please click here for contact information for such authorities.