EEA HCP Privacy Notice

EEA HCP PRIVACY NOTICE

INTRODUCTION

This EEA/UK Privacy Notice for Health Care Professionals (“HCP Privacy Notice” or “Privacy Notice”) describes the Personal Data that the EEA/ UK 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.

More information

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

We may receive Personal Data from other third parties to confirm contact or financial details or to better understand your interests by associating demographic data with the Personal Data you have provided.

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/UK 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.

More information

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.

More information

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.
To analyze or predict 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 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.

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.

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:

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).
To companies that were formerly wholly or partly included in the Pfizer family of companies 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).

More information

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-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.

To obtain a copy of these measures please visit here

DATA OF MINORS

Any Pfizer website or application that you are using is not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Data from such individuals. If you are under the relevant age of consent in your jurisdiction, you will need your parent’s or legal guardian’s permission to use the relevant Pfizer website or application. In these cases please consult with your parent or legal guardian before using a Pfizer website or application.

If you are providing us with Personal Data of individuals under the age of sixteen (16), 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 SLU (Ref.- Protección de Datos)
Av. De Europa 20-B
Parque Empresarial La Moraleja
28108 Alcobendas
Madrid – Spain

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

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

Pfizer SLU (Ref.- Protección de Datos)
Av. De Europa 20-B
Parque Empresarial La Moraleja
28108 Alcobendas
Madrid – Spain

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 click visit here for contact information for such authorities.