This policy describes how Teva UK Limited and its affiliates and group companies (referred to here as "Teva", "we" or "us") use your data, whether or not you have interacted with Teva previously. It also describes your data protection rights, which include a right to object to some of the processing which Teva carries out. More information about your rights, and how to exercise them, is set out in the “What rights do you have?” section.
What does this policy cover?
Scope of this Privacy Notice
This Privacy Notice applies to personal data we collect through the Site but also that we collect about healthcare professionals throughout our relationships with them and from third party sources in our market analysis. It describes how we use your data and your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Your data protection rights” section.
Please note that your data may also be used in relation to the reporting of adverse events, which is dealt with in Teva’s notices on adverse event reporting, see https://www.tevauk.com/pharmacovigilance-policy for more details.
Information we collect from you
We will collect personal data about you when you interact with us and our representatives, and when you make use of our Site.
Information collected from third party sources
Teva collects information about health from a number of third party data sources, in particular from publicly available sources such as public registers of healthcare professionals, published journals and event materials and from websites of healthcare professionals or their employers. Teva also specially makes use of third party data providers to enhance its own knowledge of the healthcare sector. This data will include information about your role(s), your qualifications, your speciality, your employer, your experience, your publications and other information related to your profession.
How we use your information
We process the personal data we collect as follows:
|Carrying-out and follow-up training, information and communication actions for example to invite you to symposia, congresses, seminars, debates and carry out market research, scientific cooperation or research, and handling any questions or complaints you may have about Teva or Teva staff;||Our legitimate interest to develop and maintain our relationship with you and to better understand the healthcare sector.|
|Analysis of your use of our sites, your interests and experience, collecting information in relation to any calls or visits from our representatives, and contacting you or otherwise providing you with information regarding Teva products or events and tailoring our communications to you based on your expertise and professional interests;||Our legitimate interest in promoting and communicating with you about our products, or – where required under applicable law – marketing based on your consent.|
|Management of contracts we have with you, including any payments being made to you;||Necessary to perform and manage our contract with you.|
|Analysis if your skill is adequate for the mission before signing a service agreement (consultant, speaker, investigator, expert);||Comply with our legal obligations.|
|Managing orders, questions and complaints regarding products (for pharmacists only);||Necessary to perform and manage our contract with you.|
|Assessing the purchases you have made and other information collected from you included your marketing preferences and how you browse our relevant sites (for pharmacists only);||Our legitimate interest in promoting and communicating with you about our products, or – where required under applicable law – marketing based on your consent.|
|Managing and responding to requests concerning medical information;||Comply with our legal obligations or carry out our legitimate interest in providing appropriate information to healthcare professionals about our products, research and companies.|
|Complying with all legal and self-regulatory obligations including transparency and disclosure obligations or anti-gift obligations.||Comply with our legal obligations and carry out our legitimate interest in meeting self-regulatory standards on transparency. On publication of data, if not required by law, we will publish identifiable information with your consent.|
|Using data in connection with legal claims, compliance, regulatory and investigative purpose as necessary (including disclosure of such information in connection with legal process or litigation)||Comply with our legal obligations, and carry out our legitimate interest in ensuring compliance with laws, self regulatory requirements and our internal policies as well as protecting our legal interests and rights.|
|Placing cookies and use of similar technologies in accordance with this policy and the information provided to you when those technologies are used||Your consent, unless the placement of cookies is strictly necessary (and is based on our legitimate interest in ensuring the performance of our Site).|
|As described in any consent sought from you.||Your consent.|
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below. For certain Teva Sites, you may also have an ability to change some marketing preferences online.
Who will we share this data with, where and when?
We will share your personal data with Teva group companies for the purposes of market analysis, ensuring accuracy of information collected about healthcare professionals throughout the group and to carry out appropriate and proportionate marketing activities.
We also share information with relevant regulators, such as the EMA, and with pharmaceutical self-regulatory bodies such as EFPIA and applicable national bodies as required to meet regulatory obligations. Where we receive information from third party sources, we also share your information back to these sources where we need to confirm and have agreed to assist them with the accuracy of information – for example, where we become aware that you have moved to a new role.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Personal data will also be shared with third party service providers, who will process it on behalf of Teva for the purposes identified above. In particular, we use third party providers of website hosting, CRM hosting, event management, mailing providers and analytics providers.
In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
Teva is a multinational company, and so your information may be transferred to relevant locations internationally – particularly, where you are in the EEA, your data may be shared with Teva’s Israeli and US entities for the purposes set out above. Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request.
Cookies and related tracking technologies
Teva uses the following categories of cookies on the Site:
Category 1: Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for (such as remembering your login details) cannot be provided.
Category 2: Performance Cookies
These cookies collect information on how people use the Site. For example, Teva uses these cookies to help us understand how customers arrive at the Site, browse or use the Site and highlight areas where we can improve areas such as navigation, user experience and marketing campaigns. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Site works.
Category 3: Functionality Cookies
These cookies remember choices you make (such as language choices). These can then be used to provide you with an experience more appropriate to your selections and to make your visits to the Site more tailored. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Information on deleting or controlling cookies is also available at www.allaboutcookies.org. Please note that by deleting our cookies (or disabling future cookies) you may not be able to access certain areas or features of the Site.
Your data protection rights
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in national data protection legislation. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us – or our data protection officer – using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
Where collection of your data is mandatory, this will be made clear to you at the time of collection. All other use of your data is optional.
Which Teva entity is my data controller, and which Teva affiliates might my data be shared with?
The data controller for your information is the Teva entity with which you have a relationship or which manages the website you have visited.
How long will you retain my data?
In accordance with applicable data protection law, your data is retained for the duration of your contract and for an appropriate duration after its termination in your country to protect us from any legal claim.
We hope that we can satisfy any queries you may have about the way in which we process your personal data. If you have any concerns about how we process your personal data, you can get in touch with Teva’s Data Protection Officer at EUPrivacy@tevaeu.com. However, if you have unresolved concerns you also have the right to complain to the data protection authority in the location in which you live, work or believe a data protection breach has occurred.
Effective: July 2019