Privacy and Cookie Notice
This privacy and cookie notice (“Notice”) is provided by Teva UK Limited ("Teva") and its affiliates (Norton Healthcare Limited and Teva NI Limited). Teva is referred to in this Notice as “we”, “us” and “our.”
1. Scope of this notice
This Notice applies to our general processing of your personal data. However, there may be specific scenarios in which a different Privacy Notice is provided to you by us or on our behalf, including for example, if (i) you report adverse events to us, or (ii) we have specific obligations to record and report "transfers of value" in accordance with transparency requirements.
This Notice describes how we use your personal data, and your data protection rights, including, where applicable, 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 rights” section.
This Notice applies to personal data we collect through:
1. Sites and digital properties
We process your personal data when you visit or use our websites and other digital properties (such as apps) or platforms (each, a “Site”). The data we collect may include device and network activity information, such as your device type, IP address, device or user identifiers, operating system, internet service provider, the date and time of your website use, information about the links, emails or features or content you interact with, and other log information. We also may receive error-reporting information in the event of a technical error, including the device or software type and version, the time the error occurred, the feature being used, the state of the device or software when the error occurred, and any communications or content provided at the time the error occurred.
For Sites where you create an account (for example to access pharmacy ordering), in order to manage your account we may collect information which identifies you, including your contact details and an account username and password, and details of the business or organisation linked to the account.
Our Sites may include links to other websites or organisations over which we have no control. Teva is not responsible for the privacy policies or practices of other websites or organisations. If you access these websites via our Sites, you should review the privacy policies of those sites so you can understand how they collect, use and share your personal data.
In particular, our Sites use YouTube API services to display videos. This third party service has separate and independent privacy policies and/or Terms of Service shown below:
- YouTube API Services Terms of Service (https://www.youtube.com/t/terms)
b. Conflict of interest checks
We will process your personal data if one of our employees has declared a potential conflict of interest (i.e. any situation in which personal, social, financial, political or other interests are placed before those of Teva) that concerns you.
c. Interactions with us or our representatives
We collect information about healthcare professionals/experts, including any contact details you provide, when you interact with us or our representatives. As well as personal identifiers, including contact details, we collect professional and employment-related information (including professional title, employing institution, credentials and interests. We also maintain records of our communications and meetings with you.
d. Supplier/vendor and customer relationships
When you engage with Teva as a supplier/vendor, customer or supplier/vendor/customer’s personnel, we will process your personal data, including your name, personal identification number, business contact details, business bank account details and other related information and business financial information. We will also maintain order/payment data, survey responses where applicable, and other appropriate records of our interactions with you.
e. Third parties
We also collect personal data 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 the websites of healthcare professionals or their employers. We also use third party data providers to enhance our 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 personal data
We rely on a number of legal bases for the processing of your personal data, which vary according to the purposes for which we collect it.
We process your personal data when it is necessary for the purposes of our legitimate interests as a controller (or those of a third party):
- to respond to your queries or other correspondence you have submitted through our Sites;
- to analyse engagement with our Sites, communications, events and services in order to improve content, optimise performance and enhance their relevance to various audiences;
- to optimise and tailor the use of our Sites and our communication to you;
- to assess any purchases you have made and other information collected from you including your marketing preferences and how you browse our relevant Sites to enable us to better meet your needs in the future;
- to detect, investigate, prevent or report activities that may violate our policies or be illegal;
- to carry out conflict of interest checks and assessments where you have been identified by a Teva employee as having a potential conflict of interest with us and keep records of the same to enable us to take appropriate action to remediate such conflicts;
- to develop and maintain our relationship with you and to better understand the healthcare sector;
- to contact you or otherwise provide you with information regarding Teva products or events (when your consent to receive direct marketing communications is not required);
- to tailor our communications to you based on your expertise and professional interests;
- to assess and analyse your interests and experience based on information our representatives collect during calls or visits;
- to carry out and follow-up training, including by providing you with further information, inviting you to symposia, congresses, seminars, debates and other events;
- to carry out or engage in market research, scientific cooperation or other research activities to better understand our markets and/or increase our expertise;
- to check that your professional expertise and experience matches our identified need for a particular service prior to entering into any personal services contract with you (to the extent that this is not a legal obligation as set out below);
- to manage our business relationship with you;
- to plan for, conduct and monitor our business in relation to our supplier/vendor or customer contracts;
- to handle any questions or complaints you may have about Teva or Teva staff
- to investigate allegations of misconduct; and
- for due diligence prior to setting up a trading account or in the circumstances of mergers and acquisitions, dispute resolution or audit.
We are required to carry out a balancing test of our legitimate business interests in using your personal data as outlined above against your interests and rights under the data protection law. You can find more information regarding Teva's legitimate interest balancing test by contacting us at the addresses specified in the "Your Rights" section below.
We process your personal data when it is necessary for the performance of a contract with you, or where you have requested us to take steps prior to us entering into a contract together, in particular:
- to fulfil any of our obligations owed to you under such contract such as to manage your orders, arrange the provision or receipt of goods and services, and to make payments to you for services provided, the reimbursement of expenses or rebates;
- where applicable, to manage information related to your attendance at an event, for example, your dietary requirements; and
- managing orders, questions and complaints regarding products where you have placed orders, posed questions in relation to orders, or submitted complaints.
c. Legal obligation
Sometimes we process your personal data to meet legal (including tax and accounting), regulatory, pharmacovigilance and compliance requirements, including:
- to respond to requests for information from government authorities;
- to comply with all legal and self-regulatory obligations including transparency and disclosure obligations or anti-gift obligations (this may either be in our legitimate interests or a legal obligation);
- to manage and respond to requests concerning medical information (this may either be in our legitimate interests or a legal obligation);
- prior to entering into a personal services contract with you, to check that your professional expertise and experience match our identified need for that service.
We may also process your personal data in connection with dispute resolution, legal claims, compliance, regulatory and such investigative purposes as we deem to be necessary (including disclosure of such information in connection with legal process or litigation). We maintain records of any consents, preferences or other settings to enable us to comply with data protection law.
Generally we do not rely on consent as a legal basis for processing your personal data. If you are an individual, however, we may ask for your consent prior to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
If we require your consent to process your personal data in any other circumstances we will contact you separately to request such consent.
Where we collect personal data to perform our contract with you or to comply with our legal obligations, this is mandatory and we will not be able to perform the contract or we may be prevented from complying with our legal obligations to you or third parties (such as mandatory reporting, tax and accounting) without this information. In all other cases, provision of the requested personal data is optional, but this may affect your ability to receive certain services or take part in certain activities where the information is needed for those purposes.
We will use your personal data only for the purposes for which it was collected, unless we reasonably consider that we need it for another purpose that is compatible with the original purpose. If we need to use your personal data for an unrelated but compatible purpose, we will notify you in advance of our use of your personal data and explain the legal basis for this. Note that we may process your personal data without your knowledge or consent where this is required or permitted by applicable law.
Sharing your personal data
We disclose your personal data to the following recipients and/or categories of recipients (in all cases, only when necessary to fulfil their functions):
- our staff (including employees and external consultants), professional advisors and agents;
- other functions and companies in the Teva group of companies worldwide such as Teva Pharmaceuticals Industries Ltd. in Israel, Teva Pharmaceuticals Europe B.V., Teva Croatia (PLIVA HRVATSKA), and Teva Pharmaceuticals USA Inc, who provide IT support, IT hosting and other group services such as HR, Finance and other support. You can view a list of all the Teva affiliates at the following website: http://www.tevapharm.com;
- third party service providers which process your personal data on behalf of Teva and who are bound by contractual obligations to keep your personal data confidential and appropriately secure, such as:
- IT support, website hosting, CRM hosting, event management and analytics providers;
- in the case of supplier and supplier personnel personal data, administrative, consultancy and logistical support service providers, investment houses for the purposes of benefits management, and training providers;
- enquiry and other database hosting and support
- various HR, travel and administration services.
- government authorities (including tax authorities), regulatory agencies and law enforcement officials, if required for the purposes specified above, if mandated by law, or if required for the legal protection of our legitimate interests in compliance with applicable laws.
- if you are a healthcare professional, relevant regulators such as EMA and pharmaceutical self-regulatory bodies such as EFPIA;
- our third party sources of personal data where we need to confirm and have agreed to assist them with the accuracy of information when / if we become aware of a change to your personal data (for example, if you are a healthcare professional, we may inform our third party sources that there has been a change to your personal data they hold (e.g. name, surname, workplace, telephone number) so that they can validate the accuracy of information with you);
- if you are a pharmacy customer, your nominated wholesaler;
- in the event that the business is sold or integrated with another business, potentially our advisers, any prospective purchaser’s advisers and any new owners of the business and third parties (and their advisors) with whom we merge or acquire in future.
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, and the Site would be unable to function. The use of such cookies does not require your consent.
Category 2: Performance Cookies
These cookies collect information on how people use and interact with the Site. We use these cookies to help us understand how users arrive at the Site, browse or use the Site and highlight areas where we can improve such as navigation, user experience and marketing campaigns. Where these are used in emails we use them to understand whether an email was opened, clicked on or sent to spam, time stamps of the above actions, and what device was used. This helps us to understand your level of interest and engagement with the information we send to you. The data collected can be combined with other data we collect to improve how the Site works and the quality and relevance of the information we sent to email recipients. For example we use Google Analytics to better understand how users use the Site. If you don’t want Google Analytics to be used in your browser, you can install this Google add-on: https://tools.google.com/dlpage/gaoptout?hl=en_GB.
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.
Category 4: Social Media Cookies
These cookies are used when you share information using a social media sharing button or "like" button on our Platforms, or when you engage with our content on or through a social site such as LinkedIn or Twitter. These cookies collect information about your social media interaction with the Site, such as whether or not you have an account with the social media site and whether you are logged into it when you interact with content on the Site. This information allows us to tailor and target our advertising and marketing activities. Please see the "Third Party" section below for more information on social media platforms placing cookies on our Sites.
Category 5: Advertising cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement, as well as help measure the effectiveness of the advertising campaigns and where we have your consent to personalise the emails we send you. They are a mix of first-party cookies and third-party cookies placed by advertising networks, such as Google and Facebook, with our permission. They remember that you have visited the Site and this information is shared with other organisations such as advertisers. Please see the "Third Party" section below for more details.
Category 6: Email tracking
We will also collect information using web beacons, which give us an indication of the usefulness of the emails we send to you such as whether an email was opened, clicked on or sent to spam, time stamps of the above actions, and what device was used.
We may combine this information with your personal identifier to personalise our messaging to you through our sales reps, emails, mobile or web channels and evaluate the quality of our messaging to you, customer research and benchmarking.
If you would like to avoid web beacons all together in your emails, you may refer to your settings in your email reader program and disable the functionality that enables remote images to load and by refraining from clicking on links.
- Google Analytics
- Orbital Media
- Ceuta Healthcare
Managing these technologies:
If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. If you would like to avoid cookies (web beacons) in your emails, you may refer to your settings in your email reader program and disable the functionality that enables remote images to load and by refraining from clicking on links.
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 Sites.
We keep information collected from cookies for a maximum of 6 months.
How we store your information
If we have a contract with you, your personal data will be 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.
Otherwise, your information will be retained for a maximum period of two years, or as otherwise required by applicable laws. For more information on your particular circumstance, please contact EUPrivacy@tevaeu.com.
You may be entitled under applicable law to ask Teva for a copy of your information, to correct it, erase or restrict its processing, or to ask us to transfer some of this information to other organisations. You may also have rights to object to some processing (in particular, where we do not have to process the information to meet a contractual or other legal requirement, or where we are using the information for direct marketing). These rights may be limited in some situations – for example, where we can demonstrate we have a legal requirement to process your personal data.
Where you have consented to the processing of your data, you may withdraw such consent at any time.
You have an absolute right to opt-out of processing for direct marketing purposes 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 Sites, you may also have an ability to change some marketing preferences online or in-app.
If you have any concerns about how we process your personal data or wish to exercise any of your rights or wish to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with Teva’s Data Protection Office by contacting us. If you live in Europe or in the UK, you can contact us at EUPrivacy@tevaeu.com. We hope that we can satisfy any queries you may have about the way in which we process your personal data. 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. In the UK, this is the Information Commissioner (https://ico.org.uk/). Relevant data protection authorities in the EU are listed here: https://edpb.europa.eu/about-edpb/board/members_en.
The data controller for personal data gathered by or on behalf of Teva UK Limited is Teva UK Limited (Company No 00302461) whose registered office is Ridings Point, Whistler Drive, Castleford, WF10 5HX, Norton Healthcare Limited (Company No 00947980) whose registered office is Ridings Point, Whistler Drive, Castleford, WF10 5HX and Teva NI Limited (Company No NI023272) whose registered office is Old Belfast Road, Millbrook, Larne, Northern Ireland, Northern Ireland, BT40 2SH.
Teva and its third party agents operate internationally and when necessary transfer your information to the recipients set out in the ‘Sharing Your Personal Data’ section in countries outside your own country and outside the European Economic Area, including to Israel and the United States. For the purposes of UK and EU data protection law, when transferring your information to Israel, Teva relies on the European Commission’s adequacy decision with respect to the transfer of data from the European Union to Israel; when transferring to other recipients outside the EEA that are not subject to an adequacy decision by the EU Commission or equivalent, Teva generally relies on EU Commission approved standard contractual clauses (or equivalent), or a vendor's Processor Binding Corporate Rules. Information on the relevant mechanism can be provided upon request to EUprivacy@tevaeu.com.
Note that those additional safeguards may not be usable in all circumstances, for example in the case of (i) disclosures to foreign authorities, (ii) where an urgent data transfer is necessary in your or another person's vital interests, or (iii) where you have expressly consented to the data transfers.
Changes to this Notice
This Notice may change from time to time. Teva will place an updated version of the Notice on this page and may otherwise communicate changes as appropriate. Regularly reviewing this Notice ensures that you are always aware of what information we collect, how Teva uses it and under what circumstances, if any, we will share it with other parties.
Updated: August 2020