Privacy Notice for Registering your Information
The collection and use of personal data, where LEO Pharma records your personal data in a Customer Relationship Management (CRM) system for certain commercial purposes is described in this privacy notice. It concerns both the instance where LEO Pharma has obtained your personal data from you directly or from a third party.
This privacy notice ensures compliance with articles 12-14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
1. We are the data controller - how do you contact us?
LEO Pharma UK is the data controller for processing of the personal data we have received about you or that you have provided to us. You will find our contact information below.
2. Contact information on the Data Protection Officer
If you have any questions about our processing of your personal data, you are always welcome to contact our Data Protection Officer. You can contact our Data Protection Officer in the following ways:
- By e-mail: Dataprivacy@leo-pharma.com
- On the phone: +45 4494 5888
- By letter: LEO Pharma A/S, Industriparken 55, 2750 Denmark, c/o Data Protection Officer
3. Purpose and legal basis for processing your personal data
We register your personal data for the following purposes:
- To manage your relationship with LEO Pharma
- To send you educational information about disease and therapy areas
- To send you promotional information about our products
Re 1: GDPR, art. 6(1)(f): Legitimate interests
Re 2 and 3: GDPR, art. 6(1)(a): Explicit consent
To ensure that your personal data is updated and correct and your relationship with LEO Pharma is coherent in both parties interest.*
* At any time, you may opt-out to LEO Pharma processing your personal data, see section 9 Your Rights.
Categories of Personal Data:
Information we have received from third parties: Unique Vendor ID, title and profession, full name, place of work eg. surgery/hospital/pharmacy, address and postcode, specialty, interest, graduation year and contact permission and if you have provided information about your professional number. Where relevant, we also record your consent to receive information as mentioned above.
Information we add is: number of visits and call frequency (for the purpose of documenting compliance with industry codes of practice), target, professional interests, adoption, awareness indicators and payment documents, if services provided, as relevant.
4. Recipients or categories of recipients
We disclose or entrust your personal data to the following recipients:
- Other LEO Pharma entities, which means other LEO Pharma subsidiaries, our ultimate holding company and its subsidiaries.
- We may share your personal data with IQVIA to ensure that our registered information is up to date and correct.
- Data processors, who LEO Pharma partner with to handle data on our behalf.
5. Transfer to recipients in third countries
We may share your personal data to LEO Pharma affiliates located outside the European Economic Area (“EEA”).
An overview of all LEO Pharma entities is available at www.leo-pharma.com. Where your personal data is transferred outside EEA, a data transfer agreement has been put in place. By contacting Data Protection Officer, you may obtain a copy of the agreement.
6. Where your personal data originates
7. Retention of your personal data
We store your personal data for 2 years after the latest contact, unless you have objected to being registered by LEO Pharma for the mentioned purposes.
8. The right to withdraw consent
You have the right to withdraw your consent at any time. You can do this by contacting us on the contact details listed above in paragraph 1. If you choose to withdraw your consent, it does not affect the legality of our processing of your personal data based on your prior consent and until the date of withdrawal. If you withdraw your consent, therefore, it will not be effective until this date.
9. Your rights
You have several rights in relation to our processing of information about you pursuant to the General Data Protection Regulation. If you want to use your rights, please contact us.
Right to see information (Access)
You are entitled to gain access into the information that we are processing about you.
Right to rectification (correction)
You have the right to have incorrect information about yourself corrected.
Right to deletion
In certain instances, you have the right to delete information about you before the time of our ordinary general deletion.
Right to limit processing
In certain instances, you have the right to limit the processing of your personal information. If you are entitled to limited processing, in future, we may only process the information - except for storage - with your consent or for the purpose of determining, enforcing or defending legal claims, or for protecting a person or important social interests.
Right to object
You may, in certain cases, have the right to object to our or legitimate processing of your personal information. You can also object to processing your information for direct marketing.
10. Complain to the Information Commissioner’s Office
You are entitled to file a complaint with the Information Commissioner’s Office (ICO), if you are dissatisfied with the way we process your personal information. You will find the Information Commissioner’s Office (ICO)’s contact information at www.ico.org.uk or email firstname.lastname@example.org.
Date of preparation: June 2018 UK/IE: MAT-17235