Zambon Privacy Policy

This privacy policy describes the collection, storage and use of personal information collected and used by us, Zambon, in the framework of our relationship with you as either a supplier, vendor, consultant, job applicant, vendor, distributor, healthcare provider or patient. It may apply to you in different respects, or only in one of these.

You have the right to be informed about our data processing practices, and to control personal information we hold about you. This document is therefore meant to provide you with transparent and detailed information about the way and the reasons why we collect, store and use your personal information, and about how you may exercise your rights under the data protection legislation.

This privacy policy was issued on September 1, 2018.

1. Who we are:

Zambon S.A., is a company with registered offices at Avenue E. Demunterlaan 1/9, 1090 Brussels, Belgium and registered with the RPR/RPM under the number 0403.069.741 ("Zambon" or "We"),

As data controller, we respect your right to privacy and will only process personal information you provide to us in accordance with applicable data protection laws and as described in this policy. (Applicable data protection laws include (i) the General Data Protection Regulation (Regulation 2016/679) (“GDPR”); and (ii) all other existing or new applicable laws relating to or impacting on the processing of information of a living person and privacy).

If you have any questions about how we collect, store and use your personal information, or if you have any other privacy-related questions, please email us at privacy-be@zambongroup.com.

We do not and will not knowingly collect information from any unsupervised child under the age of  16.

 

2. The personal information we collect about you and the purposes for which we collect it:

Below you will find an overview of:

  • the categories of personal data that we (or third party data processors acting on our behalf) may collect, use and store about you;
  • the purposes for which this information would be collected;
  • the legal basis for processing.

 

Overview of the categories of personal data that we (or third party data processors acting on our behalf) may collect, use and store about you:

Data Subjects

Healthcare Providers (HCPs)

Patients

Others; Suppliers; Vendors; Consultants; Agents; Distributors

Information we might collect and process includes:

Contact details e.g. name, address

Contact  details e.g. name, address

Contact details e.g. name, address

E-mail address

 

E-mails

E-mail address

 

Emails

E-mail address

 

Phone number

Bank account details

VAT or business registration number

Speciality

Company contact details and Company number

Treating physician

Description of patient case (e.g. in promotional material)

Video/pictures (via HCPs  in the frame of promotional material, patient testimonials)"

Full contact details of employer (or of the supplier, vendor, consultant, agent or distributor itself  when such is a natural person/data subject, including website address

National register number and/or INAMI number

 

Authorisation to send information/offer regarding products

Authorisation to send information/offer regarding products

 

Health data such as: Physical/mental health; Previous medical conditions;

VAT or business registration number.

 

Bank account details Consulting hours

CV's (other work  history or reference details)

Current/on-going medical conditions; Adverse effects; Medication; Medical  trial data;

Preference of type of contract

Transfers of values (in scope of Sunshine Act)"

Data from LRX studies (anonymized patients, shown  in age groups)

National registration numbers

Prescription behaviour

Genetic data

Agreements and contracts

Preferences for use of certain medication

 Racial data

 

Medical questions relative to  or products

 

 

Medical sample requests

 

 

Partner  contact  details  (in  case of emergency during booked travel by Zambon)

 

 

Health information

 

 

Safety reports linked to their patients

 

 

Description of  patient case (e.g. in promotional material)

 

 

Medial trial data

 

 

Website usage data

 

 

 

Data we collect in specific situations:

Specifically relating to job applicants, we may collect contact details (name, address, phone number), assessment forms, cvs, references, social media account details (e.g.: LinkedIn), background checks (e.g.: confirmation of qualifications) and interview notes.

We store and use this information in order to take steps (decide to recruit or not) at the request of the employee candidate prior to entering into a potential employment contract.

Camerasurveillance. We may collect CCTV video footage  on site. Zambon ensures all individuals are made aware by a sign at the entrance of  the property and that it complies with all applicable  CCTV Footage regulations.

We store and use this information for on-site security reasons.

Cookies and similar technologies, We may collect personal information about you as described in our cookie police which can be found on: www.zambon.com

 

3. For what purposes may process and use your information?

Zambon collects and processes your personal data for the purposes described hereafter. The processing is limited to the specific purposes of its activities and Zambon ensures that only the necessary and relevant data is processed for the specific purpose at stake.

In general, Zambon processes your data in the situations permitted by law, more specifically:

  • to comply with the legal obligations of Zambon;
  • to take the preliminary steps required for the conclusion of a contract and its execution;
  • for the fulfillment of Zambon's legitimate interest, taking into account a fair balance between its interests and your rights and freedoms;
  • in specific cases, provided your consent, as a result of a specific and unambiguous request, preceded by clear and comprehensible information that you can withdraw at any time in accordance with the law.

 

3.1 Compliance with the law

Zambon is bound by numerous laws and regulations that require your data to be processed as part of its many activities. These obligations may imply that Zambon cooperates with the competent authorities and / or third parties and, as the case may be, communicates certain of your data to them.

These obligations are, amongst others, within the following legal and regulatory domains:

  • the law of 25 March 1964 on the medicines and its executive decrees, as well as the deontological code of Mdeon (e.g. samples legislation, implementation of  the compulsory  visa procedure, etc.);
  • the Belgian Income Tax Code (preparation of the annual income statement 281.50) and more general Zambon’s obligation to contribute to the fight against fraud and tax evasion;
  • the Sunshine Act (including the mandatory notification of premiums or benefits that it directly or indirectly to health care professionals and healthcare organizations);
  • Adverse Event Reporting: Zambon is obliged to report pharmacovigilance relevant  information to health authorities worldwide (including to countries that may have another  level of data protection compared to the EU). For the HCP, the report will include the name, profession (e.g. physician, pharmacist), initials or address, email and phone number as provided. The contact information is required to be able to follow-up with the reporter to gain high quality and complete information on adverse events. If the reporter does not wish to provide his or her contact details, “privacy” is entered in reporter's names field. For Patients, the report will only contain, age / date of birth / year of birth, gender and initials as provided, but never the patient's name.
  • the obligation to contribute to the fight against market abuse, detection and reporting of certain information to the competent authorities;
  • Complaint handling and more in general he obligation to protect consumers of Zambon products and services;

 

3.2 Contractual relationships with Zambon

In some cases, Zambon may have to obtain and process certain data before closing contracts, in particular

  • respond to your questions or requests regarding products or services;
  • determine the conditions and guarantee the conditions under which the contract will be concluded.

In the context of the execution or the management of existing contracts, Zambon has to implement a number of data processing processes and operations of different types in order to meet administrative and accounting obligations, as well as managing its business relationship with you.

This may include the processing of personal data for:

  • general administration such as the processing or executing of any document or underlying transaction, operation, project or task relating to the business relationship (e.g. the contract itself, purchase orders, delivery, shipment or customs, order or sample management, deliveries, invoicing of tangible and intangible services, payments, etc. ;
  • organizing your participation in an event; providing you with practical / logistical information about the event; allowing you to enjoy premiums and benefits from Zambon within the limits of applicable law;
  • perform obligations or enforce Zambon’s rights in relation to our contractual or business relationship with you or with a third party certify, qualify, manage the services provided and/or products supplied;
  • certify, qualify, manage the services provided and/or products supplied;
  • organize meetings with representatives;
  • negotiate contractual terms;
  • participate to public or private tenders;
  • support, substantiate Zambon's position, allegations, arguments, defense, conclusions, in disputes and legal proceedings involving you or any third party;
  • analyse the use of our site in order to continuously improve content and measure performance;
  • optimize and tailor the use of our site and our communication to you

In this connection, your data may be shared internally within Zambon through various departments  and services, including those who are not directly responsible for the relationship with you or the performance of a particular contract.

Zambon may process your data for additional  purposes in connection with  its relationship with you and the performance of the contract.

 

3.3 Legitimate interests of Zambon

Zambon also processes your data for the realization of its legitimate interests. To this end, Zambon strives for a fair balance between the need to process data and respect for your rights and freedoms, including the protection of privacy.

Personal data are therefore processed for:

  • Technical commercial information: the analysis of potential competitors and business  partners and prospecting and evaluation of potential business partners;
  • Public relations: marketing and the creation of goodwill for the organization. Zambon can ask you (i) questions about your satisfaction with the eye on improving its services; (ii) invitations to participate in scientific events; and (iii) send targeted advertisements that may be  of interest to you;
  • Market research: studies on prescription behaviour, preferences and other intentions of people, to determine business strategies;
  • Security: in order to guarantee the security of persons and property;
  • Statistical research: carrying out statistical surveys or obtaining a statistical result (e.g. dissemination of general information, assistance in planning and decision-making and service to science);
  • Historical research: from private or public archives with a view to analysing a past event or to permit such analysis.

 

3.4 Specific legitimate interest of Zambon: Direct marketing purpose

Zambon conducts market segmentation and profiling - in particular, according to the HCPs business activities, prescription behaviour, patient needs, etc. - to offer you appropriate products and services that correspond to your professional and personal situation and the products / services you already have.

Zambon can process personal data, amongst others:

  • to send you advertisements that may be of interest to you and to send you satisfaction  surveys about the services that Zambon offers to you, in accordance with the law applicable;
  • Zambon can ask you (i) questions about your satisfaction with the eye on improving its services; (ii) invitations to participate in scientific events; and (iii) send targeted advertisements that may be of interest to you;
  • for the analysis of customers or prospects behaviour or preferences based on purchases and other parameters and/or interactions with the customers;
  • to further design and prepare its marketing campaigns.

3.4 Your permission to send electronic communication

Zambon may process your personal electronic contact information, namely your mobile  phone  number and e-mail address, to send you personal information, advertisements or proposals via direct marketing or newsletters. In this case, Zambon first asks for your specific permission.

 

4. Sources of personal data

 

Personal data you give us

You may give us personal information about you by filling in forms on our site or by registering on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to receiving email notifications and/or promotional materials from us, subscribe to receive information from us, enter a competition, promotion or survey, or when you report a problem with our site.

 

Personal data we receive from other sources

We may receive personal information about you if  you use any of the other websites we operate or  the other services we provide. In this case we will have informed you when we collected that data that  it may be shared internally and combined with data collected from other sources.

We are also working closely with third parties, including but not limited to business partners, sub- contractors in technical and delivery services, advertising networks, analytics providers, search information providers and may receive personal data about you from them. In this case, those data processors will have informed you when they collected that data that it may be shared with others.

 

5. Disclosure of personal data

We will not disclose, sell or rent your personal information to any third party unless you  have consented to this. If you do consent but later change your mind, you may contact us and we will cease any such activity.

We may disclose personal data to the following 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 Zambon group of companies worldwide;
  • third party service providers which process your personal data on behalf of Zambon and who are bound by contractual obligations to keep your personal data confidential and appropriately secure;
  • purchasers, or potential purchasers, of all or part of Zambon's business (and  their professional advisors), under a confidentiality commitment;
  • and governmental body, regulatory agencies and law enforcement officials or agencies, 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

 

6. Data retention

We will delete personal data once it is no longer required to fulfil the purposes outlined in this Privacy Policy, unless their retention would remain required for other fundamental purposes, including but not limited to complying with our legal obligations, handling claims and resolving disputes.

 

7. International transfers

When we transfer personal information that we collect from you to third party data processors located in countries that are outside of the European Economic Area and which do not offer an adequate level of protection, we ensure the use of appropriate data transfer tools such as the entering into of the standard contractual clauses issued by the European Commission.

 

8. Security

Zambon has taken appropriate technical and organisational measures to safeguard the personal information that you provide us with, against unauthorized or unlawful processing and against accidental destruction, loss or damage.

 

9. Your rights

You have the following rights as a data subject:

  1. the right to access to personal information that we hold about you;
  2. the right to ask us to update or correct any out-of-date or incorrect personal information that we hold about you;
  3. where the processing is based on your consent, the right to withdraw consent at any given time, without affecting the lawfulness of processing based on consent before its withdrawal;
  4. the right to erasure where the conditions of article 17 of the GDPR have been met;
  5. the right to restriction of processing where the conditions of article 18 of the GDPR have been met;
  6. the right to data portability insofar the conditions of article 20 GDPR apply to you;
  7. the right to object to processing of personal data concerning you, insofar the conditions under article 21 GDPR have been met;
  8. the right to lodge a complaint with a supervisory authority; and
  9. the right to opt out of any direct marketing communications that we (with your consent) may send you.

(With the exception of section 6(h) of this policy), you can exercise these rights at any given time by emailing us at privacy-be@zambongroup.com.