EAP Privacy Notice

INTRODUCTION

 

This webpage Our position on early access | Galderma (”Webpage”) is operated by Galderma SA, Zählerweg 10, 6300 Zug, Switzerland and its affiliates (“Galderma”, “We”, Us”) to offer healthcare professionals (“you”, “your” or “webpage users”) an opportunity to receive updates on Galderma’s Early Access Programs.

The privacy and security of your personal data is important to us. This Notice (“Notice”) will explain to you in a clear and comprehensive way how and why we collect, store, use and disclose your personal information (hereinafter referred to as “Personal Data”), as well as describe the controls and options at your disposal in how you choose to share your personal data.

For more information on how Galderma handles your Personal Data in general, please visit our corporate website and read our general Privacy Policy here.

 

HOW DO WE COLLECT THE DATA AND UNDER WHAT LEGAL BASIS?

Galderma will collect data directly from you based on your consent.

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 you with additional services, we may not be able to provide you such information.

 

WHAT PERSONAL DATA DO WE COLLECT AND WHY?

Early Access Program:

We only collect your identification details (name, surname), you contact details (telephone number, email address), your title and your country of residence to ensure you will receive information regarding Galderma Early Access Programs.

All your data is stored securely on our third-party, cloud-based mail service platform. A record of consent and how it was obtained will be stored on the same mail service platform.

Should you wish to delete (unsubscribe) yourself from the mailing list, simply check on the corresponding link in your email and we will permanently remove all personal data provided at the point of sign-up. We will not be able to add this back in, but should you wish to sign-up again, you can do so by following the process on the Webpage as before.

Deletion is both an automated and manual process run through our mail platform provider. All notifications are automatically sent to our team of administrators who will then personally process your request. We will undertake this process within 30 days, and you will receive notification accordingly.

Cookies:

Galderma may collect data from your computer or any other devices you use when visiting Galderma’s website, such as internet protocol (IP), domain name, internet service provider (ISP), data about date and time of your request and other information provided by tracking technologies (e.g., through Google Analytics). Please see our Cookie Policy for further details on our use of Cookies.

 

WITH WHOM DO WE SHARE YOUR PERSONAL DATA

In principle, we do not share or disclose your Personal Data with any third party. As an exception, we may disclose your Personal Data to other Galderma affiliates and certain third parties, acting for and on our behalf as data processors who provide us with various business services, including but not limited to professional services, information technology services and related infrastructure, customer service, e-mail delivery.

Currently we are using the following service provider as processor:

  • Bionical Emas
    The Piazza
    Mercia Marina, Findern Lane, Willington
    Derbyshire
    DE65 6DW
    United Kingdom

All Galderma affiliates and any third-party service providers are only permitted to use such data only to the extent strictly necessary for the purpose of performing services on our behalf and in accordance with all applicable data protection legislation.

Some of our affiliates and the third parties who provide services to us may be located outside the European Economic Area (EEA) or your country of residence; they may also store and process your data in data centers located outside the UK, the EEA or Switzerland. As a result, your Personal Data could be transferred to third countries where the local privacy laws may not provide an adequate or essentially equivalent level of data protection as the one afforded in your country of residence, the UK, the EEA or Switzerland. 

We will ensure that any third party recipients located in countries outside the UK, the EEA and Switzerland will comply with applicable local privacy laws and regulations and require such parties to implement appropriate safeguards e.g., by executing the Standard Contractual Clauses adopted by the European Commission, as amended or replaced at any time, or any other legally approved transfer mechanism, as well as implement any supplementary measures, as may be required by law or deemed necessary by Galderma, to ensure the security of the processing as well as to ensure that an adequate or essentially equivalent level of data protection is afforded by the importing entity, taking into account the factual circumstances of the transfer(s) in question.

To receive a detailed list of our third-party recipients and a copy of the adopted data safeguards, where applicable, you may contact our Privacy Office via email at privacy.office@galderma.com

 

PERSONAL DATA OF CHILDREN

This Webpage is intended for adult use only, specifically for qualified healthcare professionals. We do not knowingly collect personal data from anyone under the age of 16 through this Webpage. We assume that any person who provides their personal data through this Webpage is a qualified healthcare professional. If we learn that we have collected any personal data from a child under the age of 16, we will take steps to delete such information promptly.

 

HOW LONG WILL WE KEEP YOUR PERSONAL DATA

We will keep your Personal Data only so long as we need it to provide the relevant services to you and to fulfill the purposes described in this Privacy Notice. This is also the case for anyone that we share your information with and who carries out services on our behalf. When we no longer need to use your information or at your request, your Personal data will be securely and permanently disposed or rendered completely anonymous. More specifically, we will delete/anonymize your data three years after you have subscribed (unless you are contacted about an EAP and decide to participate in it).

 

WHAT ARE YOUR DATA PROTECTION RIGHTS?

Depending on your country of residence, you might have the right to request from us to (all of the following are applicable to all EU/CH/UK residents):

a) provide you with further details on the processing of your Personal Data;
b) provide you with access to your Personal Data that we have stored and request to obtain copies thereof;
c) update any inaccuracies in your Personal Data we have stored that is demonstrated to be inaccurate or incomplete;
d) delete any Personal Data for which we no longer have a lawful basis of processing;
e) provide you or a third party, with a copy of your data in a digital format (data portability);
f) cease any processing based on the legitimate interests or public interest to process information, unless our reasons for undertaking that processing outweigh your data protection rights; and
g) restrict certain aspects of the processing of your information.

If you wish to exercise any one of your privacy rights, or request additional information or make a complaint about the processing of your data, you may contact our Privacy Office by email at: privacy.office@galderma.com; alternatively, you may contact our Swiss office in writing at Galderma SA, , Zählerweg 10, 6300 Zug, Switzerland or write to the relevant Galderma entity in your country of residence.

If you are not satisfied with our response to you or have a concern about the way we handle your personal data, you have the right to file a complaint with the data protection authority of your country of residence or place of work. A list with the Supervisory Authorities in European Economic Area and their contact details is available here:  https://edpb.europa.eu/about-edpb/board/members_en.

 

CHANGES TO THIS PRIVACY NOTICE

From time to time, we may update this Privacy Notice. Any changes will become effective when we post the revised Privacy Notice on the Webpage. Your use of the Webpage following these changes means that you are informed of the revised Privacy Notice.

Last updated: October 2022