Medical Information, Pharmacovigilance 
and Product Complaints 
Privacy Notice

Last Updated: 15-06-2026

1. Introduction
2. Scope of the Policy
3. Responsible Entity - Controller 
4. Data We Collect 
5. Sources Of Your Personal Data
6. Our Purposes and Legal Bases 
7. Data Sharing
8. International Data Transfers
9. Data Retention
10. Rights of Individuals
11. Data Security
12. Changes to the Policy
13. Contact Information 

1. Introduction

Protecting your personal data while ensuring your safety is extremely important for Galderma SA or any of its subsidiary or affiliated companies worldwide (“Galderma”). This Privacy Notice outlines how Galderma collects, uses, shares, stores, and otherwise processes the information that relates to an identified or identifiable natural person (“personal data”) in relation to medical information inquiries, pharmacovigilance activities and product complaints in compliance with applicable data protection laws and regulations.

2. Scope of the Policy

This Privacy Notice applies to the processing of personal data of:

• any individual (e.g., patients or their representatives, professional caregivers, healthcare professionals etc.) requesting medical information, or reporting safety information (suspected side effects or adverse events), or raising product complaints to a Galderma entity (“submitter”), and

• any individual whom such medical or safety information concerns (“subject”).

In this Privacy Notice, “you” refers to the individuals described above.

Information on processing activities by Galderma regarding personal data in the context of Galderma websites can be found in the Global Privacy Notice.

With respect to the processing of personal data in healthcare professionals (HCPs), please see the HCP Privacy Notice {include link}.

3. Responsible Entity - Controller 

The data controller is the Galderma entity with which the individual requesting or reporting the medical or safety information report interacts, namely [INSERT FULL DETAILS OF THE LOCAL GALDERMA ENTITY] (“Controller” or “we”, “us”, “our”). 

If you have any questions or concerns about this Privacy Notice or our processing of your personal data, please contact us via the email address included in the ‘Contact Information’ section.

4. Data We Collect

Depending on how you interact with Galderma (online, offline, over the phone, etc.), We may collect various types of personal data about you, as described below:

For the submitters:

• Personal identification data: Name, relationship with the subject.

• Contact details: Email address, phone number, postal address.

• Professional details: Occupation/affiliation

• Interaction data: Communications, Statements.

For the subjects:

• Personal identification and demographic data: Name/initials, gender, date of birth/age, weight and height.

• Sensitive data: Medical and treatment history and status, genetic or biometric data.

• Feedback data: suspected side effects or adverse events, medical information queries, product quality complaints, details of the product of interest, including the dosage and duration you have been taking or were prescribed, the reason you have been using the product and any subsequent change to your regimen.

In some cases, the submitter and the subject may be the same individual (for example, a patient directly reporting a suspected side effect or adverse event).

Please note that we only request personal data that is requested or permitted under the applicable laws and is necessary to serve the lawful purposes. If you choose not to provide certain personal data, we might not be able to handle appropriately your medical information inquiries, pharmacovigilance reports and product complaints.

5. Sources Of Your Personal Data 

We collect personal data either directly from the individual to whom the personal data relates, or from the individual’s representatives, professional caregivers, healthcare professionals. 

6. Our Purposes and Legal Bases

Below, you may find a detailed overview of all the purposes for and all the legal bases under which we will process your personal data in line with the respectful activity. Please note that not all of the uses below will be relevant to every individual.

In case we want to use your personal data for purposes unrelated to those described in the table above, we will appropriately notify you and, where required, obtain your consent or offer you a choice as to whether or not we may use your personal data in this manner.

When publishing information about adverse events (such as case studies and summaries), we will remove identifiers from any publication to keep your identity private.

7. Data Sharing

We may share your personal data with service providers that process personal data on our behalf and subject to our instructions as so-called data processors, for the purpose of providing their professional services to us:

• IT service providers (hosting services, email services, document processing software, website analytics, website operation, website development)

• Tag management, cookie consent and analytics technology providers (e.g., providers enabling pixels, tags, web beacons or other tracking technologies)

• Cybersecurity, fraud prevention and data protection service providers responsible for system monitoring, security and backup

• Customer support and patient or consumer engagement service providers supporting educational materials or product-related information services

• Event management and advertising, media and social media partners who support targeted advertising, campaign measurement and audience insights

• Marketing support providers (e.g., handling and dispatch of newsletters)

• Market research agencies or consultants conducting surveys, interviews and studies

• Privacy and compliance management service providers (for example, OneTrust LLC)

• Logistics and delivery providers assisting with shipment of materials, samples or event-related items.

Furthermore, we may share your data with the following third parties:

• Other entities of the Galderma group. 

• Other third parties (data controllers):

  • Regulatory authorities (including healthcare authorities, tax authorities and law enforcement agencies) for the purpose of compliance with legal obligations (e.g., under healthcare transparency laws, tax law, drug/medical device safety laws) 

  • Other pharmaceutical companies who are our co-marketing, co-distribution, or other license partners of Galderma if they relate to the product/activity of interest

  • Healthcare professionals and clinical research organizations for the purpose of collaboration

  • Consultants (including lawyers and auditors) for the purpose of compliance with legal obligations and/or safeguarding rights

  • Courts for the purpose of safeguarding our rights

  • Potential buyers or acquirers of all or part of our asset(s) and/or activity(ies) for the purpose of corporate transactions

Where any such organization is located outside of your country of residence, the resulting international transfers of Personal Data are carried out in accordance with Section 8 of this Privacy Notice.

8. International Data Transfers

The storage as well as the processing of your personal data as described above may require that your personal data is ultimately transferred/transmitted to, and/or stored at, a destination outside of your country of residence. When we share your personal data with an entity located outside of your country of residence (e.g. other Galderma entities, third parties), including to countries which have different data protection standards to those which apply in your country of residence, we will put in place, in line with applicable legal requirements, appropriate safeguards to ensure that your personal data is appropriately protected. In the absence of an adequacy decision and/or any other data protection related certifications – unless applicable data protection law provides for an exception – these measures may include (i) entering into approved standard contractual clauses, as amended or replaced at any time, to protect your personal data, as well as any supplementary measures required by law or deemed necessary, to provide an adequate level of data protection and/or (ii) obtaining your consent (where permitted or required by law).

You may request further information regarding these safeguards or obtain a copy of the relevant contractual protections by contacting us using the details provided in Section 13.

9. Data Retention

We will hold your personal data for as long as it is necessary to fulfil the purposes that we collected it for, taking into consideration the nature of the personal data, the purposes for which we are processing your personal data and the potential risk of harm from unauthorized use or disclosure of your personal data. Therefore, personal data may be kept for as long we reasonably determine it is required for, according to our retention policy and applicable laws.

In any case:

• Personal data in relation to medical information inquiries is kept for at least 10 years after receipt and closure of the inquiry

• Personal data in relation to pharmacovigilance reports is kept for at least 10 years following termination of Galderma’s marketing authorization for the product related to the report

• Personal data in relation to product complaints is kept for at least 10 years following termination of Galderma’s marketing authorization for the product related to the report

Retention periods may be extended where required by applicable pharmacovigilance or quality regulations. We may also retain personal data further and as necessary for the establishment, exercise or defense of legal claims.

Data that is no longer needed will be securely deleted or anonymized.

10. Rights of Individuals

Depending on your jurisdiction, you may have the following rights, in accordance with the applicable data protection laws:

• Access and to be informed: To request a copy and/or to be informed of the personal data we hold about you.

• Rectification: To request correction of inaccurate or incomplete personal data.

• Erasure: To request the deletion of personal data, where applicable.

• Restriction: To request the restriction of processing, where applicable.

• Objection: To object to processing where applicable.

• Data portability: To request a copy of your personal data, which you have provided to us, in a structured, commonly used, machine-readable format.

• Withdraw consent: To withdraw consent at any time, where consent was provided for processing.

• Automated decision-making and profiling: To request not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Where applicable, you also have the right to obtain human intervention, to express your point of view, and to contest the decision

• To be informed about data transfers: To request more information about the countries where your data is transferred and, where such countries have not been recognized as proving an adequate level of data protection, to request more information about the appropriate safeguards implemented such as standard data protection clauses.

Please note that the exercise of these rights may be subject to limitations and/or restrictions set out in applicable laws; they may also be subject to variations or additional rights may be available to you in your country of residence or place of work.

If you wish to exercise one of these privacy rights, you may submit a relevant request using our Data Subject Request Webform; alternatively, you may also send our Group Data Privacy Office an email at privacy.office@galderma.com, or write at the Galderma Headquarters, at Galderma SA, Zählerweg 10, 6300 Zug, Switzerland.

If we do not satisfy your request or if you consider that the processing of your personal data infringes data protection law otherwise, depending on your jurisdiction, you may also have the right to lodge a complaint with a data protection authority in your country of residence, or your place of work or of the alleged infringement. If you are based in the EEA, the competent Data Protection Authority’s contact details may be found here. If you are based in the UK, you may contact ICO here. If you are based in Switzerland, you may contact FDPIC here.

If you are based in the US, please visit our US Privacy Notice to learn how to exercise your privacy rights.

11. Data Security

We take the security of your personal data seriously and implement appropriate technical and organizational measures to protect it from unauthorized access, accidental loss, or misuse, alteration or unlawful processing. Please note, however, that these protections do not apply to information you choose to share in public areas such as third-party social networks.

12. Changes to the Policy

We might change the way we process your personal data. Therefore, Galderma reserves the right to modify this Privacy Notice at any time. Please check back frequently to see any updates or changes in our Privacy Notice.

13. Contact Information

If you have any questions or concerns about this Privacy Notice or your personal data, please contact us at privacy.office@galderma.com.

Please also note that Galderma SA has designated EU and UK Representatives pursuant to Article 27 of the GDPR and UK GDPR respectively.

EU:

Q-MED AB
Seminariegaten 21, 75228, Uppsala, Sweden
Email:  DataProtection.SEUPP@galderma.com

UK:

Galderma (U.K.) Limited
Evergreen House North, Grafton Place, London, England, NW1 2DX
Email: uk.privacy.office@galderma.com