In case we want to use your Personal Data for purposes unrelated to those described in this Notice, we will first notify you and, where required, offer you a choice as to whether or not we may use your Personal Data in this manner.
6. DISCLOSURE OF YOUR PERSONAL DATA
In addition to the Galderma entity mentioned in the data controllers & contact section (see Section 12), We share your Personal Data with the following types of third party organisations:
Service providers. These are external companies that We use to help Us run our business (e.g. website operation, support services, website development, data analysis, CRC, etc.). Service providers, and their selected staff, are only allowed to access and use your Personal Data on our behalf for the specific tasks that they have been requested to carry out, based on our instructions, and are required to keep your Personal Data confidential and secure. Where required by applicable law, you can obtain a list of the providers processing your Personal Data (see Section 12 to contact Us).
Third party recipients using Personal Data for legal reasons or due to merger/acquisition. We will disclose your Personal Data to third parties for legal reasons or in the context of an acquisition or a merger (see Section 5 for details).
7. RETENTION OF YOUR PERSONAL DATA
Galderma takes every reasonable step to ensure that your Personal Data are only processed for the minimum period necessary for the purposes set out in this Privacy Notice. The criteria for determining the retention period for your Personal Data are:
(a) Galderma will retain copies of your Personal Data in a form that allows for identification only for as long as: (i) We maintain an ongoing relationship with you; or (ii) your Personal Data are necessary in connection with the purposes set out in this Privacy Notice and we have a valid legal basis,
(b) if you are a healthcare professional, your Personal Data will be retained for 2 years after your last interaction with us, unless applicable laws or sectoral regulations impose longer retention periods,
(c) in the remaining cases, your Personal Data is kept for the duration of: (i) any applicable limitation period (i.e. any period during which a person could bring a legal claim against us), and (ii) an additional 2 months following the end of the applicable limitation period (so we are able to identify any personal data of a person who may bring a claim at the end of the applicable period), and
(d) in addition, if any relevant legal claims are brought, we may continue to process your Personal Data for such additional time necessary in connection with that claim.
During the periods noted in paragraphs c (i) and c (ii) above, we will restrict our processing of your Personal Data to storage or, and maintaining the security of, those data, except to the extent the data need to be reviewed in connection with any claim, or any obligation under applicable law.
Once the periods in paragraphs (a), (b), (c) and (d) above, each to the extent applicable, have concluded, we will either (i) permanently delete or destroy the relevant Personal Data or (ii) anonymise the relevant Personal Data.
8. DISCLOSURE, STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA
We use appropriate measures (described below) to keep your Personal Data confidential and secure. Please note, however, that these protections do not apply to information you choose to share in public areas such as third party social networks.
People who can access your Personal Data. Your Personal Data will be processed by our authorised staff or agents, on a need to know basis, depending on the specific purposes for which your Personal Data have been collected.
Measures taken in operating environments. We store your Personal Data in operating environments that use reasonable security measures to prevent unauthorised access. We follow reasonable standards to protect Personal Data. The transmission of information via the Internet is, unfortunately, not completely secure and although We will do our best to protect your Personal Data, We cannot guarantee the security of the data during transmission through our Websites.
Transfer of your Personal Data. The storage as well as the processing of your Personal Data as described above may require that your Personal Data are ultimately transferred/transmitted to, and/or stored at, a destination outside of your country of residence, notably Switzerland and the USA. When we share your Personal Data with an entity located outside of the European Economic Area (“EEA”) (e.g. other Galderma / Galderma entities), including to countries which have different data protection standards to those which apply in the EEA, we will put in place, in line with applicable legal requirements, appropriate safeguards to ensure that your Personal Data gets the same protection as it does here in the European Economic Area. These measures may include (i) entering into European Commission approved standard contractual clauses to protect your Personal Data (and you have a right to ask Us for a copy of these clauses by contacting us as set out below) and/or (ii) will rely on your consent (where permitted by law).
9. YOUR RIGHTS
Access to Personal Data. You have the right to access and request a physical or electronic copy of information held about you. Where the data was not obtained directly from you, you also have the right to request information on the source of your Personal Data.
These rights can be exercised by sending Us an e-mail at email@example.com or writing to us at Galderma SA, Rue d'Entre-deux-Villes 10, 1814 La Tour-de-Peilz, Switzerland, attaching a copy of your ID or equivalent details (where requested by Us and permitted by law). If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected. Please note that any identification information provided to Us will only be processed in accordance with, and to the extent permitted by applicable laws.
Additional rights (e.g. modification, deletion of Personal Data). Where provided by law, you can request deletion, objection, the portability, rectification of your Personal Data and restrict our processing of your Personal Data.
Please note that, in certain circumstances, We will not be able to delete your Personal Data without also deleting your user account. We may be required to retain some of your Personal Data after you have requested deletion, to satisfy our legal or contractual obligations. We may also be permitted by applicable laws to retain some of your Personal Data to satisfy our business needs.
Where available, our Websites have a dedicated feature through which you can review and edit the Personal Data that you have provided.
We hope that We can satisfy queries you may have about the way we process your Personal Data. However, you have the right at any time to complain to competent data protection authorities.
10. YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR PERSONAL DATA
We strive to provide you with choices regarding the Personal Data that you provide to Us. The following mechanisms give you the following control over your Personal Data:
Cookies/Similar Technologies. You manage your consent via (i) our consent management solution or (ii) your browser so as to refuse all or some cookies/similar technologies, or to alert you when they are being used. Please see Section 4 above.
11. CHANGES TO THIS NOTICE
If We change the way We handle your Personal Data, We will update this Notice. We reserve the right to make changes to our practices and this Notice at any time, please check back frequently to see any updates or changes to our Notice.
12. DATA CONTROLLERS & CONTACT
To ask questions or make comments on this Notice and our privacy practices or to make a complaint about our compliance with applicable privacy laws, please contact our Group Data Protection Officer at: firstname.lastname@example.org or in writing to Galderma SA, Rue d'Entre-deux-Villes 10, 1814 La Tour-de-Peilz Switzerland or write to the relevant Galderma entity in your country of residence.
We will acknowledge and investigate any complaint about the way We manage Personal Data (including a complaint that We have breached your rights under applicable privacy laws).
Last updated October 2020.
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