Condensed Privacy Policy

General

For us at Gedeon Richter, your personal integrity is very important. Our goal is for you to feel safe when we process your personal data. In our role as data controllers, we, therefore, ensure that the applicable legislation on the protection of your data is always followed.

Area of application

This Privacy Policy applies to all Gedeon Richter’s use of personal data within the scope of our business in relation to you as a recipient of marketing from us.

Collected personal data

The information we collect about you is mainly provided by you when you register for one of our mailings, or events or when you notify us that you want more information from us.

To improve our web and app services, we also use cookies that may contain personal data. You can read more about how we use cookies in our cookie notice.

Our Use and Sharing

We at Gedeon Richter use your personal data in order to best provide you with the products and services we offer. Your personal data is used for the following purposes:

  • To market our products to you who are healthcare providers or prescribers through e.g. mailings by mail and e-mail and events,
  • To provide, develop and improve our website,
  • To provide information to and communicate with you as a representative of our customers and partners,
  • To comply with our legal obligations, as well as
  • To safeguard our legal interests in the event of a dispute.

We do not use your personal data for any other incompatible purpose and only keep it for as long as it is necessary.

In some cases, we may disclose your personal data to IT providers and companies that we cooperate with to provide our services. We will not sell your personal data to anyone else.

Your rights

You have the right to receive information about which personal data we use about you and what we do with it, as well as some control over your data. You, therefore, have the right in certain cases to obtain your data or to have it corrected, deleted, blocked or moved. You also have the right to object to certain types of use of your data or withdraw your consent to their use. If you think that we have used your data in an unauthorized way, you always have the right to complain to the Swedish Data Protection Authority. If you want to know more about your rights, you can read more in our full Privacy Policy.

Contact Information

If you have any questions about this Privacy Policy, our use of your personal data or if you want to exercise your rights, you can contact us as follows:

Gedeon Richter, organization no. 556890-1663
Postal address: Barnhusgatan 22, 5 tr, 111 23 Stockholm Sweden
Street Address: Barnhusgatan 22, 5 tr, 111 23 Stockholm Sweden

E-mail: [email protected]
Telephone: +46 8 611 24 00
Website: https://www.gedeonrichter.se

1. General

1.1. Gedeon Richter Nordics AB, corporate no. 556890-1663 (” Gedeon Richter ”) respects and protects your personal privacy. We want you to feel safe when we process your personal data. With this privacy policy (” Privacy Policy ”), we want to show how we ensure that your personal data is handled in accordance with applicable legislation.

1.2. In order to provide our website, marketing, etc. for you, we must use personal data about you. This Privacy Policy applies to you as a prescribing healthcare professional or the general public, when we, for example, provide marketing to you or when you visit our website.

2. Personal data controller

Gedeon Richter is the personal data controller for the use of your personal data and is responsible for the use taking place in accordance with applicable legislation. You will find our contact information at the bottom of this Privacy Policy.

3. Our use of your personal information

We, therefore, use your personal data for the following purposes:

  • To market our products to you who are healthcare providers or prescribers through e.g. mailings by mail and e-mail and events,
  • To provide, develop and improve our website,
  • To provide information to and communicate with you as a representative of our customers and partners,
  • To comply with our legal obligations, as well as
  • To safeguard our legal interests in the event of a dispute.

In the tables below, you get more information about e.g. why we use your personal data, which personal data we save to achieve those purposes and how long we save your personal data.

Purposes

 

To market our products to you who are healthcare providers or prescribers through e.g. dispatch by mail and e-mail and event

 

What we do

If you are a healthcare provider or prescriber, we use your personal data for the purpose of providing you with marketing, for example, to send you information about our products and activities by post and e-mail and to invite you to events.

Within the framework of this purpose, we may sort your personal data into different segments, e.g. based on areas of interest, points of contact, which activities you participate in or where you are in our customer journey, in order to provide you with customized and relevant marketing.

Personal data

Contact details such as name, phone number and email address.

Information related to your role as a healthcare provider or prescriber such as employer and title.

Surfing habits and visit history such as which pages you visited on our website, how long the visit lasted and which videos you watched.

Demographic data such as city, country and language.

Information about your device such as the device you are using, user ID and browser.

Legal basis

Your consent. Note that you have the right to withdraw your consent at any time according to section 8.4 below.

Balance of interests, in cases where we have access to your personal data through a collaboration partner, we will, however, only continue to process these after you have given your consent. This is as we judge that our interest in providing you with marketing outweighs your interest in the protection of your personal data, especially as we only do this on one occasion and only continue to provide you with marketing if you have confirmed that you wish it.

Storage time

We process your personal data as long as we provide marketing to you. By opting out, you can stop receiving mailings from us at any time, and we will then delete your personal information.

We go through our customer registers annually and delete your personal data if it turns out that you are inactive, no longer work for the care provider or similar.

To provide, develop and improve our website

 

What we do

If you visit our website and agree to our use of cookies for this purpose, we process your personal data for the purpose of developing and improving our website.

[We want you as a visitor to have the best possible experience of our website and the information that you can take part in, that it is relevant and interesting for you as a visitor. The data is collected for an analytical purpose.]

Personal details

Surfing habits and visit history such as which pages you visited on our website, how long the visit lasted and which videos you watched.

Demographic data such as city, country and language.

Information about your device such as the device you are using, user ID and browser.

Legal basis

Balance of interests, as we consider that our interest in providing, developing and improving our website outweighs your interest in the protection of your personal data

Your consent, when using cookies that are not strictly necessary for the function of the website. Note that you have the right to withdraw your consent at any time according to section8 .4 below. For more information about how we use cookies, see our cookie notice.

Storage time

We store your personal data for a maximum of 2 years.

To provide information to and communicate with you as a representative of our customers and partners

 

What we do

If you are a representative of one of our customers or partners, we process your personal data to communicate with you, within the scope of our business.  This may be, for example, sending information about our products, which does not constitute marketing, and to communicate with you via e-mail, for example.

Personal details

Contact details such as name, phone number and email address.

Information related to your role as a healthcare provider or prescriber such as employer and title.

Legal basis

Balance of interests, as we judge that our interest in providing information to, and communicating with, you as a representative of our customers and partners outweighs your interest in the protection of your personal data.

Storage time

We store your personal data during the time we have a contractual or other business relationship with the customer or partner you represent, and it is still necessary for us to be in contact with you.

Your personal data and communications with you by e-mail are deleted after 3 years from the end of the business relationship.

To comply with our legal obligations

 

What we do

Gedeon Richter may need to process your personal data to fulfill our legal obligations, for example requirements that follow from the Pharmaceuticals Act (2015:325) and the regulations of the Swedish Medicines Agency

Personal data

All the categories of personal data specified in this section 3.

Legal basis

We process your personal data to fulfill our legal obligations under applicable legislation.

Storage time

Your personal data is only saved for the time required according to applicable legislation, for example 7 years according to Accounting and tax legislation.

To safeguard our legal interests in the event of a dispute

 

What we do

We may need to process your personal data in order to safeguard our legal interests in the event of a dispute, such as to establish, exercise or defend legal claims.

Personal data

All the categories of personal data set out in section 3.

Legal basis

We process your personal data based on Gedeon Richter’s legitimate interest as we judge that our interest in protecting our interests in the event of a dispute outweighs your interest in protecting the personal data.

Storage time

Your personal data is saved for as long as is necessary for us to protect our legal interests in the event of a dispute. For example, during the time the dispute is ongoing, before it is finally settled.

4. How long do we save your personal data?

We only save your personal data as long as it is needed for the purposes for which we process the data according to this Privacy Policy. When we no longer need to save your data, we remove it from our systems, databases and backups. In the tables directly above (under section 3), we specify how long we save personal data about you for various purposes.

5. From where we collect your personal data

5.1. The personal data we use about you mainly comes from you in connection with you signing up for one of our mailings, or events or when you notify us that you want more information from us.

5.2. In addition to the information we collect from you, we may also collect common contact information, such as email addresses for a working group, from our partners. The data is collected for mailings related to your role as a healthcare provider or prescriber.

5.3. We only retain personal data we have collected from our partners if you have agreed to receive mailings from us.

6. Automated decision-making

We do not use automated processes to make decisions that significantly affect you.

7. Who do we disclose your personal data to?

7.1. Gedeon Richter may disclose your personal data to third parties, such as to IT providers and companies with which we cooperate to provide our services. In some cases, we may also need to disclose information at the request of authorities. In the table below, we specify which third parties we can disclose your personal data to, as well as which categories of personal data may be disclosed to each third party.

Receiver Categories of personal data
HubSpot Inc. Contact details, name, email, job title, workplace
MedMind AB Contact details, name, email, job title, workplace
Media-Soft inc. Contact details, name, email, job title, workplace
Google Inc.
– Youtube
– Analytics
Country, city, language, region, device, platform, unique user ID which videos you have seen on our site, Video player preference
Matomo Country, city, language, region, device, platform, unique user ID which videos you have seen on our site, Video player preference
Microsoft Ireland Operations Ltd (“Microsoft”)
– Teams,
– SharePoint/Cloud services,
– Outlook
Contact details, name, email, job title, workplace
The Swedish Medicines Agency Contact details, name, email, job title, workplace

 

7.2. We will not sell your personal data to anyone else.

8. Where do we use your personal data?

8.1. Gedeon Richter strives to always only process your personal data within the EU/EEA. In some cases, we may transfer your personal data to countries outside the EU/EEA. If personal data is transferred to any such country, we will ensure that the personal data continues to be protected and that the transfer takes place in a legal manner.

8.2. For transfers to a country outside the EU/EEA that does not ensure an adequate level of protection for personal data, we use the transfer mechanisms listed below, where we also specify to which countries we transfer personal data.

Countries outside the EU/EEA Transfer mechanism
United States of America The European Commission’s standard contract clauses

8.3. For more information about the legal basis for a specific transfer, or to obtain a copy of the relevant documentation regarding the security measures taken for the transfer, please contact us at the contact details set out in section 13 below.

9. Your rights

9.1. Our responsibility for your rights

9.1.1. Gedeon Richter is responsible as a personal data controller for your personal data being used in accordance with the law and for your rights to be enforced. You can contact us at any time if you want to exercise your rights. You will find our contact details at the bottom of this Privacy Policy.

9.1.2. Gedeon Richter is obliged to respond to your request to exercise your rights within one month of hearing from you. If your request is complicated or if a large number has been received, we have the right to extend the time by two more months. If we believe that we cannot do what you want us to do, we are obliged to notify you within one month of receiving your request at the latest why we cannot do what you want us to do and inform you that you have the right to complain to the supervisory authority.

9.1.3. All information, communication and all actions we carry out are free of charge for you. However, if what you request in relation to your rights is clearly unfounded or unreasonable, we have the right to charge an administrative fee to provide you with the information or to carry out the requested action, or to refuse to comply with your request.

9.2. Your right to access, rectification, erasure and restriction

9.2.1. You have the right to request from Gedeon Richter

a) Access to your personal data. This means that you have the right to request a register extract of our use of your personal data. You also have the right to receive a free copy of the personal data that we use. For any additional copies, we have the right to charge an administration fee. If you make a request in electronic format, e.g. by e-mail, we will provide you with the information in a commonly used electronic format.

b) Correction of your personal data. We will, at your request or on our own initiative, correct, de-identify, delete or supplement the information that we discover to be incorrect, incomplete or misleading. You also have the right to supplement with additional information if something relevant is missing.

c) Deletion of your personal data. You have the right to request that we delete your personal data if there is no longer an acceptable reason for us to use it. Acceptable reasons for our continued processing of your personal data may be:

(i) for us to comply with a legal obligation,
(ii) for archival purposes of general interest, scientific or historical research purposes or statistical purposes,
(iii) to establish, exercise or defend against legal claims.

Deletion as above must therefore take place if none of the circumstances above exists and if:

(iv) the personal data is no longer needed for the purpose for which we collected it,
(v) we use your data based on your consent and you revoke this,
(vi) you object to our use of your data which takes place after a balance of interests and we do not have important interests that outweigh your interests and rights,
(vii) we have used the personal data in an unauthorized way,
(viii) we have a legal obligation to delete the personal data, or

However, there may be legal requirements or other compelling reasons that prevent us from immediately deleting your personal data. We will then stop using your personal data for purposes other than complying with legislation or which are not necessary for any other compelling reason.

d) Limitation of Use. This means that we temporarily limit the use of your personal data and that we must inform you before the restriction of processing ends.  You have the right to request a restriction when:

(i) you believe that your information is incorrect and you have requested a correction according to point9.2.1a), while we investigate the correctness of the data,
(ii) the use is illegal and you do not want the data to be deleted,
(iii) we, as the data controller, no longer need to process the personal data for our purposes of processing, but you need it to be able to establish, assert or defend a legal claim, or
(iv) you have objected to use according to point9.3.1 , pending verification if our legitimate concerns outweigh your legitimate reasons.

9.2.2. We at Gedeon Richter will take all reasonable steps we can to notify anyone who has received personal data in accordance with section7 above if we corrected, deleted or restricted access to your personal data after you requested us to do so. At your request, we will inform you about to whom we have disclosed personal data.

9.3. Your right to object to use

9.3.1. You have the right to object to such use of your personal data that we make on the basis of a balancing of interests or in the public interest (see section3 above). If you object to such use, we will only continue use if we have important reasons for continuing use that outweigh your interests, rights and freedoms or if continued processing is necessary for the establishment, exercise or defence of legal claims.

9.3.2. If you do not want Gedeon Richter to use your personal data for direct marketing, you always have the right to object to such use by contacting us. Once we have received your objection, we will stop using personal data for this marketing purpose.

9.4. Your right to withdraw consent

For the use where we use your consent as a legal basis (see section3 above where we specify which legal grounds we have for our processing), you can withdraw your consent at any time by contacting us. You will find our contact details at the bottom of this Privacy Policy.

9.5. Your right to data portability

You have the right to data portability. This means a right to obtain part of your personal data in a structured, commonly used and machine-readable format and to be able to transfer this data to another personal data controller provided that it is technically possible. You only have the right to data portability when the use of your personal data is automated and we base our use on your consent or on an agreement between you and us.

9.6. Your right to complain to a supervisory authority

You have the right to submit any complaints about our use of your personal data to the supervisory authority. The supervisory authority in Sweden is the Privacy Protection Authority (IMY).

10. We protect your personal data

You should always be able to feel safe when you provide us with your personal data. Gedeon Richter has therefore taken appropriate security measures to protect your personal data against improper access, alteration and deletion. If there are security incidents that could affect you or your personal data in a more significant way, e.g. when there is a risk of fraud or identity theft, we will contact you and tell you what you can do to reduce the risk.

11. Cookies

We at Gedeon Richter use cookies on our website and in our services to improve your experience with us. We use cookies, among other things, to simplify and adapt our web and app services. In our cookie policy, we explain in more detail how we use cookies and which choices you can make for our cookies. You can find the policy here.

12. Changes to this Privacy Policy

Gedeon Richter has the right to change this Privacy Policy at any time. When we make changes that are not purely linguistic or editorial, you will receive clear information about the changes and what they mean for you before they take effect. If we need your consent to be able to fulfil our obligations to you and you do not accept the changed terms, you have the right to terminate the agreement with us before the terms come into effect.

13. Contact information

Do not hesitate to contact us at Gedeon Richter if you have any questions about this Privacy Policy, our use of your personal data or if you wish to exercise your rights.

Gedeon Richter, organization no. 556890-1663
Postal address: Barnhusgatan 22, 5 tr, 111 23 Stockholm Sweden
Street address: Barnhusgatan 22, 5 tr, 111 23 Stockholm Sweden

Email: [email protected]
Telephone: +46 8 611 24 00
Website: https://www.gedeonrichter.se/