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Privacy & Cookie Policy

Purpose of this privacy notice

Chiesi Limited (collectively referred to as “Chiesi”, “we”, “us” or “our” in this privacy notice) respects your privacy and is committed to protecting your personal data. This privacy notice aims to give you information on how Chiesi collects and processes your personal data.

  

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

 

Controller

Chiesi is the controller and is responsible for your personal data.

 

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

 

Contact details

Our full details are:

Full name of legal entity: Chiesi Limited

Name or title of DPO: Matt Wiggetts, Legal & Compliance Director

Email address: ukdpo@chiesi.com

Postal address: 333 Styal Road, Manchester M22 5LG

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 25 May 2018 and historic versions are archived and can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

A. HEALTHCARE PROFESSIONALS AND ATTENDEES AT OUR EVENTS

1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name and title.
  • Contact Data includes your practice address, email address and telephone numbers.
  • Financial Data includes details provided to us by you to facilitate the payment of certain fees, sponsorship, contributions and expenses. For example, if we pay for your associated travel and accommodation costs in order for you to attend one of our events.
  • Travel Data includes passport details and travel itineraries.
  • Engagement Data includes details of all our engagements with you including emails and notes of meetings/telephone calls.
  • Complaint Data includes details of a complaint made by you in relation to one of our products.
  • Pharmacovigilance Data includes details of adverse events which are reported to have arisen as a result of the use of our products. This may include reference to your patient and his/her medical condition.
  • Enquiry Data includes details of an enquiry made by you in relation to our products.
  • Usage Data includes details of how you use our products.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we will use it to monitor the quantity and frequency of company interactions with Healthcare Professionals. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

 

If you fail to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions . You may give us your Identity, Contact, Financial, Travel, Engagement, Complaint and/or Enquiry Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • Contact us regarding a general enquiry;
    • Contact us with a view to obtaining further medical information regarding our products;
    • Contact us to report an adverse event/side effect;
    • Contact us to report a complaint regarding our products;
    • Enter into an agreement with us to provide certain services to us including speaking at one of our events or take part in an advisory board; and
    • Speak with one of our sales representatives.

 

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Identity and Contact Data from data brokers or aggregators such as IQVIA Solutions UK Limited, based inside the EU.
    • Identity and Contact Data from publicly availably sources such as NHS Service Provider websites.

 

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To deal with an enquiry made by you in relation to our products

(a) Identity

(b) Contact

(c) Enquiry

(d) Usage

(a) Necessary for our legitimate interest in administering and responding to a request made by you for further information made in the context of an enquiry.

To deal with a complaint made by you in relation to our products.

(a) Identity

(b) Contact

(c) Complaint

(d) Usage

(a) Necessary for our legitimate interest in administering and responding to a request made by you for further information made in the context of an enquiry.

(b) Necessary for reasons of substantial public interest – to comply with our statutory obligation to deal with complaints made in respect of our products pursuant to an EC Directive (2001/83/EC).

To deal with a report made by you in respect of an adverse event caused by one of our products.

(a) Identity

(b) Contact

(c) Pharmacovigilance

(d) Usage

(a) Necessary for our legitimate interest in administering and investigating a report made in respect of adverse side effects which may have arisen as a result of the use of our product(s).

(b) Necessary for reasons of substantial public interest – to comply with our statutory obligation to deal with reports of adverse side effects which may have resulted from the use of our product(s) pursuant to an EC Directive (2001/83/EC).

To contact you about potential opportunities to work with us at future speaking events or sit on one of our advisory boards.

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (i.e. in providing you with potential opportunities to work with us).

To speak with you about potential products which might be of interest to you and your practice.

(a) Identity

(b) Contact

(c) Usage

(a) Necessary for our legitimate interests (i.e. contacting you about potential products we feel might be of interest to you and your practice.

Record and monitor our engagements with you in accordance with the ABPI code of practice as regulated by the PMCPA.

(a) Identity

(b) Contact

(c) Engagement Data

(a) Necessary for our legitimate interest (i.e. to comply with our obligations pursuant to the ABPI code of practice as regulated by the PMCPA).

To manage our relationship with you which will include notifying you about changes to our terms or privacy policy

(a) Identity

(b) Contact

(c) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To use data analytics to improve our, products, customer relationships and experiences.

(a) Technical

(b) Usage

(a) Necessary for our legitimate interests (i.e.to define types of customers for our products and services, to develop our business and to inform our marketing strategy).

To maintain a register of key opinion leaders who are deemed to be leaders in their field and who we may wish to contact for potential future engagements.

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (i.e. to keep up-to-date with those individuals who are deemed to be leaders in their respective fields and who we may wish to contact about future collaborative opportunities).

To arrange for travel and accommodation where you attend a conference organised by us, and/or where you are working with us as part of a speaking engagement or advisory board.

(a) Identity

(b) Contact

(c) Travel

(a) Necessary for the performance of our contract with you.

To arrange for payment of those sums agreed to be paid to you in accordance with your contractual engagement with us

(a) Identity

(b) Contact

(c) Finance

(a) Necessary for the performance of our contract with you in order to pay you.

Report details of fees paid to you for services rendered to us (e.g. speaking at one of our events or sitting on an advisory board) to the Association of British Pharmaceutical Industry who publish these details on their disclosure portal.

(a) Identity

(b) Contact

(c) Finance

(a) Consent – provided by you in the contract.

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

 

Promotional material from us

We may use your Identity, Contact and Usage to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us (or on our behalf using our third party event organisers) if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

B. PATIENTS

1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name, title, date of birth and gender.
  • Contact Data includes your address, email address and telephone numbers.
  • Medical Provider Data includes details of your GP and other health care professional who provides you with medical care.
  • Complaint Data includes details of a complaint made by you in relation to one of our products.
  • Pharmacovigilance Data includes details of adverse side effects which are reported to have arisen as a result of the use of our products. This may include reference to you and any details of your medical condition that you may provide to us.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may also collect, store and use the following "special categories" of more sensitive personal information:

  • Special Category Data Information about your health reported in the context of a complaint or a report of adverse events, including any medical condition which may be provided by you or your health care provider.

 

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions . You may provide us with those categories of personal data listed above, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • Contact us regarding a complaint about one of our products;
    • Contact us to report an adverse event/side effect; or
  • Third parties. We may receive personal data about you from your health care provider.

 

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To deal with a complaint made by you in respect of our product(s).

(a)Identity

(b)Contact

(c)Complaint

(d)Medical Provider Data

(e) Special

(a) Necessary for compliance with legal obligation to which Chiesi is subject – an EC Directive (2001/83/EC).

(b) Necessary for reasons of substantial public interest – in the exercise of a function conferred upon Chiesi - an EC Directive (2001/83/EC).

To deal with a report made by you in respect of an adverse side effect which may have resulted from your use of our product(s).

(f) Identity

(g)Contact

(h)Complaint

(i) Medical Provider Data

(j) Special

(c) Necessary for compliance with legal obligation to which Chiesi is subject – an EC Directive (2001/83/EC).

(d) Necessary for reasons of substantial public interest – in the exercise of a function conferred upon Chiesi - an EC Directive (2001/83/EC).

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

C. VISITORS TO OUR WEBSITE

1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name, title, date of birth and gender.
  • Contact Data includes your address, email address and telephone numbers.
  • Technical Data may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Enquiry Data includes details provided by you in the course of contacting us with an enquiry.
  • Usage Data includes information about how you use our website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions . You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • Contact us regarding a general enquiry; and
    • Contact us with a view to obtaining further medical information regarding our products.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy, below, for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties [as set out below:
    • Technical Data from analytics providers such as Google based outside the EU .

 

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To manage our relationship with you which will include notifying you about changes to our terms or privacy policy

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

 

Promotional offers from us

We may use your Identity, Contact, Technical and Usage to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

 

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Chiesi group of companies for marketing purposes.

 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

 

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy below.

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

D. EVERYONE

1.Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

2. International transfers

Although Chiesi is based in the UK, its parent company is based in Italy and we use suppliers from many parts of the world. As a result, the information we collect about you may on occasion be transferred to, stored and used at premises in other countries, including those which are outside of the European Economic Area, such as the US.

 

3. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

4. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

5. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are as follows:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

6. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

THIRD PARTIES

Internal Third Parties

Other companies in the Chiesi Group.

External Third Parties

 

FOR HEALTHCARE PROFESSIONALS AND ATTENDEES AT OUR EVENTS:

  • Service providers acting as processors based in the EEA who provide IT and system administration services, including the receipt of complaints on our behalf where such complaint is made outside of normal office hours.
  • Local manufacturers where it is necessary to inform the manufacture of a complaint reported in respect of our products.
  • The European Medicines Agency where we are required to report adverse events relating to our products.
  • Third parties responsible for reviewing and reporting on details relating to adverse events to determine the seriousness of such side effects.
  • Our third party marketing agency who is responsible for managing various events that we run (including registration of delegates, sending out communications and invitations on our behalf and arranging travel (where requested to do so by you)).

 

FOR PATIENTS

  • Service providers acting as processors based in the EEA who provide IT and system administration services, including the receipt of complaints on our behalf where such complaint is made outside of normal office hours.
  • Local manufacturers where it is necessary to inform the manufacture of a complaint reported in respect of our products.
  • The European Medicines Agency where we are required to report adverse events relating to our products.
  • Third parties responsible for reviewing and reporting on details relating to adverse events to determine the seriousness of such side effects

 

FOR VISITORS TO OUR WEBSITE

  • Service providers acting as processors based in the EEA who provide IT and system administration services.

 

COOKIE POLICY

What are cookies and why do we use them?

A cookie is a small text file of letters and numbers that we place on your computer or device when you use our website. We use cookies to distinguish you from other visitors and provide you with a good experience browsing our website.

What types of cookies do we use?

Some cookies only last until you close your browser or a short time. These are called session cookies. Some last longer, for example, to enable a website to recognise you when you return to it. These are called persistent cookies. We use both session and persistent cookies to ensure that you get the best experience when using our website.

We use several different types of cookies:

  • Strictly necessary cookies: these are cookies that are required for the operation of our website, enabling you to login and use the features of our website.
  • Performance cookies: these are cookies that allow us to recognise and count the number of visitors we have to our website and to see how they move around when they are using it. This data helps us to improve the way our website works, for example, by ensuring that visitors find what they are looking for easily.

In the table below we set out the individual cookies we use and why we use them:

 

Cookie name

Type of Cookie

What does it do?

PHPSESSID

first party, session, strictly necessary

Ensures that once you have logged in, you stay logged in throughout your session.

_utma

first party, persistent, performance

Used to distinguish users and sessions.

_utmb

first party, session, performance

Used to determine new sessions/visits.

_utmc

first party, session, performance

Operates in conjunction with the _utmb cookie to determine whether the user is in a new session/visit.

_utmv

first party, persistent, performance

Used to store visitor-level custom variable data.

_utmz

first party, persistent, performance

Used to identify and store the traffic source or campaign that explains how you reached our site.

 

How can you manage cookies?

There are various ways that you can control and manage your cookies, which are discussed in more detail below. Please remember that any settings you change will not just affect Chiesi cookies. These changes will apply to all websites that you visit (unless you choose to block cookies from particular sites).

Managing cookies in your browser

Most modern browsers will allow you to:

  • See what cookies you've got and delete them on an individual basis.
  • Block third party cookies.
  • Block cookies from particular sites.
  • Block all cookies from being set.
  • Delete all cookies when you close your browser.

You should be aware that any preferences will be lost if you delete cookies. Ironically, this includes where you have opted out from cookies, as this requires an opt-out cookie to be set. Also, if you block cookies completely many websites will not work properly and some functionality on these websites will not work at all.

If you are primarily concerned about third party cookies, you can turn these off separately. This is discussed in more detail below.

To manage or block cookies placed on your computer, mobile phone or tablet, you need to alter your browser or device settings. Please consult your browser's guide or visit www.allaboutcookies.org for more information or refer to your device user manual.

Our website is designed to use cookies, so if you choose not to allow any cookies at all, you may not be able to access or use all or parts of our site and the functionality may be affected.

 

Third parties

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be performance cookies or targeting cookies.

If you are concerned about cookies from third parties, you can often opt-out with the provider directly (such as with Google Analytics, please visit https://tools.google.com/dlpage/gaoptout ). Please note that these providers may use cookies to power their opt-out service, so if you change your browser settings to block all cookies, their opt-out service may cease to work.

 

Our recruitment website is managed by a third party called Talentia Software UK Ltd. They also use cookies to enable you to get the most from our recruitment website. You can find out more information about the cookies used by Talentia Software UK Ltd at https://talentia.chiesi.uk.com/hcmcv/CFLibrary/CFCookiePolicy.asp