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1. WHO WE ARE AND HOW YOU CAN CONTACT US
UCB or "we" means UCB Australia Pty Ltd, Level 1, 1155 Malvern Road, Malvern VIC Australia 3144.
As the controller, i.e. the legal entity that decides on the why and how information relating to you (personal data) is collected and processed in the context of this UCB Cares for Immunology website, available at www.UCBCaresforImmunology.com.au (the Website), we respect your right to privacy. This Privacy Policy (“Policy”) applies to all webpages which form part of the Website.
We will only process your personal data as described in this Privacy Policy for UCBCares for Immunology Website (the Policy) and in accordance with the relevant data protection legislation, including Australian Privacy Act 1988 (Cth), including the Australian Privacy Principles, as well as Medicines Australia Code of Conduct.
At UCB we have a data privacy officer (DPO), who can be contacted by any of the following means for any privacy-related questions, including regarding how we collect, store and use your personal data:
- E-mail: dataprivacy.au@ucb.com; or
- Regular mail: UCB Australia, Level 1, 1155 Malvern Road, Malvern Victoria 3144 (attention : Data Privacy Officer)
2. THE REASON BEHIND THIS PRIVACY POLICY
The Policy governs the collection, use and retention by UCB of personal data relating to your use of the Website. This Policy applies to all Website users.
The Policy consists of five main components and informs you about:
1. Who we are and how you can contact us;
2. The reason behind this Policy;
3. The purposes for which we process your personal data, applicable retention periods and the related legal basis under the relevant data protection legislation;
4. What your rights are in relation to the personal data we hold about you and how you can exercise them; and
5. Further details on how we process (including transfer) your personal data.
This Policy may be updated periodically to reflect changes in our personal data processing practices. In that case we will post a prominent notice on the Website to inform you of any significant changes.
3. THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA AND APPLICABLE LEGAL BASIS
At UCB we have a UCB General Privacy Policy for Healthcare Professionals (or UGPPH), accessible at https://www.ucb.com/Privacy-policy-for-Healthcare-Professionals. The UGPPH describes UCB’s global policy in relation to the personal data processing activities which generally apply (i) to all healthcare professionals (HCPs) we have a professional relationship with; as well as (ii) to HCPs acting as a representative or contact person for a healthcare organization we have a professional relationship with. In addition to the processing activities explained in the UGPPH, UCB collects and processes the following personal data regarding you within the framework of your use of the Website.
In other words, please carefully read through both the UGPPH and this Policy to understand how we collect and process personal data concerning you. The table below indicates per purpose (i) the categories of personal data we collect and process concerning you, (ii) the source, (iii) how long we retain your personal data, (iv) who we share it with, and (v) the relevant legal basis under GDPR.
| ALL WEBSITE USERS | |
| 1. In order to make the Website and its content available to you, UCB: | |
| Collects the following personal data about you: | 1. Electronic identification data (*) 2. Information collected through cookies (*) Failure to provide the personal data with an (*) may result in (some features of) the Website not being accessible. |
| Receives this personal data from: | You, through the device(s) you use to access the Website |
| Retains (**) your personal data for: | For cookies, see our Cookie Policy |
Shares your personal data with:
| UCB affiliates and third party processors (as detailed in Section 5.A) |
| Relies on the following legal basis: | 1. Processing necessary for performance of a contract with you 2. For those cookies that require your consent, processing based on your consent (see Cookie Policy for more information) |
2. In order to enable:
we use cookies (combined with other information as outlined below) that allow us to evaluate - on an aggregate level - use made of our Website and how users (including yourself) access different features of our Website. In that context, UCB: | |
| Collects the following personal data about you: | 1. Electronic identification data (*) 2. Information collected through cookies (*) Failure to provide the personal data with an (*) may result in (some features of) the Website not being accessible |
| Receives this personal data from: | You, through the device(s) you use to access the Website |
| Retains (**) your personal data for: | For cookies, see our Cookie Policy |
| Shares your personal data with: | UCB affiliates and third party processors (as detailed in Section 5.A) |
| Relies on the following legal basis: | For those cookies that require your consent, processing based on your consent (see Cookie Policy for more information) Otherwise, processing necessary for the purpose of the legitimate interests pursued by UCB to conduct its business and to improve its product and service offering. To this end, UCB strives to maintain a fair balance between its need to process your personal data and the preservation of your rights and freedoms, including the protection of your privacy. For more information or if you have any questions regarding how we assess this balance, please contact us through any one of the channels set out under Section 1 - “Who we are and how you can contact us” |
| 3. In order to maintain Website security (including the detection and prevention of malicious activities or invalid traffic on the Website), UCB: | |
| Collects the following personal data about you: | 1. Electronic identification data (*) 2. Information collected through logfiles (*) Failure to provide the personal data with an (*) may result in (some features of) the Website not being accessible |
| Receives this personal data from: | You, through the device(s) you use to access the Website |
| Retains (**) your personal data for: | See our Cookie Policy |
| Shares your personal data with: | UCB affiliates and third party processors (as detailed in Section 5.A) |
| Relies on the following GDPR legal basis: | For those cookies that require your consent, processing based on your consent (see Cookie Policy for more information). Otherwise, processing necessary for the purpose of the legitimate interests pursued by UCB to protect its IT infrastructure and maintain the security of its business assets. To this end, UCB strives to maintain a fair balance between its need to process your personal data and the preservation of your rights and freedoms, including the protection of your privacy. For more information or if you have any questions regarding how we assess this balance, please contact us through any one of the channels set out under Section 1 - “Who we are and how you can contact us” |
| 4. In order to enable UCB to comply with its legal (including but not limited to pharmacovigilance) obligations, UCB: | |
| Collects the following personal data about you: | Any legally required information that have been disclosed as part of or within the framework of the other processing activities in this table (*) Failure to provide the personal data with an (*) may prevent UCB from complying with its obligations in accordance with applicable laws |
| Receives this personal data from: | You |
| Retains (**) your personal data for: | For as long as is legally required under applicable law |
| Shares your personal data with: | 1. Relevant regulatory and government agencies 2. UCB affiliates and third party processors (as detailed in Section 5.A) |
| Relies on the following legal basis: | Processing necessary for compliance with our legal obligations (including but not limited to pharmacovigilance/ adverse event reporting legislation); Processing necessary for the performance of a task carried out in the public interest, as pharmacovigilance is a key public health function (i.e. monitoring the safety of medicines, reducing the risks and increasing the benefits of medicines); For health data or other special categories of personal data, the aforementioned legal basis will be coupled with processing necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of Union or Member State law; . Should you raise an adverse event to a UCB product, we will need to report it even if it has already been reported by you directly to the company or to the Australian Regulatory Authority (TGA) using the 'Blue Card' Reporting form. UCB Australia’s Patient Safety group may follow up with you to obtain further information regarding the adverse event / product quality complaint, if required and if you have provided your contact details. You can also report an adverse event or product quality complaint to a UCB product by contacting UCB Australia Patient Safety via (03) 9828 1800 option 3 or via ds.au@ucb.com. |
| 5. In order to enable UCB to respond to your online queries submitted via your UCB contact’s email address and/or the UCBCares email address: | |
| Collects the following personal data about you: | 1. E-mail address (*) 2. Any other information you include in the email (*) Failure to provide, where required, the personal data with an (*) may prevent UCB from adequately responding to your query or request
|
| Receives this personal data from: | You |
| Retains (**) your personal data for: | A maximum duration of one year |
| Shares your personal data with: | UCB affiliates and third party processors (as detailed in Section 5.A) |
| Relies on the following legal basis: | 1. Processing necessary for performance of a contract with you 2. Processing based on your consent for any sensitive personal data you provide 3. For the applicable legal basis for processing adverse event related information see our explanation under the previous purpose in this table (“In order to enable UCB to comply with its legal (including but not limited to pharmacovigilance) obligations”) For more information on the processing of personal data by UCB within the framework of adverse event reporting, please check UCB’s Patient Safety Reporting Privacy Notice |
| 6. In order to enable UCB to respond to your online queries submitted via the “Ask the Expert UCB webform”: | |
| Collects the following personal data about you: | 1. Personal details you provide:
2. Disease area of interest as selected from a drop down menu (*) 3. Any other information you submit in the free text question field (*) Failure to provide, where required, the personal data with an (*) may prevent UCB from adequately responding to your query or request |
| Receives this personal data from: | You |
| Retains (**) your personal data for: | Your data is deleted once we have responded to your request |
| Shares your personal data with: | UCB affiliates and third party processors (as detailed in Section 5.A) |
| Relies on the following legal basis: | 1. Processing necessary for performance of a contract with you 2. Processing based on your consent for any sensitive personal data you provide |
| 7. In order to enable UCB to process your registration requests for UCB events: | |
| Collects the following personal data about you: | Personal details you provide:
Failure to provide, where required, the personal data with an (*) may prevent UCB from adequately responding to your query or request |
| Receives this personal data from: | You |
| Retains (**) your personal data for: | 60months |
| Shares your personal data with: | UCB affiliates and third party processors (as detailed in Section 5.A) |
| Relies on the following legal basis: | Processing necessary for performance of a contract with you |
(**) We will retain your personal data in accordance with the retention periods set out in the table above. These retention periods, included in our data retention policy, are dictated by:
- applicable statutory/legal requirements;
- industry guidelines, and
- for those data categories for which no express statutory or legal requirements apply, certain other determining factors such as the need to prove or enforce a transaction or contract, enforce our policies, etc.
We will delete your personal data once the abovementioned retention periods will have expired or if you object to or withdraw your consent to our processing of your personal data (to the extent such processing is based on your consent), except where we need to hold on to such data for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person, for compliance a legal obligation which requires such further processing or where we need to prove or enforce a transaction or contract or enforce our policies.
4. YOUR RIGHTS AND HOW YOU CAN EXERCISE THEM
A. 4.A. Your rights
Right to access
You have the right to obtain confirmation from us as to whether or not we process personal data concerning you, and if so, the right to obtain a copy of your personal data from us, as far as this does not adversely affects the rights and freedoms of others or there is another reason for us to refuse such access (for example, if providing access would pose a serious threat to the life or health and safety of another person, or if we consider your request to be frivolous or vexatious). If we refuse your request for access, we will provide you with a written explanation. For more information, please check Section 4.B “How to exercise your rights”.
Right to rectification
You have the right to ask us to rectify without undue delay any inaccurate personal data concerning you. You can also ask us to complete incomplete personal data regarding you by providing us with a supplementary statement containing such additional information. We will consider your request and take reasonable steps to rectify the issue, unless there is another reason for us to refuse to do so. If we refuse your request, we will provide you with a written explanation. For more information, please check Section 4.B “How to exercise your rights”.
Right to withdraw consent
Where UCB’s collection, use or the processing of your personal data is based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. For more information, please check Section 4.B “How to exercise your rights”.
4.B. How to exercise your rights
If you wish to exercise any of the rights mentioned above or to ask questions or make a complaint in relation to our management of your personal data, please contact UCB’s Data Privacy Officer by:
- e-mail: dataprivacy.au@ucb.com
- post: “To the attention of Data Privacy Officer” UCB Australia Pty Ltd, Level 1, 1155 Malvern Road, Malvern VIC Australia 3144
Please clearly identify the right(s) you wish to exercise and include your contact details (including a valid e-mail or postal address) so that we can respond to your request. Please note that you may be asked to provide proof of your identity.
We will respond to your request within one month following receipt of the request. This period may be extended by two additional months where necessary, but in that case we will inform you of any such extension within one month of receipt of your initial request together with the reasons for the delay. If you have made a complaint, the Data Privacy Officer or their representative will contact you to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.
5. MORE DETAILS ON HOW WE PROCESS YOUR PERSONAL DATA
5.A. Who we share your personal data with.
Principle
We will disclose your personal data only as described in this Policy (as further detailed above), as may be updated from time-to-time.
UCB affiliates and third party processors
UCB transfers or discloses your personal data to its personnel, affiliates and to third party service providers processing personal data on UCB’s behalf for the purposes set out above.
Third party service providers including IT services and website hosting companies, (internet) connectivity providers, provider of data analytics (Google) and tracking services, as well as service providers that provide technical and administrative support for the Website and underlying IT systems. These service providers provide their services from locations within the EU (including Germany, Malta, UK and Ireland) and outside of the EU (USA, Chile, Taiwan, Singapore).
Other third parties include regulatory and government agencies (see further below in this Policy), and potentially, third parties with whom UCB may merge or which may be acquired by UCB (see further below in this Policy).
Compliance with laws and legal proceedings
UCB will disclose your personal data where:
UCB is required to do so by applicable law, by a governmental body or by a law enforcement agency;
To establish or exercise our legal rights or defend against legal claims;
To investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies or as otherwise required by law.
Other
If a third party acquires all (or substantially all) of our business and/or assets, we will disclose your personal data to that third party in connection with the acquisition. However, such disclosure will occur subject to and in accordance with applicable data protection laws, including the GDPR.
5.B. International transfers
The transfer of your personal data to third party service providers (as set out above under Section 5.A) in countries outside of the EEA that do not ensure an adequate level of (data) protection occurs on the basis of Standard Contractual Clauses that have been executed between UCB and the relevant third-party service provider.
You may - by exercising your rights set out below above under Section 4.B (“How to exercise your rights”) - obtain a copy of the relevant safeguard UCB has put in place or ask UCB to redirect you to the place where they have been made available.
In the absence of the aforementioned appropriate safeguards, UCB may – to the extent permitted under and in accordance with applicable data protection laws (including the GDPR) - rely on a derogation applicable to the specific situation at hand (e.g. the data subjects’ explicit consent, the necessity for the performance of an agreement, the necessity for the establishment, exercise or defense of legal claims).
For more information on how Google processes your personal data within the framework of Google Analytics, please consult How Google uses data when you use our partners' sites or apps
5.C. Links to third party sites
This Website may contain links to other websites operated by third parties, including but not limited to patient organization, medical/scientific congress and other information resources (e.g. certain social media sites such as Vimeo etc.) This Policy does not apply to any website, other than this one. Third party websites are governed by their own terms and conditions. You should therefore always carefully check the privacy and cookie policies of third-party websites before accepting to be redirected to them.
AU-BK-2100012 October 2021