Privacy Utenti Registrati

PRIVACY POLICY FOR REGISTERED USERS

DATA PROTECTION STATEMENT (for Healthcare Professionals - HCPs)

This statement describes which personal data are processed by Boehringer Ingelheim Italia S.p.A. (hereinafter, for the sake of brevity, “we”, “us” or “BI”) for which purposes – on this site and elsewhere, – if  you have contacts with us and our collaborators. It includes different types of processing performed by BI with regard to the personal data of Healthcare Professionals or other healthcare practitioners (HCPs) with whom BI interacts. Therefore, the specific type of processing and the relevant purpose depend on the type of relationship and/or interaction that you have with BI. In short:

  • We collect personal data when we provide you with services (e.g. contracts, responses to inquiries) or advice/detailing information about our products and information about BI’s therapeutic areas or initiatives or refresher materials, or if you visit our sites coming from search engines and public data bases.
  • We use personal data in order to provide you with these services, to give you advice/detailing information, to inform you according to your interests, preferences and wishes on the basis of the collected data, to fulfil our reporting obligations under the law and to enforce rights.
  • To this end, we also engage service providers and other Boehringer group companies that process the data for the purposes specified herein.
  • Your data protection rights: You may withdraw your consents at any time. You may also – at any time –exercise additional rights to have access to information, to object, to rectify data, etc., as better specified herein.
  1. WHAT KIND OF PERSONAL DATA DO WE COLLECT AND FOR WHICH PURPOSES DO WE USE THEM?
    1. Requested and agreed services: we collect your data in order to be able to provide you with the agreed or requested services, such as if you register on our sites or apps; if we enter into contracts with you for consultancy services, conferences or in other cases; if you take part in training courses or events; if you send us inquiries about products or possible side effects. More specifically, with reference to consultancy agreements and participation in training courses or events, we collect your data in order to:
  1. Make it possible to check your background and experience for the purpose of possibly engaging you and, in case, determining the engagement fee.
  2. Make it possible to manage the contractual relation, e.g. payment, invoicing and fulfilment of other contractual obligations.
  3. Enable monitoring, e.g. in order to fulfil legal obligations, such as obligations to assess our Business Partners’ compliance.
  4. Proceed with publication – with your consent – pursuant to Article 5 of Farmindustria’s Code of Conduct, which lays down that every pharmaceutical company shall publish the amount of the value transfers made during the previous year – on an individual basis for each recipient – with regard to:
    1. costs for participation in meetings and congresses in respect of participation fee, travel and accommodation (excluding meals and beverages);
    2. expenses for consultancy activities and professional services not falling within the activities set forth in letter i) above, as resulting from a specific contract between BI and the individual healthcare professional which specifies the type of service rendered.

The data will be published on the company website www.boehringer-ingelheim.it as provided for by Resolution No. 88 of 2 March 2011 issued by the Data Protection Authority on the non-availability of data through external search engines and the adoption of suitable measures to prevent mass duplication operations.

  1. With your consent, if appropriate, in order for Boehringer Ingelheim to disclose the results of the consultancy service (publication in journals, on the Internet, etc.) both internally and commercially.
  1. With your consent, in order to use and possibly disclose your name – along with your date of birth, speciality, if any, and a statement of compliance with the regulations in force concerning the obligation to disclose one’s sponsored participation in congress events to the respective healthcare facilities to which one is affiliated – to Farmindustria’s Control Committee, pursuant to Art. 3 of Farmindustria’s Code of Conduct.
    1. Your inquiries: When we contact you to provide you with advice or information, we also collect personal data in order to further adapt the information and advice to your preferences and wishes:
  1. If you send us inquiries about products or possible side effects.
  2. If you send us inquiries to improve your scientific knowledge about a therapeutic area and product, or concerning the provision of services (possibly also connected with the performance of detailing activities) which you requested (e.g. including through registration on our websites).
  3. In the case of physicians and pharmacists, after meetings or calls our sales reps take note of the topics you would like to have more information on and the topics you are less interested in. If our sales reps show you information on a tablet during calls, the tablet also stores which pages/pieces of information were displayed and for how long (you can always object to this to our sales rep).
  4. If you receive email newsletters (which are only sent with your prior consent), we store whether and when you opened them, which links you clicked on and when. You can object to this processing at any time, including to our sales reps.
  5. Our sales reps may also send communications to physicians and pharmacist via email, text messages, MMS or in paper format, with their prior consent.
  6. With your prior consent, you may receive operator calls, including to conduct marketing research.
  7. With your consent, by including your data into pre-defined group profiles (“clusters”), including in relation to the opinion you showed/expressed about BI’s products as part of your treatment choices, to your participation, if any, in clinical trials, and/or to your scientific publications, as well as to the preference you showed or expressed for the contents that BI may send you.
  8. We store the inquiries that you send us via email, sites or other channels.
    1. Data collected via BI’s websites: we collect your personal data if you register on our sites or apps or if you log into a personal area with specific contents reserved for you.
      1. Log data and website usage cookies: When using the website, certain data, including data sent by the browser (e.g. IP address, cookies, additional site, time and date, displayed contents) are temporarily stored. We use these data to enable you to use our site and, if necessary, to investigate incidents and assert rights in the event of damage or violations of legal provisions, our terms of use and the rights of third parties. This type of processing is aimed at fulfilling legal obligations and is based on the so-called balance of interest clause of the European General Data Protection Regulation.

As better stated in the relevant policy for the specific visited site, we use cookies and similar technologies, such as pixel tags, web beacons and clear GIFs (hereinafter referred to as “cookies”). We use cookies for technical reasons, such as to resume a user’s session when logging in if the previous session was interrupted due to inactivity. These cookies are not used to analyse the use of the site. This type of processing is aimed at fulfilling legal obligations and is based on the so-called balance of interest clause of the European General Data Protection Regulation

  1. Analytics: if envisaged for the specific visited site, and as better stated in the relevant policy, we also use cookies from Adobe Analytics, a web analytics service provided by Adobe Systems Software Ireland Limited (“Adobe”). Adobe Analytics uses Cookies on behalf of BI to analyse total traffic and usage patterns. The IP address recorded by cookies is anonymized before it is localised and is also replaced by a generic IP address. Adobe will not associate your IP address with any other information held by Adobe. You can prevent Adobe from collecting and using information (cookies and IP address) by setting the options about you on http://www.adobe.com/privacy/opt-out.html

Analytics help us improve our services by analysing which of our offerings are better accepted or less accepted, and are based on the so-called balance of interest clause of the European General Data Protection Regulation

  1. Usage data on sites, apps, webinars: if you have given your explicit consent, we store usage data when you visit our sites, apps or webinars as a registered user. Usage data are data generated when those services are visited: pages accessed, clicks, downloaded materials, as well as time and duration.

You may withdraw your consent at any time.

  1. Data from public sources and information obtained from third parties (for master data management and consultation): we collect your personal data when we retrieve personal data about healthcare professionals from public or external sources, in particular to check their professional qualifications and identity. The data also help us communicate with you and provide you with advice according to your interests and preferences:
    1. OneKey: in order to perform detailing activities and to provide you with advice and refresher materials, we keep your contact data (e.g. email address, telephone number) and the information about your specialities up-to-date using OneKeyTM, a data base managed by IQVIA Solutions Italy S.r.l., Via Fabio Filzi 29 Milan (hereinafter “IQVIA”) which contains contact data and information about the specialities of medical and other healthcare professionals that are constantly updated.
    2. Publicly available information sources (publications, websites, memberships): We collect publicly available data about your publications, your participation in seminars, your membership of scientific or professional associations, whether you manage a website and how it is designed.

Processing is performed on the basis of the so-called balance of interest clause of the European General Data Protection Regulation

  1. Request for samples: if appropriate, we collect your personal data in order to keep your requests for free samples of our products, in fulfilment of the provisions of Sect. 125 of Legislative Decree No. 219/2016; and/or in order to keep your requests for materials, if any (e.g. forms, donations of product kits, educational materials for patients, etc.).
  1. Risk prevention and controls: as a protection against the different threats to our IT systems – for example malware, hacker attacks and spam – and to protect our intellectual property rights, we use different procedures to continuously monitor exchanged information for viruses, and connection data for anomalies. In the presence of anomalies, the relevant documents and connection data can be analysed further. In order to comply with the existing trade and/or payment restrictions, for example with regard to companies and persons listed in different governmental lists, your data may be compared with these lists. Moreover, in case of whistleblowing reports, judicial or governmental investigations and to legally protect Boehringer Ingelheim, it may be necessary to conduct investigations and also to transmit documents and/or data, including your data concerning the case in point. In all these cases, we will comply with all our internal regulations, the rules in force and the rights of the persons concerned.

 

  1. LEGAL BASIS

Processing of your personal data is necessary for the purposes listed above. The legal basis for processing, as applicable to the individual types of processing, is Article 6 (1) b) GDPR (performance of a contract) for the types of processing referred to in Article 4, Article 6 c) (legal obligation to which the controller is subject), Article 6 (1) f) GDPR (legitimate interest) or Article 6 (a) GDPR if you have given your consent.

 

 

  1. WHOM DO WE TRANSFER PERSONAL DATA TO?

We may share personal information with third parties in the following cases.

  1. Reporting obligations to regulatory authorities and enforcement of rights. As a pharmaceutical company, Boehringer Ingelheim is subject to specific healthcare regulations, such as those concerning pharmacovigilance. Some of these laws require us to send the reports received from users to regulators or  other authorities worldwide (including countries that may have a different level of data protection than the EU). We only provide authorities with personal data if we are legally obliged to do so.

In order to protect our rights or the rights of third parties, we may also disclose data to right holders, consultants and authorities in accordance with legal provisions.

  1. Service providers. We engage service providers to process your personal data for the purposes described in this data protection statement. These service providers process the data only on our behalf, in accordance with our instructions and under our control.
  1. Boehringer group companies. As part of a global group, we involve other Boehringer group companies that support us in data processing. These group companies process the data exclusively for the purposes stated in this privacy policy.
  1. OneKey. If we receive personal data about healthcare professionals who are not present in OneKey, or personal information which is different from that appearing in OneKey, we will inform IQVIA. After validation by IQVIA, these data will be made available to other companies with which IQVIA collaborates.
  1. Data transfer to recipients outside the EU. Some of these service providers and Boehringer group companies process personal data outside the EU. In these cases, Boehringer Ingelheim ensures an adequate level of protection to comply with European law (usually through the standard contractual clauses published by the European Commission).

 

  1. HOW LONG DO WE KEEP PERSONAL DATA?

We will keep personal information for as long as necessary for the particular purpose(s) for which it has been collected, also considering the retention period provided for by law, where applicable, as well as operational requirements or business practices.

You may exercise the rights referred to in point V below at any time, requesting the erasure of data or withdrawal of consent, subject to the retention obligations provided for by law.

 

 

  1. WHAT ARE YOUR RIGHTS?

You can request information on which personal data are stored. If you have provided personal data based on a contract or consent, you have the right to receive these data in a common and machine-readable format.

If provided for, you may also request the erasure, correction or limitation of the processing of your data. If your personal data are transferred to a country outside the EU that does not provide adequate protection, you may request a copy of the contract that provides adequate protection of personal data. If you gave your consent for the use of your personal data, you can withdraw your consent at any time with future effect.

If we use your personal data on the basis of a legitimate interest, you can object to the use of your data. In this case, we will no longer use your data unless our interests prevail. You can object to the use of your data for direct marketing purposes, e.g. the receipt of mailings, at any time without further consideration.

You also have the right to file a complaint with the relevant supervisory authority.

If you have any questions about our use of personal data or this statement or if you would like to exercise your rights, you can contact the Controller at any time by writing to Boehringer Ingelheim Italia S.p.A., Via Lorenzini n. 8 20139 Milan or you can contact the Data Protection Officer directly as follows: Ufficio del Responsabile della Protezione dei Dati/Data Protection Officer

Boehringer Ingelheim Italia S.p.A.

Via Lorenzini 8 20139 Milano

Tel: 0253551

Email dataprotectionofficer.it@boehringer-ingelheim.com

 

 

  1. WHAT WILL HAPPEN IF WE AMEND THIS PRIVACY POLICY?

We will update this privacy policy from time to time. We will inform you about any amendments to our Privacy Policy by publishing the new Privacy Policy here. If necessary, we will also ask you to give your prior consent. You should periodically review this Privacy Policy to check if it has been amended.

 

 

  1. ADDITIONAL INFORMATION ABOUT PERSONAL DATA PROCESSING

Please note that, in certain situations (e.g. in clinical trial agreements), additional privacy policies may apply.

 

Last updated in: September 2018

 

Boehringer Ingelheim

© 2019 BOEHRINGER INGELHEIM ITALIA S.p.A. A single-member company with registered office at Via Lorenzini 8, Milan, Fully paid-up share capital: 24,260,040.00 Euro, Tax Code, registration number in the Milan Trade Register and VAT Registration Number: 00421210485, No. 1370160 in the List of Business and Administrative Information of Milan. Certified email: bitspa@legalmail.it 

A company subject to management and coordination by C.H. Boehringer Sohn.