Customer Relationship Management Privacy Notice

At Ferring, your privacy is important to us and we are committed to ensuring our data protection practices adhere to applicable European and local national data protection regulations.

This Privacy Notice will provide information as to how Ferring may collect, hold and process your personal data in this context, and will describe the ways in which we will ensure your personal data is protected in accordance with the applicable regulations.

This Privacy Notice applies only to this process, therefore if you visit another website related to or recommended by Ferring or else enter into a business relationship with Ferring of a different nature, please consult the privacy notice on the respective website or as otherwise provided by Ferring in that context.

This Customer Management Privacy Notice describes our practices in connection with information that we or our service providers collect through the website, paper forms or applications operated by our sales representatives and controlled by us from which you are accessing this Privacy Notice.

The controller of your personal data is Ferring Sdn Bhd (977595-w), 21-6, Block B, Jaya One, No. 72-A, Jalan Universiti, 46200 Petaling Jaya, Selangor, Malaysia

What is personal data?

Personal data means all information that relates to an identified or identifiable individual. This may include name, postal address, phone number, email address, GMC or practice number.

What categories of personal data does Ferring process in the context of the Customer Relationship Management system?

Ferring may collect and use the following categories of personal data in this context for the purposes described below:

• data such as your name, age, gender and contact details;
• professional data such as your workplace, position, the medical field in which you are active, your professional qualifications, and scientific activities (such as previous clinical trials and participation in previous or ongoing studies at Ferring and others), publication of academic or scientific research and articles and membership of associations and boards;
• financial details such as payment details, including tax identification number; and
• details of the interactions with us, such as topics discussed, your knowledge of and questions you have had about our company and our products, what kind of material we have shown you and what feedback you have given, as well as your views and routines about prescribing, routines related to your patients and diagnosis, and similar data.

From what sources does Ferring collect your personal information?

The data described above is provided either directly by you (on our website, paper form, email, or to our sales representatives to Ferring) or indirectly via companies that have organised activities sponsored or supported by Ferring, such as clinical research, and development activities; public sources, recruitment agencies, interim offices, and third parties, such as IQVIA;

For what purposes does Ferring process your personal data?

Ferring processes your personal data for the following purposes:

• Improving your customer experience;
• Product improvement and innovation;
• Management of the business relationship; and
• PR and marketing.

Ferring relies on your consent for processing your personal data. However, in certain cases Ferring may rely on different grounds for processing your personal data, such as legitimate interests, in line with applicable law.

With whom and how does Ferring share my personal data?

Your personal data may be transferred to other locations in which Ferring maintain facilities (including Ferring affiliates, contractors, partners or agents), where there are legitimate grounds for such a transfer, such as a valid business reason. Such locations may include countries outside the European Economic Area (EEA). Any such transfers will be safeguarded by internal international data transfer agreements, to ensure that your personal data is protected in accordance with the applicable European and national data protection laws.

Ferring may, in certain circumstances, share your personal data with third parties, such as vendors, contractors, partners or agents, if necessary to achieve the notified purposes, or if such third parties are assisting Ferring with the processing of the data. Ferring will only disclose personal data about you to a third party in the following circumstances:

• Relevant consent has been provided by you;
• where applicable, as a result of a request by you as a data subject
• whereby there is a legal basis for the disclosure of the data and you have been provided with suitable notice of this
• where we are required to do so under applicable laws or as a result of a court order; or
• where Ferring decides to sell, buy, merge or otherwise reorganise its business structure.

Ferring will never sell your information to a third party.

We may transfer your personal data to the following categories of recipients:

• to the companies within our group,
• to external service providers and partners who provide data processing services on our behalf, such as email service providers, hosting, transport, etc.
• to any competent supervisory or regulatory authority, public authority, court or other third party where we believe that disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to protect our legal rights (iii) to protect your vital interests or those of any other person;
• to any other person with your consent to the communication.

Storage Restriction

We will retain the personal information we collect for a maximum period of 10 years after termination of our business relationship so that Ferring can comply with its legal obligations.

Your data protection rights

You have the following data protection rights:

• You have the right to access your data,
• You have the right to rectify, update or delete your data,
• You can object to the processing of your data.
• You can ask us to limit the processing of your data.
• You can ask for the portability of your data.
• You have the right to complain to a data protection authority about the collection and use of your personal data

You can exercise these rights by contacting Ferring at in DATA SUBJECT CONTACT FORM. In addition, you can always unsubscribe from direct marketing by clicking on the “unsubscribe” or “opt-out” link in the emails we send you.

• You have the right to unsubscribe at any time from marketing communications that we send you.
• If we have collected and processed your data with your consent, you can withdraw your consent at any time. Withdrawal your consent does not affect the lawfulness of the processing that we have carried out prior to your withdrawal, nor does it affect the processing of your data based on other processing grounds.

You can unsubscribe from physical forms of marketing (such as post-marketing or telemarketing), via my_enquiries@ferring.com or by contacting us on our behalf postal address.

Please also note that if you opt out of receiving marketing related messages from us, we may still send you important transactional and administrative messages in line with applicable law.

Cookies

In case you used the dedicated website, data about your use of the website may be collected using Google Analytics when visiting the Ferring website dedicated to consent management. This tracking technology uses cookies to collect aggregate data about website usage and activity, such as how many users visit the website and how often. This data may be shared with a third-party service provider in order to further improve our web services. No personal data can be accessed or collected via these cookies. The use of this type of technology shall comply with applicable data protection regulations and the current E-Privacy Regulation. We may also, collect information via:

Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, and Internet browser type and version. We may collect similar information, such as your device type and identifier, if you access the Service through a mobile device. We use this information to ensure that the Service functions properly.

Device Information: We may collect information about your mobile device, such as a unique device identifier, to understand how you use the Service

Security information

Ferring maintains appropriate technical and organizational security measures to safeguard your personal data from unauthorized access, use, disclosure, accidental destruction or loss. For example, where appropriate, Ferring is committed to the encryption, anonymization or pseudonymization of personal data, and personal data will be stored securely in a designated system. Our internal policies and procedures are designed to prioritise and promote the protection of personal data.

While our data security measures are continually evaluated and updated, the security of data transferred via the internet from a computer or other device cannot be guaranteed and you are encouraged to take steps to protect yourself online and against unauthorized use of your passwords, and mobile devices, as well as installing the appropriate firewall, anti-virus and anti-spyware protections for your computer.

A non-exhaustive list of possible data incidents may include,

• a lost/stolen laptop
• an external hacker
• an email containing personal data sent in error
• information lost in transit
• documents left in unsecured location.

If you suspect any security compromise or detect vulnerabilities, it is essential to report these data incidents immediately by using the Data Subject Contact Form.

Children

The Service is not directed to individuals under the age of 18, and we request that these individuals not provide personal information through the Service. If your child has submitted Personal Information and you would like to request that such Personal Information be removed, please contact us as explained below under Contact Us.

Modifications

Any changes to this Privacy Notice will be communicated at this location https://crm.ferring.info/privacy/my/. We recommend you consult our Privacy Notice when revisiting our website to review any changes and to keep informed about our ongoing commitment to respecting the right to privacy and to providing the highest possible level of data protection.

Contact information

If you have any questions or comments question regarding this Privacy Notice, please contact Ferring via my_enquiries@ferring.com.

You can always unsubscribe from direct marketing by clicking on the “unsubscribe” or “opt-out” (hyper link to preference page) link in the confirmation emails we send you or contact us at the following address:

Ferring Sdn. Bhd. (977595-w)
21-6, Block B, Jaya One, No. 72-A, Jalan Universiti,
46200 Petaling Jaya, Selangor,
Malaysia
Tel: +603-7960 3032

Please note you can opt out only for those service and communication you have consented to.

In addition, you can exercise these rights by contacting Ferring via
DATA SUBJECT CONTACT FORM
Alternatively, mail us to the following address:
(Att.: Data Protection Officer)
Ferring International Center S.A.
Chemin De la Vergognausaz 50
1162 St Prex
Switzerland

This Privacy Notice was last updated on 02/07/2020.