Privacy policy

This Notice is issued by each of the Controller entities listed in Section (Q) below (together, “Norgine“, “we“, “us” and “our“) and is addressed to individuals outside our organisation with whom we interact, including patients, visitors to our Sites, other users of our products or services, (personnel of corporate) customers, partners and vendors, applicants for employment, and visitors to our premises (together, “you“). Defined terms used in this Notice are explained in Section (R) below.

This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. Where necessary, we will inform you about any changes we might make in accordance with the terms of this Notice.

This Notice was last updated on 24 July 2023.

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:

• Data provided to us: We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application, or when you provide information to our sales representatives).
• Data we obtain in person: We obtain Personal Data during meetings, during visits from sales or marketing representatives, or at events we attend.
• Collaborations: We obtain Personal Data when you collaborate with us in research or in an advisory/consultancy capacity.
• Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you, or to your employer).
• Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from scientific publications, national registries, and your social media profile(s), if you make a public post about us).
• Site data: We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
• Registration: We collect or obtain Personal Data when you use, or register to use, any of our Sites, products, or services.
• Third-party databases: We collect or obtain Personal Data via third party databases we have contracts with (e.g., IMS or IQVIA).
• Content and advertising information: If you interact with any third-party content or advertising on a Site (including cookies) we receive Personal Data from the relevant third-party provider of that content or advertising.
• Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us, as far as deletion periods do not contradict this procedure. We may also combine Personal Data from any of our Sites, products, or services, including where those data are collected from different devices.

We Process the following categories of Personal Data about you:

• Personal details: given name(s); preferred name; and photograph.
• Contact details: correspondence address; shipping address; telephone number; email address; details of personal assistants, where applicable.
• Professional details: your CV; records of your expertise; professional history; practising details and qualification details; information about your experience; participation in meetings, seminars, advisory boards and conferences; information about your professional relationship with other individuals or institutions; language abilities; and other professional skills.
• Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
• Visitor logs: records of visits to our premises.
• Consent records: records of any consents you have given, together with the date and time, means of consent, and any related information (e.g., the subject matter of the consent).
• Purchase details: records of purchases and prices; and consignee name, address, contact telephone number and email address.
• Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.
• Data relating to our Sites: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; registration details; username; password; security login details; usage data; unique identifiers; access rights; and aggregate statistical information.
• Employer details: where you interact with us in your capacity as an employee of a third party; and the name, address, telephone number and email address of your employer, to the extent relevant.
• Content and advertising data: records of your interactions with our online advertising content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
• Views, feedback, and opinions: any views, feedback, survey responses and opinions that you share with us or publicly post about.
• Product use details: when you report a possible adverse event, and/or a medical information query or quality complaint, associated with one of our products.

Where it becomes necessary to process your Sensitive Personal Data for any reason, we rely on one of the following legal bases (as set out in Article 9 of the GDPR / UK GDPR):

1. you have given explicit consent to the Processing of your Sensitive Personal Data for one or more specified purposes, in accordance with applicable law;
2. Processing is necessary for the purposes of carrying out the obligations and exercising specific rights in the field of employment and social security and social protection law in so far as it is authorised by applicable law or a collective agreement pursuant to applicable law providing for appropriate safeguards for your fundamental rights and interests;
3. Processing is necessary to protect your vital interests or of another natural person where you are physically or legally incapable of giving consent;
4. Processing relates to Personal Data which you have manifestly made public;
5. Processing is necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity;
6. Processing is necessary for reasons of substantial public interest, on the basis of applicable law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard your fundamental rights and interests;
7. Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of applicable law or pursuant to contract with a health professional and subject to the relevant conditions and safeguards provided in applicable law;
8. Processing is 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 applicable law which provides for suitable and specific measures to safeguard your rights and freedoms, in particular professional secrecy;
9. Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with applicable law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard your fundamental rights and interests.

The purposes for which we Process the categories of Personal Data identified in Section (D) above, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

We disclose Personal Data to other entities within the Norgine group and to our business partners (licensing partners and distributors), for legitimate business purposes and the operation of our Sites, products, or services to you, in accordance with applicable law. In addition, we disclose Personal Data to:

• you and, where appropriate, your appointed representatives;
• legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
• accountants, auditors, consultants, lawyers and other outside professional advisors to Norgine subject to binding contractual obligations of confidentiality, e.g. external Data Protection Officer, law firm First Privacy;
• third party Processors (such as clinical trial-related service providers; payment services providers; shipping companies; Web service providers etc., e.g. Amazon Web Services, Google Analytics, Microsoft Azure), located anywhere in the world, subject to the requirements noted below in this Section (G);
• any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;
• any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
• any relevant third-party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
• any relevant third-party provider, where our Sites use third party advertising or content. If you choose to interact with any such advertising or content, your Personal Data may be shared with the relevant third-party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

Because of the international nature of our business, we transfer Personal Data within the Norgine group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Notice. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located For example, we could transfer your data to European Member States (Austria, Germany, France, Belgium, Spain, Italy, Portugal, the Netherlands, Finland, Sweden), countries in the EEA (e.g. Norway, Switzerland), as well as countries outside the EEA that do not provide an adequate level of protection for your personal data (e.g. India). Non-EU countries include the United States, India, Australia and New Zealand.

If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where no exemption or derogation applies, and we transfer your Personal Data from the UK or the EEA to recipients located outside the UK or the EEA (as applicable) who are not in Adequate Jurisdictions, we do so on the basis of the latest valid version of the European Commission’s Standard Contractual Clauses or the UK equivalent (i.e., the UK International Data Transfer Agreement / UK addendum to the Standard Contractual Clauses), as applicable. You are entitled to request a copy of our template Standard Contractual Clauses or the UK equivalent (i.e., the UK International Data Transfer Agreement / UK addendum to the Standard Contractual Clauses), as applicable, using the contact details provided in Section (Q) below.

We have implemented appropriate technical and organisational security measures (such as end-to-end encryption, pentesting, incident response management, malware alerts and remediation actions) designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the Internet is an open system, the transmission of information via the Internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the “open” Internet. As such, any such transmission via the open channels of the Internet is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely. It is recommended that if there is the risk identified to the transmission of data, protective measures such as encryption are used in line with commonly used methods.

We take every reasonable step to ensure that:

• your Personal Data that we Process are accurate and, where necessary, kept up-to-date; and
• any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:

(1) we will retain Personal Data in a form that permits identification only for as long as:

  (a) we maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed); or

  (b) your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between us and your employer, and we have a legitimate interest in Processing those Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),

plus:

(2) the duration of:

  (a) any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and

  (b) an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),

and:

(3) in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

 • permanently delete or destroy the relevant Personal Data; or

 • anonymize the relevant Personal Data.

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

• the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, products, or services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
• the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
• the right to request rectification of any inaccuracies in your Relevant Personal Data;
• the right to request, on legitimate grounds:
  • erasure of your Relevant Personal Data; or
  • restriction of Processing of your Relevant Personal Data;
• the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
• where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
• the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (i.e., in relation to the UK, the Information Commissioner’s Office (https://ico.org.uk/) or in relation to the EU, the Data Protection Authority for EU Member State in which you live, or in which you work, or in which the alleged infringement occurred (see the list here: https://edpb.europa.eu/about-edpb/about-edpb/members_en)).

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (Q) below. Please note that:

• in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and
• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

When you visit a Site we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We Process Personal Data through Cookies and similar technologies, in accordance with our Cookie Policies.

All use of our Sites, products, or services is subject to our Terms of Use. We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, products, or services that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Sites, products, or services. If we provide Sites, products, or services to you, we may send or display information to you regarding our Sites, products, or services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send. Please note that it may take up to 4 weeks to process your unsubscribe request during which time you may continue to receive communications from us. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, products, or services you have requested.

For the purposes of this Notice, the relevant Controllers are:

Alternatively, you may contact us using our online contact us form or contact our Data Protection Officer (First Privacy GmbH) at:

Address: First Privacy GmbH, Konsul-Smidt-Straße 88, 28217 Bremen, Germany

Tel: (+49) 0421 696632-0

Fax: (+49) 0421 696632-11

Email: office@first-privacy.com

• “Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.

• “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.

• “Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

• “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

• “EEA” means the European Economic Area.

• “GDPR” means the General Data Protection Regulation (EU) 2016/679.

• “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

• “Process“, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

• “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

• “Relevant Personal Data” means Personal Data in respect of which we are the Controller.

• “Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, biometric data, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.

• “Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.

• “Site” means any website operated, or maintained, by us or on our behalf.

• “UK GDPR” means the GDPR as it forms part of the laws applicable in the UK by virtue of section 3 of the European Union (Withdrawal) Act 2018, and as applied and modified by Schedule 2 of the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (SI 2019/419) or as modified from time to time by other laws applicable in the UK).

• “UK International Data Transfer Agreement” means the template transfer agreement adopted by the UK Information Commissioner’s Office on 21 March 2022.