In certain cases, additional privacy notices and/or consent forms (“Privacy Notices”) will be provided to you, which will provide additional information as to the processing of your Personal Data.
Sources of Personal Data
Directly from you: We may collect Personal Data from you when you, for example:
- visit and/or communicate with us through the Site and/or offline;
- partner with us in research and/or inquire about the same;
- register for an event sponsored or hosted by us;
- participate in our clinical trials or patient access programs as a healthcare professional;
- submit a job application to us; and/or
- otherwise voluntarily provide us with your Personal Data.
From third parties: We may collect Personal Data from third parties that you, or the entity you represent, might be interested in, for example, collaborating, partnering, or investing with us, or licensing or purchasing our products. These third parties may include, for example, third party data providers, healthcare professionals, healthcare organizations, clinical trial sites, public databases, and references and referral sources.
Types of Personal Data
The Personal Data we may collect and may have collected varies depending on the purpose for which we are collecting your Personal Data. This will include the following categories of Personal Data:
- Personal identifiers and contact information, including your name, physical address, email address, phone numbers, and IP address or other unique identifier.
- Demographic information, such as age, date of birth, and gender.
- Education, professional and performance information, including employer, job title, specialty, employment history, background check information, references, membership in professional organizations, speaking engagements, and affiliations with patient advocacy organizations.
- Financial information, such as bank account information and amounts paid.
- Audio and visual information, including video recordings e.g., where you participate as a speaker at one of our events.
- Internet or other electronic activity information, such as your device and browser type, your browsing and search history on our Site, and information regarding your interaction with our Site.
Use of Personal Data
We may have used, and may continue to use, your Personal Data for the purposes and in reliance on the legal bases set out below.
As necessary for our legitimate interests to:
- Operate and manage our business: for example, providing our products and services, improving and developing new products and services, researching market trends, conducting audits and investigations, and otherwise administering our business.
- Communicate with you: for example, responding to your questions or requests for information or otherwise contacting you in connection with our business, to manage and maintain our relationships with you, for ongoing customer service and for maintaining records of our communications with you.
- Promote our business: for example, carrying out solicited sales marketing and activities, sending you market research communications and enabling the creation, distribution, broadcast or other use of any video recordings made during an event.
- Collect information from or about you, for example, where you are a health care professional interested in participating in one of our clinical trials or patient access programs.
- Identify / consider potential candidates for employment, for example, reviewing CVs or publicly available information to identify candidates.
- Administer the day-to-day management of our business, for example, to monitor, maintain and improve the processes, information and data, technology and communications solutions and services we use and offer, to perform general, financial and regulatory accounting and reporting, and to share Personal Data with third parties that acquire or are interested in acquiring all or part of our assets or shares or that succeeds us in carrying on our business.
- Enforce or defend our rights and interests and those of third parties, ourselves or through third parties to whom we delegate such responsibilities.
You have the right to object to the processing of your Personal Data (including, for direct marketing purposes). You can request a copy of the legitimate interest assessment undertaken by contacting our data protection officer via [email protected].
Pursuant to a contract, to:
- Engage you to provide services to us, for example, engaging with services providers that provide market research services or working with research collaborators.
- Provide grants and sponsorships, for example, sponsoring and participating in research, events, and conferences.
Where we require your Personal Data to comply with our contractual obligations, failure to provide this Personal Data could make it impossible for us to engage with you.
With your consent to:
- Send you promotional information about our products and services (where permitted by law) and conduct market research activities. We will obtain your consent for such activities via a separate consent form. If you wish to stop receiving marketing communications from us you can unsubscribe via the link at the bottom of the relevant e-mail or contact us using the contact details below.
- Personalize our interactions with you, for example, to personalize your visit to the Site and to assist you while you use the Site, and to improve the Site by helping us understand who uses the Site.
As required by law, to:
- Monitor adverse events and product complaints, including to disclose appropriate information to regulators.
- Comply with transparency reporting requirements in relation to agreements with an/or payments and benefits to healthcare professionals and healthcare organizations.
- Fraud prevention and detection.
- Respond to legal requests, for example, from administrative or judicial authorities and complying with subpoenas.
- Investigate and resolve complaints and manage regulatory matters, investigations and litigation.
Where we require your Personal Data to comply with our legal requirements, failure to provide this Personal Data could make it impossible for us comply with our legal obligations.
Sharing of Personal Data
We may disclose, each of the categories of Personal Data identified above to:
- Affiliates: We may share your Personal Data with other companies in the argenx group of companies located in and outside of the European Economic Area (“EEA”) / UK where in our legitimate interests to assist in the delivery of goods / services to you and/or to otherwise manage our business. We also reserve the right where in our legitimate interests and/or where required by law to disclose and transfer such information to a subsequent owner, co-owner or operator of the Site or in connection with a merger, consolidation, restructuring, sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
- Third Parties providing services on our behalf: We may use third party vendors in and outside of the EEA/UK to perform certain services on our behalf, such as technical support, marketing support and back-office services, clinical research organisations, laboratories, hosting services and Site activity tracking and analytics. We may also disclose your Personal Data to our advisors (e.g., attorneys and other professional services firms) in and outside of the EEA / UK.
- Business Partners: We may share your Personal Data with healthcare professionals and organizations, distributors, other members of the healthcare and pharmaceutical industry including, researchers with whom we collaborate, companies with whom we co-develop a therapy, or companies with whom we co-promote a product where in our legitimate interests.
- Judicial, Regulatory and Law Enforcement Bodies: We may share your Personal Data as required by law or where in our legitimate interests, to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your Personal Data with third parties to help detect and protect against fraud or data security vulnerabilities in reliance on the same legal bases for processing.
Transfer of Personal Data to third countries
Your Personal Data can be transferred to countries outside the EEA/UK, including in countries that may not offer the same level of protection as in the EEA/UK (such as, the US). We have put in place appropriate safeguards so that your Personal Data are and remain protected. These include implementing the Standard Contractual Clauses which may require the recipient to put in place supplementary measures to ensure an essentially equivalent level of protection is provided, as in the EEA/UK. We will ensure that your rights and an adequate level of protection essentially equivalent to that ensured within the EEA/UK are guaranteed. You may obtain further information and a copy of the relevant data transfer mechanisms that we have in place by contacting our data protection officer via [email protected].
Protection of your Personal Data
We are committed to protecting the security and privacy of your Personal Data. We maintain appropriate security procedures and practices designed to protect the security, confidentiality, and integrity of Personal Data. These include the use of appropriate technical and organizational measures to restrict access to Personal Data to those of our employees, agents, contractors, or representatives who require access to such information to perform tasks assigned to them by us. These measures shall take into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons. For instance, we store your Personal Data on servers that have various types of technical and physical access controls, which may include, for instance, if appropriate, encryption. While we are committed to safeguarding your Personal Data through our information security program, even the most stringent security program may not always be able to prevent all security breaches.
How long we keep your Personal Data
We keep your Personal Data for the duration that is needed to achieve the purpose for which it was collected. The criteria used to determine the retention periods include: (i) how long the Personal Data is needed to provide / receive the services and operate the business; (ii) the type of Personal Data collected; and (iii) whether we are subject to a legal, contractual or similar obligations to retain the Personal Data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation or data that must be retained for the purposes of litigation or disputes). Further information is set out in the relevant Privacy Notice and/or can be obtained by contacting our data protection officer via [email protected].
Your data privacy rights
You have the following data privacy rights which may be subject to limitations / restrictions:
- The right to request access to your Personal Data.
- The right to request that your Personal Data be corrected or deleted.
- The right to request that we restrict our processing of your Personal Data.
- The right to object to the processing of your Personal Data where it is carried out (i) for our legitimate interests unless we can demonstrate compelling legitimate grounds for the processing, and/or (ii) for direct marketing purposes.
- The right to object to the processing of your Personal Data (including, for direct marketing purposes) or withdraw consent to the processing of your Personal Data.
- The right to request that Personal Data be provided to you or a third party in a machine-readable format.
Please contact our data protection officer via [email protected] in case you wish to exercise any of these above rights.
You also have the right to file a complaint with the competent data protection authority if you believe we did not properly handle your Personal Data or did not respect your rights.
Other useful information
The Site is not designed for or intentionally targeted at children 16 years of age or younger. If we become aware that a child under 16 has provided us with Personal Data, we will take reasonable steps to remove such information from our systems and terminate the applicable account.
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