Primal Pictures is part of Pharma Intelligence (Citeline), a Norstella company
This site operated by Pharma Intelligence UK Limited, registered in England and Wales with company number 13787459 whose registered office is 3 More London Riverside, London SE1 2AQ.
This section clarifies the organisation that may use your personal information.
Pharma Intelligence is the leading provider of drug, device, company, clinical trial and market intelligence in the pharmaceutical and MedTech markets.
Data and information are at the heart of what we do, and we take matters of data privacy seriously. We respect our relationships with customers, clients, visitors, sponsors, exhibitors, contributors, suppliers and colleagues, and the trust they place in us to hold their personal information.
Data Controller
This Privacy Policy explains how Pharma Intelligence UK Limited – a company registered in England and Wales with company number 13787459 whose registered office is 3 More London Riverside, London SE1 2AQ (Copyright ©️ 2023 Pharma Intelligence UK Limited (Citeline), a Norstella company) and the data controller of personal information – collects, uses, and protects personal information across our products and services. References to “we”, “us” or “our” are to Pharma Intelligence and its associated entities processing your personal information.
To update your personal information or marketing preferences, or for any data privacy queries or complaints, you can address them to our Privacy team by contacting [email protected].
International coverage and variation
Pharma Intelligence operates in over several countries, which each have varying data protection laws. This Privacy Policy applies to all Pharma Intelligence products and services across the world except to the extent a country specific requirement supplements the policy. These country specific requirements are listed in the country appendices below.
This section explains what personal information we collect.
This section describes what personal information we may collect from you when you use our products and services, and what other personal information we may receive from other sources.
In this Privacy Policy, personal information refers to the types of personal information that may be collected and used, including:
This personal information relates to the following categories of people:
We may collect this information directly from you when you register for an event or engage with our services and/or platforms. We may also collect this information from third party partners and public sources to the extent permitted by applicable data protection law. In some cases, the data we collect from third parties is provided in pseudonymised form and we are only able to connect it to you, if, and when you enter your email address on our webforms.
If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data (e.g., we may require your passport details to verify your identity for the purposes of compliance with laws and regulations). Failure to provide this information means that we cannot conduct business with you. In this case, we may have to cancel an existing business arrangement with you but we will notify you if this is the case at the time.
Sensitive personal information
If collecting or storing sensitive personal information or special category data such as information relating to health, beliefs, or political affiliation, we will typically ask for your explicit consent. However, there are some limited situations where this will not occur, such as if you have an accident. If this does occur, we will ensure your privacy rights are protected.
Children’s personal information
Our services and products are directed at business professionals. They are not intended for children under the age of sixteen. We do not knowingly collect personal information from users in this age group and reserve the right to delete such information if we become aware of having collected it.
This section explains how and why we use personal information.
Product enquiries, sales and administration
If you have made an enquiry about us or our products or services, either online or over the phone, your personal information will be used to respond to the enquiry or to take other steps at your request, prior to you entering into a contract with us.
If you have purchased or registered for one of our products or services, including on a trial basis, we will use your personal information, including bank or card details, to provide you with the product or service, communicate with you about it, handle payments and recover any debts.
Call monitoring for training and quality monitoring purposes
Where one of our sales representatives speaks to you over the phone, the calls are recorded for training and monitoring purposes.
To include professional information in our products and consulting services
If your professional personal information is relevant to our products and is freely available through public sources, such as a website related to your work or profession, listed directories, press releases, industry publications, or if you provide it to us, to the extent permitted by applicable data protection laws, we may use such personal information in the products we provide to customers, for example in subscription products, research, industry analysis and insights.
If you make an enquiry or engage us to provide consulting services or research/analysis, we will collect information such as your name, country, job title, company information or academic affiliation, postal address, e-mail address and telephone number. We will use your personal information to respond to the enquiry or to fulfil consulting services.
For event and exhibition management
If you participate in one of our events as a speaker, sponsor, exhibitor or attendee, your personal information will be used in connection with the running of the event, to handle payments and recover debts.
We will also use your personal information to maintain databases that allow us to assess your qualities as a speaker or sponsor/exhibitor, promote events and encourage further engagement at our events.
In addition, photos and videos are taken at our events, which may feature attendees, speakers, sponsors, or exhibitors. Where we have taken photos and videos at our events that feature you as an attendee, sponsor or exhibitor, to the extent permitted by applicable data protection laws, those photos and videos may be used for promotional purposes.
Where events and exhibitions use badge scanning technology, your personal information will be used to identify you at certain access points, such as to access VIP areas, seminars, entry and exit in other areas of the event. This will provide certain location information. Badges cannot be read remotely.
The personal information obtained from badge scanning will be used for access control, security and analysing visitor traffic with a view to improving the event experience for visitors and others.
You can also allow your badge to be scanned by event exhibitors. When you do so your contact details will be shared with the relevant exhibitor and used in accordance with applicable data protection laws, the exhibitor’s privacy policy and any other notices or consents you are provided with or given at the event.
Where we are hosting and managing a virtual exhibition or event, Pharma Intelligence (and any third party platform provider acting on our behalf) will use your personal information provided during the registration process to host and manage this digital event; and also, for analysing visitor interactions and traffic with a view to improving the event experience for visitors and provide you with a personalized experience.
When you enter virtual spaces, zones, or rooms such as an exhibition booth, your personal information may be shared with the sponsor and exhibitor to allow them to engage with you subject to the attendee privacy notice you may have been provided during the registration and login process.
For marketing
Pharma Intelligence may use your personal information to send you newsletters, offers or other marketing emails that keep you up to date with our news, events and products that may be of interest. Depending on the nature of your interaction with us and applicable data protection laws, you may have actively given us your consent (i.e., opted in) or we may be entitled to rely on your implied consent or legitimate interests to market to you. The opportunity to opt out of future marketing will always be provided, and you have the right to amend your marketing preferences at any time (see Your Rights section).
Many of our events and products are co-branded or sponsored by third party exhibitors or sponsors. We may share your details with these third party partners. Where this happens, a clear notice will be provided, that gives the opportunity to opt out or opt in to such sharing as required by applicable data protection laws. The third party partner’s use of your details will be in accordance with the notice provided and its privacy policy and is not covered by this Privacy Policy.
For our client-facing marketing services
Pharma Intelligence will combine the personal information that they collect from you, including much of the information in the “what we collect” section above, with personal data collected from certain trusted third party sources and use this information to create profiles to determine your/your company’s commercial interests.
For example, we will collate the information you provide as part of your registration for events, information you generate in connection with your attendance at events, information obtained by us using first party cookies and tracking technology on our websites and apps and certain information we obtain from third parties (such as data providers) to analyse, segment and determine which marketing segments you fall within.
This information can then be used by, or for the benefit of, our clients in different ways as part of our marketing service offering to enable these clients to undertake tailored and targeted advertising campaigns. Our clients can present individuals with information about products and services that our clients think will be of interest to them via various channels based on the marketing segments we have developed and allocated individuals to. In many cases these advertising campaigns are run by us on behalf of clients without us ever sharing any personal data with the relevant clients (including via marketing emails, and social media channels and our advertising partners who facilitate advertising on third party sites). In other cases, we may provide to clients information that the client is unable to use to identify you for them to instigate their own marketing campaigns. In all cases, our activities are undertaken to the extent permitted by applicable law. These activities are undertaken based on individuals’ marketing consents. Therefore, if you have exercised your rights to opt out of email marketing, you will not be marketed to in connection with the marketing services we provide to clients via any channel.
The activities that we, and our third party partners, undertake may entail automated and machine learning-based processing of data to analyse or predict behaviours and preferences (e.g., interests in certain content, services and/or at events). The algorithm will identify companies and individuals with similar characteristics to companies and individuals that we know are interested in certain services, generating a similarity score for those clients. We will then enrich the information we hold about companies and individuals and send advertising to prospects based on this analysis.
In social media
We may use your personal information to undertake advertising campaigns on social media platforms such as LinkedIn, Instagram and Facebook in order to provide information about upcoming events or new products and to ensure you only receive relevant advertising about our products and services. We may share your personal information with social media platforms so that you see advertising about our, or our partners’, products and services that we think you will be interested in when you interact with the relevant social media platform. We may also share your personal information with social media platforms to help us present relevant advertising to individuals who the social media platforms determine are likely to have similar interests to you.
We maintain presences on social media platforms, through our company and brand pages. We collect personal information when you interact with us on social media. Please note that these social media platforms may set cookies and other tracking technologies on your device when you visit their pages and when you navigate from their pages. The output of such information may be provided to us (usually for statistical purposes to see how users interact with our content on social media platforms). The social media platforms are responsible for how they handle your personal information and information about how these social media platforms collect and use your personal information (and how they use cookies and other technologies, including instructions on how you can disable these) can usually be found in their respective privacy policies and cookies policies on their respective websites. For customer and prospects management (including analytics and product management)
For customer and prospects management (including analytics and product management)
The personal information held about you, combined with other personal information legitimately obtained and shared with us by third parties or publicly available data, may be used to better understand our customers and their preferences and to improve the products and services delivered. This may include automated profiling and campaign management techniques.
Data may also be used in advertising campaigns on social media platforms such as LinkedIn, Instagram and Facebook in order to provide information about upcoming events or new products and to ensure you only receive relevant advertising about our products and services as described above.
For mobile applications and website analytics
We may combine visitor session information or other information collected through tracking technologies, whether you are logged in or not, with personally identifiable information to understand and analyse your online experiences and determine which events, products and services are likely to be of interest to you.
Where you consent to the use of your location data, certain mobile applications may use location data to assist you to navigate around events and bring exhibitors’ and sponsors’ products to your attention whilst you are using the app.
Our marketing related emails contain a single, campaign-unique “web beacon pixel” to tell us whether emails are opened, and combined with other technology, to verify any clicks through to links within the email. We may use this information for purposes including determining which of our emails are more interesting and to query whether users who do not open our emails wish to continue receiving them. The pixel will be deleted when you delete the email.
Where you subscribe to an online service, the accompanying emails similarly include a pixel. We track interaction with these emails and our online services to validate attendance for accreditation purposes, to help determine which information is of interest to you and to customise the advertisements seen on our sites.
If you do not wish the pixel to be downloaded to your device, you should choose not to click links that we send or to opt out of email marketing or online events. This information may be connected to your personal identity.
While we strive to offer choice when using our website and mobile applications, we do not promise that we will be able to receive or honour web browser Do Not Track signals.
Within online membership communities, bulletin boards and chat areas
You may choose to participate in online membership communities on our sites that allow you to create and publish a profile and other personal information. These communities may provide privacy controls that allow choice in how much of your profile and other information to make public or to share with others within the community.
Privacy controls are usually found on the page on which you edit your profile, and each individual is responsible for understanding how those controls work, including default settings, and choosing how the information provided is shared and protected. By participating in these online membership communities, you may be contacted by other participants using the information provided.
When you disclose personal information on any public community boards or chat areas on such websites, your personal information can be collected and used by anyone who views that board or area. This may result in unsolicited messages from other participants or other parties, which are outside of our control or responsibility.
However, where you engage with us in customer enquiry chat areas, this is private, and we will use any information provided to help recommend products and/or assist with confirming any order you wish to place.
For enquiries
Any personal information provided on the Contact Us page will be used only to provide a response or to service the request or enquiry made. The information provided will not be added to our marketing or customer prospect databases.
For news alerts
The information collected when you sign up for news alerts is used only to provide that service, and to understand the background and interests of our subscriber list.
In providing the service we gather statistics about how many emails are opened, using industry standard technologies including image downloads. This is to help us monitor and improve the news alerts service and information is collected and analysed at an aggregate level only.
With your permission, from time-to-time Pharma Intelligence may use your registration details to contact you about the news alerts service. You can unsubscribe from the service at any time using links provided within our emails.
In automated decision-making, including profiling
We use fully automated algorithm-based technologies to personalise dynamic web content based on your explicit and/or implicit interests. General profiling, such as segmentation, is carried out for the purpose of providing a more relevant experience. Automated decision making is never used in any way that produces a legal or similarly significant effect.
When we use these techniques, we use measures to avoid legally discriminatory biases and inaccuracies. These automated processes may result in different content being shown to you.
For fulfilment of our legal obligations including anti-fraud measures and screening
It is industry standard for companies to access and use certain personal information to prevent fraud, as may be required by applicable law and regulation and best practice at any given time. If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies and may be recorded by us or by them.
To ensure we comply with international trade sanction laws and regulations, where appropriate customers, vendors and suppliers are screened against applicable sanctions lists.
We recognise the importance of protecting and managing personal information. Your personal information will be treated with the utmost care and security. This section sets out some of the security measures in place.
We use a variety of physical and technical measures to keep personal information safe and prevent unauthorised access to or use or disclosure of it. Electronic data and databases are stored on secure computer systems with control over who has access to information using both physical and electronic means. Our colleagues receive data protection training and there is a set of detailed security and data protection policies which colleagues are required to follow when handling personal information.
While we take all reasonable steps to ensure that personal information will be kept secure from unauthorised access, we cannot guarantee it will be secure during transmission by you to a website or other services, as we do not control that transmission. We make use of HTTPS (HTTP Secure) whereby the communication protocol is encrypted via Transport Layer Security (TLS) for secure communication over a computer network. The website is loaded via HTTPS, represented by the lock icon in your web browser ensuring the transmission is secured with a certificate issued by an official security certificate.
This section explains our process around transferring personal information internationally.
Due to the international nature of our business and the technologies required, personal information may be accessed by our colleagues and third-party service providers from locations all around the world, whose data protection laws may not be as extensive as those in regions such as the United Kingdom or the European Union.
We put in place appropriate protections to make sure your personal information remains adequately protected and is treated in line with this policy and applicable data protection laws.
Certain jurisdiction specific requirements apply to this section, as listed in the country appendices below.
More information on our use of cookies can be found in our Cookie Policy.
A cookie is a small text file containing a unique identifier that is automatically placed on a user’s computer or other device when the user visits a website. For more information, please visit our Cookie Policy link on the bottom of the website.
This section explains that third party links on our websites are subject to separate privacy practices.
This website contains links to other websites. We are not responsible for the privacy practices of these websites and do not accept any liability in connection with their content. We recommend reviewing the privacy policy of each third-party site linked from this website to determine its use of your personal information.
Your information may be shared for specific reasons. This section explains how and why personal data is shared.
Sharing with Service Providers
We may share your personal information with third parties who assist in providing our products and services and administering our business. These include IT and marketing technology host suppliers, web and data hosting providers, mailing houses, ad servers, logistics and general services contractors, debt collection agencies, onsite health and safety partners, event registration partners, sales platform providers, communication tool providers, stand designers/builders/fitters, suppliers of sponsorship/marketing/PR collateral and other event collaboration partners. Personal information will only be shared with third parties if and to the extent it is necessary for them to provide our products and services to you.
We use web chat services including Intercom, LiveAdmins, Live Chat, Casengo that allow us to connect with you and answer sales and customer services questions quickly and directly. We ensure these service providers protect your data but these chats are intended to provide quick answers to basic service questions only, and you should not provide any sensitive information, such as bank or credit card details in these chats.
These data processors are bound to compliance through contracts in place that protect the personal information you have shared with us.
Sharing with other Organisations
We may share your personal information with trusted partner organisations for their marketing purposes, in accordance with local data protection laws and where required, with your permissions.
We may share your personal information with clients and data providers in connection with the marketing services referred to above, who are bound to process that data strictly in compliance with applicable law.
To reorganise or make changes to our business
If we are subject to negotiations for the sale of all or a part of our business to a third party, are sold to a third party or undergo a re-organisation, we may need to transfer some or all of your personal information to the relevant third party or its advisors as part of any due diligence process. Any information that is transferred to that re-organised entity or third party will be used for the same purposes as set out in this policy, or for the purpose of analysing any proposed sale or re-organisation.
In connection with legal or regulatory obligations
We may process your personal information to comply with our legal and regulatory requirements or to respond to regulators where applicable. This may include disclosing your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings, or investigations by such parties anywhere in the world or where compelled to do so.
In some circumstances, we may be legally required to disclose your personal information because a court, the police, another judicial or law enforcement body or government entity has asked us for it.
We will only retain personal information for as long as is necessary and as permitted by applicable laws.
We will retain personal information while we are using it, as described in the section above. We may continue to retain it after we have ceased such uses for certain legitimate business purposes. For example, if you have opted out of marketing communications from us, we will retain limited details about you to ensure we can honour your opt-out request. We may also continue to retain your personal information to meet our legal requirements or to defend or exercise our legal rights.
The length of time for which we will retain your personal information will depend on the purposes for which we need to retain it. After we no longer need to retain your personal information, it will be deleted or securely destroyed
This section explains your legal rights in relation to how we process your personal information depending on jurisdiction.
Pharma Intelligence operates in countries with data protection laws that provide different rights to individuals in respect of access, deletion, rectification and limiting processing of personal information.
To understand rights you have in respect of your personal data, please see below for the relevant country appendix where the Pharma Intelligence product you engage with is located.
To make a request you can contact our Privacy team by contacting our Privacy team at [email protected].
This section explains who you can contact to update your personal information that we hold and how you can update how we can send you updates on our products, services and events.
We want you to remain in control of your personal information. We try to ensure the personal information held about you is accurate and up-to-date. We will always provide the opportunity to unsubscribe or opt out of future marketing communications.
Information on how to unsubscribe or opt out will be provided on every marketing email we send you. However, if at any stage you would like to update and/or correct such personal information, or opt-out of future marketing communications, request this by sending an email to our Privacy team at [email protected].
For any questions about this Privacy Policy contact our Privacy Team.
For any questions about this Privacy Policy or our use of your information, you can contact our Privacy team at [email protected].
We hope we will be able to resolve any privacy concerns you may have. However, you always have the right to complain to any supervisory authority or other public body with responsibility for enforcing privacy laws in your country. The contact details for the supervisory authority in the country for are set out in the country appendices below.
Please note that we update our Privacy Policy from time-to-time.
To keep up with changing legislation, best practice and changes in how we process personal information, we may revise this Privacy Policy at any time. Depending on the nature of the changes, we may update you via email if we have your personal information; or we may update the Policy without notice by posting a revised version on this website. To stay up to date on any changes, check back periodically.
This Appendix applies where a Pharma Intelligence product you are engaged with is in the EU or UK or where a Pharma Intelligence product based outside the EU or UK provides services to you if you live in the EU or UK.
How and why we use personal information
There are a number of legal grounds under which the use of personal information under UK and EU data protection laws is justified and we are required to set out the grounds of such use in this Privacy Policy. An explanation of the scope of the principal grounds that justify our use is set out below:
International transfer of personal information
To the extent your personal information is transferred to countries outside of the UK or the European Economic Area, such transfers will only be made in accordance with UK and EU data protection laws. For further information about the safeguards used, please contact our Privacy team at [email protected].
Your rights
You have the right to access the personal data we hold about you, and there are a number of ways you can control the way in which and what personal data we store and process about you. To exercise these rights and controls, please contact our Privacy team at [email protected].
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). If you exercise any of these rights, we will check your entitlement and respond in most cases within a month.
We hope to resolve any privacy concerns you may have. If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to any supervisory authority or other public body with responsibility for enforcing privacy laws.
In the UK, the UK Information Commissioner’s Office regulates and enforces data protection law. Their procedures can be found at www.ico.org.uk.
In the Netherlands, the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) regulates and enforces data protection law. Their procedures can be found at www.autoriteitpersoonsgegevens.nl.
This Appendix applies where you provide us with personal data which is subject to the requirements of the Singapore Personal Data Protection Act.
By accessing this website, supplying any information via this website, or continuing to use our services, you agree to all the terms of this Privacy Policy as updated from time to time.
International transfer of personal information
By providing us with personal information, you specifically consent to the transfer of data containing such information outside of Singapore for the purposes described in this Privacy Policy.
Your rights
You have the right to access, correct or update your personal data under Singapore law. If you wish to exercise any of these rights, you may do so at any time by contacting our Privacy team at [email protected].
Your exercise of these rights is subject to certain exemptions, including where the provision of your personal information might reveal personal information about another individual (where you have made an access request), or where we are satisfied on reasonable grounds that the correction should not be made (where you have made a correction request).
This Appendix applies where the Pharma Intelligence product you are engaged with is in Japan or where a Pharma Intelligence product based outside Japan provides services to you if you live in Japan.
Your rights
If you have any questions in relation to our use of your personal information, you should first contact us. Under certain conditions, you may have the right to require us to:
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). If you exercise any of these rights, we will check your entitlement and respond in most cases within a month.
This Appendix applies where the Pharma Intelligence product you are engaged with is in South Korea or where a Pharma Intelligence product provides services to you if you live in South Korea.
Your rights
You have the right to request us to provide access to or correct your information or suspend the processing of your information at any time. You may exercise such right by sending us a letter or an e-mail pursuant to the Personal Information Protection Act and other applicable laws and regulations. If you have a legal representative, your legal representative may exercise such right on your behalf.
How long do we keep your information?
Period of Use and Retention of Personal Information: In principle, we will promptly destroy your personal information in our possession once we achieve the purpose of collection and use of personal information. However, the following categories of your personal information will be retained by us for the duration of the periods specified below.
Retention under Applicable Laws and Regulations: If required under the Law on Protection of Consumers in E-Commerce and other applicable laws and regulations, we will retain your personal information for the period specified under such laws and regulations. In such case, we will use your personal information only for the purpose of retaining such data. The retention periods are as follows.
Records on Contracts or Cancellation of Orders
Law on Protection of Consumers in E-Commerce
5 years
Records on Payment and Goods and Services
Law on Protection of Consumers in E-Commerce
5 years
Records on Electronic Financial Transactions
Electronic Financial Transactions Law
5 years
Records on Consumer Disputes and Resolution
Law on Protection of Consumers in E-Commerce
3 years
Records of Website Visits
Communications Secrets Law
3 months
Procedure and Method for Destruction of Personal Information
The process and means of destroying your personal data are as follows:
A. Procedure
Your personal information will be transferred to a separate database (or separate document file for paper documents) and destroyed after storage for a certain period, according to our internal policy or applicable laws and regulations. Please refer to the provisions on retention and use period for these.
Such personal information will not be used for any purpose other than the purpose permitted under the applicable laws and regulations.
B. Method
Personal information that has been printed on paper will be shredded using a document shredder or incinerated. Personal information stored in electronic file form will be deleted by using technical means that will not allow data recovery.
This Appendix applies where the Pharma Intelligence product you are engaged with is in China or where a Pharma Intelligence product provides services to you if you live in China. Hong Kong SAR, Macao SAR and Taiwan are not included for the purpose of this Privacy Policy.
By using this site or our services you consent to the processing in this Privacy Policy as updated from time to time.
This Appendix applies if you live in Canada. This Appendix should be read in conjunction with and in addition to the main body of the Privacy Policy to which this Appendix is attached.
How and why we use personal information
Canadian privacy laws require that we obtain your consent for the collection, use and disclosure of your personal information whenever possible. You consent and agree to the collection, use and disclosure of your personal information in accordance with the terms of this Privacy Policy (as updated from time to time) and this Appendix by using this site or the services. For certain uses (such as for marketing), we will obtain your consent to that specific processing at the time of collecting your personal information.
The purposes of the collection, use and disclosure of your personal information are as described in the main body of the Privacy Policy. We will not collect, use or disclose your personal information for any new purpose without first identifying the new purpose and including it in an updated version of this Privacy Policy.
Where you have consented to our use of your information you may withdraw your consent through the privacy preferences dashboard.
International transfer of personal information
Your personal information may be collected, used or disclosed outside of Canada anywhere in the world, including but not limited to the locations of Pharma Intelligence affiliates, or third party partners including affiliates and service providers and cloud services providers set out in the main body of the Privacy Policy. We will ensure that technical and contractual measures are imposed on entities acting on our behalf to which we have transferred your personal information. Please note that when your personal information is transferred to another country, it may be accessible by law enforcement and/or national security authorities of that jurisdiction.
Your rights
If you have any questions in relation to our use of your personal information, you should first contact us. Under certain conditions, you may have the right to:
Access to Information and Enquiries
Upon written request and authentication of identity, Pharma Intelligence will provide you with your personal information under its custody or control, information about the ways that your personal information is being used and information regarding individuals or organizations to whom your personal information has been disclosed or transferred.
A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to Pharma Intelligence’ Privacy Team in the “Contacting Us” section of the Policy.
Pharma Intelligence may charge a reasonable fee for providing personal information in response to an access request and will provide an estimate of any such fee upon receiving a written access to personal information request. Pharma Intelligence may require a deposit for all or part of the fee.
Pharma Intelligence will make personal information available within 30 days or provide written notice where additional time is required to fulfil the request. In some situations, Pharma Intelligence may not be able to provide access to certain personal information. Pharma Intelligence may also be prevented by law from providing access to certain personal information.
Where an access request is refused in whole or in part, Pharma Intelligence will notify you in writing, giving the reason for refusal and outlining further steps which are available to you.
Enquiries and complaints
If you have any concerns or complaints that are unable to be resolved by contacting the Pharma Intelligence Privacy Team, you may contact one or more of the following applicable supervisory entities in Canada:
Office of the Privacy Commissioner of Canada
30, Victoria Street
Gatineau, Quebec
K1A 1H3
Toll-free: 1-800-282-1376
www.priv.gc.ca
Office of the Information and Privacy Commissioner of Alberta
Suite 2460, 801 6 Avenue SW
Calgary, Alberta
T2P 3W2
Toll-free:1-888-878-4044
[email protected]
Office of the Information and Privacy Commissioner for British Columbia
4th Floor, 947 Fort Street, Victoria BC
V8V 3K3
1-250-387-5629
[email protected]
https://www.oipc.bc.ca
Commission d/acces a l’information du Quebec
Bureau 18.200
500, boul. René-Lévesque Ouest
Montréal (Québec) H2Z 1W7
Téléphone : 514 873-4196
Télécopieur : 514 844-6170
www.cai.gouv.qc.ca
This Appendix applies where the Pharma Intelligence product you are engaged with is in Hong Kong or where a Pharma Intelligence product provides services to you if you live in Hong Kong.
Your rights
If you have any questions in relation to our use of your personal information, contact us. You have the right to require us to:
Your exercise of these rights is subject to certain exemptions. If you exercise any of these rights, we will check your entitlement and respond in most cases within 40 days. A reasonable fee may be charged for the actual costs incurred in complying with your data access request.
This Appendix applies when the Pharma Intelligence product you are engaged with is in the US or where a Pharma Intelligence product outside the US provides services to you or targets you if you live in the US.
All states, except California
Your rights: In some states you have certain rights pertaining to your personal information, including: the right to delete, the right to opt out, right to access and the right to not be discriminated against.
California
Where Californian privacy laws apply (if you are a consumer resident in California and where Pharma Intelligence meets the relevant threshold tests) the following additional provisions apply:
What do we collect – The information that we collect is set out in the main body of the Privacy Policy. We further detail it below in accordance with Californian privacy requirements in the section below.
How we share your personal information is set out in the main body of the Privacy Policy.
We further detail it below in accordance with Californian privacy requirements:
The categories of personal information that we used, transferred, exchanged, or disclosed (including to third parties as set out in the “Who do we share your personal information” with section of the Privacy Policy) about consumers during the preceding 12 months were: (a) identifiers; (b) personal information; (c) classification data; (d) commercial information; (e) internet activity; (f) geolocation data; and (g) inferences.
The categories of personal information that we disclosed about consumers for a business purpose (including to secure our network and our websites, to conduct audits related to our current interactions with you, to debug the site and service, to perform services on behalf of ourselves, including servicing your account and providing you customer service and as set out in the “How and why we use personal information” section of the Privacy Policy) during the preceding 12 months were: (a) identifiers; (b) personal information; (c) classification data; (d) commercial information; (e) internet activity; (f) geolocation data; and (g) inferences.
Tracking: Please note that the do not track disclosures are covered in the main body of the Privacy Policy under “How and why personal information is used”. For information on how we and our partners use cookies and online tracking technologies when you visit our sites please visit our Cookie Policy link on the bottom of the website.
Please note that you can also opt out of tracking by certain third parties through the mechanisms at http://youradchoices.com and https://www.networkadvertising.org/choices.
Your rights – As a California resident, you have the right:
To exercise the access, deletion, and opt-out rights described above, please submit a verifiable consumer request to us by either:
You have the right to request that Pharma Intelligence disclose to you what information it collects, uses, discloses, and sells. You also have the right to request that a business deletes any personal information about you which the business has collected about you.
Please note for your protection, any request sent to Pharma Intelligence will be subject to the following verification procedure requiring you to provide sufficient information that allows us to reasonably identify you are the person about whom we collected personal information including details of products/services you have previously taken with us and also, we will ask you to provide some evidence that you are a California resident (e.g. utility bill). We reserve the right to deny your request if we cannot verify your identify. Where we deny your request in whole or in part, we will endeavour to inform you of the denial, provide an explanation of our actions, and provide the reasons for the denial.
You have the right to direct Pharma Intelligence to not sell your information. To exercise this right to opt-out of the sale of personal information, please contact our Privacy team at [email protected].
Pharma Intelligence shall not discriminate against you for exercising any of your above rights. Please note we will continue to communicate with you directly and send you information about your product/service and promotional materials that may be relevant to you.
You may designate an authorized agent to make a request to exercise your rights on your behalf. Your authorized agent must be able to provide to Pharma Intelligence proof that you have authorized the agent to act on your behalf. For your protection, we reserve the right to deny any request from an agent who does not submit proof that they have been authorized to act on your behalf.
We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Other California Privacy Rights – California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact our Privacy team at [email protected].