Please read this privacy notice (“Notice”) carefully to understand our policies and practices regarding your Personal Data and how we will treat it. This Notice applies to individuals who interact with Galderma services as set out below (“you”). This Notice explains how your Personal Data are collected, used, and disclosed by Galderma SA (“Galderma”, “We”, Us”). It also tells you how you can access and update your Personal Data and make certain choices about how your Personal Data are used.
This Notice covers both our online and offline data collection activities, including Personal Data that We collect through our various channels such as websites, third party social networks and through our vigilance activities.
If you do not provide necessary Personal Data to us (We will indicate to you when this is the case, for example, by making this information clear in our registration forms), We may not be able to provide you with our goods and/or services. This Notice can change from time to time (see Section 11).
This Notice provides important information in the following areas:
This Notice applies to Personal Data that We collect from or about you, through the methods described below (see Section 2), from the following sources:
Depending on how you interact with Galderma (online, offline, over the phone, etc.), We collect various types of information from you, as described below.
We do not knowingly solicit or collect Personal Data from children below the age of 13. If we discover that we have unintentionally collected Personal Data from a child below 13, we will remove that child’s Personal Data from our records promptly. However, Galderma may collect Personal Data about children below the age of 13 years of age from the parent or guardian directly, and with that person’s explicit consent as required by law.
The following paragraphs describe the various purposes for which We collect and use your Personal Data, and the different types of Personal Data that are collected for each purpose. Please note that not all of the uses below will be relevant to every individual.
What We Use Your Personal Data For
Our legitimate interests
Patient/Consumer service. We use your Personal Data for consumer service purposes, including responding to your enquiries. We collect information about how Our websites are used to be able to provide you with certain content and improve it based on the feedback we receive. Responding to your inquires typically requires the use of certain personal contact information and information regarding the reason for your inquiry (e.g. responding to any questions or concerns you may have concerning your use of our products, order status, technical issue, product question/complaint, general question, etc.).
Establishing and maintaining our relationship with Healthcare Professionals. We use your Personal Data to verify whether there is a potential business opportunity, reach out to you and inform you about our products and services, and maintain a relationship with you.
Contacting you and conducting advertising on third party social networks: We use your Personal Data when you interact with third party social networking features, such as “Like” functions, to serve you with advertisements and engage with you on third party social networks. You can learn more about how these features work, the profile data that We obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third party social networks.
Legal reasons or merger/acquisition. In the event that Galderma or its assets are acquired by, or merged with, another company including through bankruptcy, we will share your Personal Data with any of our legal successors. We will also use your personal data to comply with our legal obligations (e.g., tax law and product safety obligations). We will disclose your Personal Data to third parties (i) when required by applicable law; (ii) to establish or respond to legal proceedings; (iii) in response to a request from a competent law enforcement agency; (iv) to protect our rights, privacy, safety or property, or the public; or (v) to enforce the terms of any agreement or the terms of our Website.
In case we want to use your Personal Data for purposes unrelated to those described in this Notice, we will first notify you and, where required, offer you a choice as to whether or not we may use your Personal Data in this manner.
In addition to the Galderma entity mentioned in the data controllers & contact section (see Section 12), We share your Personal Data with the following types of third party organisations:
Galderma takes every reasonable step to ensure that your Personal Data are only processed for the minimum period necessary for the purposes set out in this Privacy Notice. The criteria for determining the retention period for your Personal Data are:
(a) Galderma will retain copies of your Personal Data in a form that allows for identification only for as long as: (i) We maintain an ongoing relationship with you; or (ii) your Personal Data are necessary in connection with the purposes set out in this Privacy Notice and we have a valid legal basis,
(b) if you are a healthcare professional, your Personal Data will be retained for 2 years after your last interaction with us, unless applicable laws or sectoral regulations impose longer retention periods,
(c) in the remaining cases, your Personal Data is kept for the duration of: (i) any applicable limitation period (i.e. any period during which a person could bring a legal claim against us), and (ii) an additional 2 months following the end of the applicable limitation period (so we are able to identify any personal data of a person who may bring a claim at the end of the applicable period), and
(d) in addition, if any relevant legal claims are brought, we may continue to process your Personal Data for such additional time necessary in connection with that claim.
During the periods noted in paragraphs c (i) and c (ii) above, we will restrict our processing of your Personal Data to storage or, and maintaining the security of, those data, except to the extent the data need to be reviewed in connection with any claim, or any obligation under applicable law.
Once the periods in paragraphs (a), (b), (c) and (d) above, each to the extent applicable, have concluded, we will either (i) permanently delete or destroy the relevant Personal Data or (ii) anonymise the relevant Personal Data.
We use appropriate measures (described below) to keep your Personal Data confidential and secure. Please note, however, that these protections do not apply to information you choose to share in public areas such as third party social networks.
Access to Personal Data. You have the right to access and request a physical or electronic copy of information held about you. Where the data was not obtained directly from you, you also have the right to request information on the source of your Personal Data.
These rights can be exercised by sending Us an e-mail at email@example.com or writing to us at Galderma SA, Avenue Gratta Paille 2, 1018 Lausanne, Switzerland, attaching a copy of your ID or equivalent details (where requested by Us and permitted by law). If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected. Please note that any identification information provided to Us will only be processed in accordance with, and to the extent permitted by applicable laws.
Additional rights (e.g. modification, deletion of Personal Data). Where provided by law, you can request deletion, objection, the portability, rectification of your Personal Data and restrict our processing of your Personal Data.
Please note that, in certain circumstances, We will not be able to delete your Personal Data without also deleting your user account. We may be required to retain some of your Personal Data after you have requested deletion, to satisfy our legal or contractual obligations. We may also be permitted by applicable laws to retain some of your Personal Data to satisfy our business needs.
Where available, our Websites have a dedicated feature through which you can review and edit the Personal Data that you have provided.
We hope that We can satisfy queries you may have about the way we process your Personal Data. However, you have the right at any time to complain to competent data protection authorities.
We strive to provide you with choices regarding the Personal Data that you provide to Us. The following mechanisms give you the following control over your Personal Data:
Cookies/Similar Technologies. You manage your consent via (i) our consent management solution or (ii) your browser so as to refuse all or some cookies/similar technologies, or to alert you when they are being used. Please see Section 4 above.
If We change the way We handle your Personal Data, We will update this Notice. We reserve the right to make changes to our practices and this Notice at any time, please check back frequently to see any updates or changes to our Notice.
To ask questions or make comments on this Notice and our privacy practices or to make a complaint about our compliance with applicable privacy laws, please contact our Group Data Protection Officer at: firstname.lastname@example.org or in writing to Galderma SA, Avenue Gratta Paille 2, 1018 Lausanne, Switzerland or write to the relevant Galderma entity in your country of residence.
We will acknowledge and investigate any complaint about the way We manage Personal Data (including a complaint that We have breached your rights under applicable privacy laws).
Last updated: October 2020.
Copyright © 2020 Galderma S.A.