Glenmark | Privacy Policy

Privacy Notice – website visitors

1. Important Information and Who We Are

What is the purpose of this document?

Glenmark Pharmaceuticals Limited including its subsidiaries, affiliates, successors, assigns and representatives worldwide (“Glenmark”) respects your privacy and is committed to protecting your personal data.

In this privacy notice we will explain how we handle personal data that we or our service providers process through your interactions with us or them, through your use of our website or similar environment, such as mobile websites or apps that are operated and maintained by us and from which you can access this privacy notice (collectively, the “websites”).

Application and Scope

This privacy notice is global in scope and applies to all Glenmark websites. This privacy notice does not apply to Glenmark Life Sciences Limited, Ichnos Sciences Inc., USA, or their subsidiaries.

Our websites are neither intended for nor do they offer products and services for children/minors. We do not knowingly collect or process data relating to children/minors.

Third-party links

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their processing of personal data. When you leave our websites, we encourage you to read and consider the privacy notice of every website you visit to ensure this is acceptable to you and meets with your expectations.

Changes

We may modify this privacy notice without warning. You should therefore periodically visit this page to be sure that you have read our most current privacy notice and to ensure that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

If the terms of this privacy notice are not acceptable to you, then you should not access or use the website in any manner. However, at point of time or after giving your consent, if you wish that we should not process your personal data, you may withdraw your consent in the manner as described in this Privacy Notice. Please note that in case you withdraw your consent, you may not be able to access or use the website or some features of the website.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We use different methods to collect data from and about you including through automated technologies or interactions.

Most of our services do not require any form of registration, allowing you to visit our websites without telling us who you are. Some services may require you to provide us with personal data, which may include but is not limited to your direct identifiers, such as:

Identity Data first name, last name, username or similar identifier, title, job title, qualifications, date of birth, email address, telephone number and address;

Technical Data internet protocol (IP) address, AC address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;

Usage Data information about how you use our website, products and services;

Financial data shared by you as part of your purchase of pharmaceutical products from our website(s);

Health related data such as medical/health records, treatment plans, health insurance plans, medication history and related data;

Service data relating to products and services offered on our website such as membership details, registrations numbers and product and services reviews and ratings; and

Marketing and Communications data your preferences in receiving marketing and promotional material from us and our third parties including your communication preferences such as type, format and frequency.

3. Ways in which Personal Data is Provided

We use different methods to collect data from and about you including through automated technologies or interactions.

Information you provide. We may ask you to provide, or you may choose to provide information. Such information may be provided to us at various times, including, without limitation: when you fill in specific forms online; when you register on a Glenmark website or on other Glenmark platforms; when you register for an event or webinar via a Glenmark website/platform or by contacting us offline; when you request information or services; and when you purchase products directly from a Glenmark website.

Information collected automatically. If you interact with our websites or other online portals and systems, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and similar technologies. Please see our Cookie Policy for further information.

4. How We Use Your Personal Data

We may use personal data about you:

• to answer your enquiries and meet your requests, for instance to send you requested information.

• to provide important information about our business relationship with you, about our terms of business or use or to send you other information related to processing of your personal data.

• to comply with legal or regulatory obligations that apply to us, which include monitoring safety, managing adverse events, carrying out prevention and investigatory activities, or carrying out administrative formalities, registration, declarations or audits.

• to conduct direct marketing activities, including sending you targeted emails and offers but always and only in accordance with applicable privacy laws.

• to improve our interactions with you, to enhance our website, to personalise your use of our websites, by presenting you with product information and services tailored to you, as well as to identify the effectiveness of our advertising campaigns. In this respect, we adhere strictly to local legal requirements and as far as possible only use anonymised data, which does not allow inferences to be made about you as an individual. Applicable national laws may provide separate preconditions for the individual uses of data.

• to operate use-based online information (more information on this can be found in our Cookie Policy).

• to respond to legal requests from administrative or judicial authorities, in accordance with applicable laws.

• to fulfil product purchase orders and service requests placed through our websites.

• to provide details about loyalty programs owned and operated by us.

• for billing, pricing and administration purposes and to handle your requirements, queries, complaints and feedback.

5. Our Legal Basis for Using Your Data

We will only use your personal data when the law permits us to do so.

We must have a valid basis for using your personal information and we may not collect, store or use information shared via our website other than as described in this privacy notice. There are four ways we may have a valid basis for using your personal information:

Fulfilling a contract: The information we collect from you may be necessary to allow us to fulfil our contract with you or to enter into a contract with you.

Consent: You provide your consent for us to contact you or to collect your information for example, by consenting to the use of cookies on our website or by opting-in to receiving emails or other direct marketing communications. Once you have given consent to our use of your personal information, you are entitled to withdraw this consent at any time by various means including unsubscribing via the corresponding link provided within marketing emails we send to you or by contacting us at dpo@glenmarkpharma.com.

Legitimate interest: We may also have a legitimate interest in using your personal data to enable us to give you the best service/product and the best and most secure experience.  If this is our reason for using your personal information, we must make sure that our interests do not override yours and you may seek to object to this use of your personal information accordingly.

Legal obligation: Lastly, we may have a legal obligation to use your personal information in certain ways or to protect your interests, for example we may exchange information with other companies and organisations for the purposes of ensuring your legitimacy to view certain website content or to monitor adverse effects of marketed products.

6. Disclosures of Your Personal Data

Who has access to personal data

If necessary and where legally permitted to do so, we may pass your personal data to the following third parties:

Companies that form part of the Glenmark group, but only for the purposes identified in this privacy notice and within the scope of permitted transfers. In any event, we remain fully responsible for the handling of personal data for shared use and will ensure this is done so in accordance with applicable privacy laws.

Service providers, who provide services such as website hosting and moderation, order fulfilment, payment processing, the processing of your reviews of products and services, the provision of call centre services, the hosting of mobile applications, data analysis, infrastructure provision, IT services, customer services, delivery services for e-mails and direct advertising. Here too, these service providers are not permitted to use your personal data for their own purposes, however, we may allow them to determine and control the manner in which they process your personal data in order to achieve the specified purposes for which such personal data was originally provided.

Third parties to whom we are required to transfer personal data because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding.

International Transfers

Glenmark is a global company. The personal data we collect from you may be stored, accessed or processed in any country where we maintain branches or the aforementioned parties are located. Whenever we export your personal data, we ensure a similar degree of protection is afforded to it by using specific contracts that ensure the importer of such data has appropriate and equivalent safeguarding measures in place.

7. How We Protect Your Data

We have put in place appropriate technical, organisational and security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, service providers, contractors and other third parties who have a business need to know.

8. How Long We Will Use Your Data For

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Your Legal Rights

Under certain circumstances, you may have rights under data protection laws in relation to your personal data:

Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (as explained below). Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. In such circumstances we may reserve the right to delete your personal data rather than hold it but restrict processing, where our processes are not set up to enable a restriction.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Request information about your personal data. On request, we will disclose to you the categories of personal information Glenmark collected, used or shared about you, which third parties were involved (if any) and why they collected, used or shared that information.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

These rights can be exercised by sending an email request to dpo@glenmarkpharma.com. We will respond to your request as soon as practically possible and within the timeframes set forth by applicable law.

10. Sale of data

We do not sell your personal data to other businesses or third parties under any purposes of processing.

11. Data protection officer

We have appointed IG Smart as our global Data Protection Officer (DPO) to oversee compliance with this privacy Notice and our privacy obligations generally. If you have any questions about this Notice or how we handle your personal information, or wish to exercise any of your rights contained hereunder, please contact us by email at dpo@glenmarkpharma.com or alternatively contact our global DPO directly at dpo@ig-smart.com.

12. Complaints

If you are unhappy with the way in which we have processed your personal data please address any complaint to dpo@glenmarkpharma.com. In any case, you also have the right to lodge a complaint with the relevant supervisory authority which can be found at https://pdpecho.com/the-list/