[Glargine Converter] App Privacy Policy
Effective Date: May 25, 2018.
WHY THIS DOCUMENT?
As part of its day to day operation, SANOFI provides access to a variety of tools and resources
which are destined to provide information to all the individuals with whom it has business
interactions with (patients and their relatives, participants to clinical trials, healthcare
professionals, users of products and services, workers, etc.) regarding its activities.
Such tools and resources may be provided in various formats, including, more specifically in electronic format
and by means of online electronic communications, including this application or “app” made available by SANOFI
and to which this policy applies (hereinafter together the “App”). In order to be able to provide them, SANOFI
may need to collect and process Personal Data (as defined below) of their users.
SANOFI is fully committed to the protection of Personal Data and intends to provide you with all relevant
information regarding the way in which SANOFI processes your Personal Data on the App.
You will therefore find below all relevant information regarding the processing of Personal Data conducted on
this App. Please note that the content of this App Privacy Policy may change from time to time, for instance in
case of evolution of our processes or as a result of applicable law.. Should these changes be objectively
substantial and affect your rights or our obligations pertaining to the protection of Your Personal Data (and
insofar as we have a means to contact you), we will notify you of the update by adequate means based on the
information we may have collected.
However, we advise you to visit the page of this App Privacy Policy regularly to verify any updates.
WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA ON THIS APP (THE CONTROLLER)
Sanofi-Egypt is responsible for the processing of Personal Data of individuals using this App and therefore acts as the Controller:
- Sanofi-Egypt
- 3, El Massaneh St., Zeitoun, Cairo, Egypt,
- P.O.Box : 1486
- Cairo
- Egypt
- Tel.: +202 2286000 – 22860060
REMINDER: WHAT IS PERSONAL DATA & PROCESSING?
For the purposes of this App Privacy Policy, Personal Data is any information relating to an identified or identifiable natural person, processed by SANOFI in connection with the objectives and purposes defined in this App Privacy Policy.
To make things clear, it is any information that relates to an individual. Such Personal Data can take the form of
- Basic identification information such as your name or date of birth;
- Information that can be attributed to you directly or indirectly – such as a post on a social media
- Information which can be associated to you or your device such as, for instance, an IP address (i.e. the network address of your machine);
- Etc.
In this respect, the notion of “processing” designates any action that is undertaken on your Personal Data such as, for instance:
- Collection;
- Storage;
- Access;
- Analysis;
- Deletion ;
- Etc.
WHAT PERSONAL DATA DOES THIS APP COLLECT?
When operating, this App may collect the following categories of Personal Data:
- Identification data: any information which allows your identification, whether directly or indirectly such as your name or contact details (address, email address, telephone number), your job type, your company
- Messages: you may send us enquiries using this App
- Professional information, notably in case you submit a job application
- Connection data : any information regarding your connection and access to this App (e.g. type of machine and browser used, timestamp of your connection, IP address, pages visited, etc.), browsing history
- Location data : information that may be provided by your machine and browser about your location if you allow such information to be shared with SANOFI
- Under certain specific situations, SANOFI may process philosophical, political and religious opinions, trade-union membership, sexual orientation, information relating to health, racial or ethnic origin: SANOFI will only process such categories of Personal Data, which qualify as “sensitive” Personal Data or “special categories” of Personal Data if duly permitted under applicable data protection laws. In particular, SANOFI will only process such information it has obtained your prior explicit and specific consent to do so.
FOR WHAT PURPOSES DOES THIS APP COLLECT PERSONAL DATA?
Any processing of Personal Data must be implemented for a defined purpose. In this respect, the collection and processing of Personal Data on this App is conducted for the following purposes:
- To allow you to navigate this App
- to provide you access to online services, application and platforms ; manage your online accounts
- to provide patient support, healthcare support services, patient engagement and prescription information ; claims management, including insurance claims ;
- to conduct research and development; carry out clinical studies, registries and trials ; manage and validate the recruitment and participation of individuals to studies, trials and other operations ; analyze demographic data ; offer special programs, activities, trials, events or promotions via our services ; carry out market or consumer studies ;
- To personalize your browsing experience: when using our services ; ensure that our services are presented in the way that best suits you ; understand your professional and personal interests in our content, products and services or other content and adapt our content to your needs and preferences ; present you products and offers tailored to you
- To improve our products and services identify usage trends and develop new products and services ; understand how you and your device interacts with our services ; track and respond to safety concerns ; determine the effectiveness of our promotional campaigns, conduct surveys;
- To process your job applications
- to allow us to communicate with you ; respond to your requests or inquiries ; provide support for products and services ; provide you with important information, administrative information, required notices, and promotional materials ; send you news and information about our products, our services, our brands, our operations ; organize and manage professional events and congresses, including your participation to such events
ON WHAT GROUNDS DOES THIS APP PROCESS YOUR PERSONAL DATA?
For the purposes of this App, your Personal Data is only processed on the basis of:
- your prior CONSENT: where you have clearly expressed your approval of SANOFI’s processing of your Personal Data. In practice, this will generally mean that SANOFI will ask you to sign a document, or to fill-in an online “opt-in” form or to follow any relevant procedure to allow you to be fully informed and then either clearly accept or refuse the envisaged Personal Data processing.
- a contractual relationship between you and SANOFI: in such case, the processing of your Personal Data is generally necessary to the execution or the performance of the contract; this means that if you do not wish SANOFI to process your Personal Data in that context, SANOFI may or will be obliged to refuse to enter into such contract with you or will not be able to provide the products or services covered in this contract.
- the “legitimate interest” of SANOFI in the sense of applicable data protection law. In such a case, SANOFI shall consider your fundamental rights and interests in determining whether the processing is legitimate and lawful.
HOW LONG IS THE PERSONAL DATA COLLECTED IN THIS APP RETAINED?
The Personal Data collected in this App will be retained for the following periods, depending on the categories of Personal Data processed
- Identification data: Sanofi will process my personal data as long as it is not informed that I have ceased to occupy my function as healthcare or pharmaceutical professional and as long as I do no withdraw my consent to the processing of my personal data.
- Messages: Sanofi will process my Messages as long as it is not informed that I have ceased to occupy my function as healthcare or pharmaceutical professional and as long as I do no withdraw my consent to the processing of my Messages.
- Professional information, notably in case you submit a job application : Professional information, notably in case you submit a job application
- Connection data : Application collects connection data anonmously.
- Location data: Application collects location data anonmously
WHO HAS ACCESS TO PERSONAL DATA
SANOFI may transfer your Personal Data both internally (i.e. to other SANOFI entities) and/or externally to third party service providers for the purposes of [Personal Data will not be transferred out of Sanofi].
Where such internal or external transfer of Personal Data implies the transfer of your Personal Data to a country providing a lower level of protection to Personal Data than generally afforded in your jurisdiction, SANOFI will ensure that a sufficient level of protection is provided to your Personal Data by implementing adequate safeguards such as the European Standard Contractual Clauses, the SANOFI Binding Corporate Rules or asking for your prior explicit consent.
YOUR RIGHTS: SANOFI WILL ENSURE THAT YOU CAN EXERCICE YOUR RIGHTS PERTAINING TO YOUR PERSONAL DATA
You can exercise your rights as provided by applicable data protection laws.
To that end, SANOFI informs you that you are entitled:
- to have access upon simple request to your Personal Data – in which case you may receive a copy of such data (if requested), unless such data is made directly available to you, for instance within your personal account ;
- to obtain a rectification of your Personal Data should your Personal Data be inaccurate, incomplete or obsolete ;
- to obtain the deletionupon simple request to your Personal Data – in which case you may receive a copy of such data (if requested), unless such data is made directly available to you, for instance within your personal account ;
- to withdraw your consent to the processing of Persona Data processing without affecting the lawfulness of processing, where your Personal Data has been collected and processed on the basis of your consent ;
- to object to the processing of your Personal Data, where your Personal Data has been collected and processed on the basis of legitimate interests of SANOFI, in which case you will need to justify your request by explaining to us your particular situation;
- to request a limitation to request a limitation
- to receive your Personal Data for transmission from SANOFI to a third-party or to have your Personal Data directly transferred by SANOFI to the third-party of your choice, where technically feasible (data portability right allowed only where the processing is based on your consent)
If you would like to exercise any of these rights, please contact us as described in the “How to Contact Us” section below and we will take necessary steps to respond as soon as possible.
You may also file a complaint before a competent data protection authority regarding the processing of your Personal Data. While we suggest that you contact us beforehand, if you wish to exercise this right, you should contact directly the competent data protection authority.
HOW TO CONTACT US
SANOFI welcomes any questions or comments you may have regarding this App Privacy Policy or its implementation. Any such questions or comments should be submitted using the contact information below:
[email protected]
You can send any request pertaining to SANOFI’s use of your Personal Data to our Data Protection Officer at the following email address: [email protected]