Privacy Policy

This policy (together with our Terms of Use, our Cookies Policy and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us by visiting our website. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.qarziba.com (the “Site”) you acknowledge that you have read and understood the practices described in this policy. This website is a promotional website operated by Recordati UK LTD. Its content is addressed only to Healthcare Professionals, located to countries where the product (Qarziba) is approved. For the purpose of the UK and the EU General Data Protection Regulation (GDPR) as well as any other applicable laws and regulations, the controller is Recordati UK LTD of Breakspear Park, Breakspear Way, Hemel Hempstead, Hertfordshire, HP2 4TZ.

Information we collect

A) In most cases, we will collect data directly from you (e.g., when you visit our website; you contact us). In particular, we will collect and process the following data about you:

• Information you give us about you in the following cases:
  • When you declare that you are a Healthcare Professional located to a country where the product (Qarziba) is approved, in order to access the site; and/or
  • When you contact us by corresponding with us through e-mail to report an adverse event and/or a product complaint (at the respective email address of the medical information department available in “Get in touch”) and choose to provide personally identifiable information. The information you give us are mainly contact details and may include, your name, address, e-mail address and phone number, as well as expertise area and relationship with the patient.

We will use the collected data for the purpose for which you provided it to us, such as to respond to your inquiry or to provide you with information that you have requested.

• Information we collect about you. With regard to each of your visits to our Site we will automatically collect the following information:
  • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), listening data (descriptions of the title, segments included in a resource, time and date stamps for download material and playback events, session IDs and information about the device or platform used to download or play a particular file); page response times, download errors, duration of page visits, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.

B) In some cases, we collect personal data about a patient in relation to a reported adverse event associated with that patient via the Healthcare Professionals that visit such Site and contact the Medical Information department through e-mail (at the respective email address of the medical information department available in “Get in touch”) to report such events. The personal data that we collect may be limited by national laws, but may include:

• Identifiable Data: initials or name and last name, age or date of birth;
• Biometric data: weight and height;
• Details of the product associated with the adverse event (including the dosage taken or prescribed, the reason for being prescribed the product and any subsequent change to the patient’s usual regimen), details of other medicines or remedies the patient is taking or was taking at the time of the adverse event, (including the dosage, the length of time the patient was taking the other medicine, the reason the patient was taking that other medicine and any subsequent change to the patient’s regimen), details of the adverse event experienced such as the outcome, causality, etiology and diagnosis, the treatment the patient received for that adverse event, and any long-term effects the event has had on the patient’s health;
• Medical data: information considered relevant, including risk factors and pregnancy and medical history or familial history considered relevant, including documents such as laboratory reports, medication histories and patient histories.

Recordati UK LTD is required by law to conduct follow-up enquiries on reported adverse events. We must therefore keep sufficient information about reporters (Healthcare Professionals) to allow us to contact them for additional information once we have received the adverse event report, as mentioned under section A. above.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our Site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

The legal basis for processing your personal data

In order to comply with applicable data privacy laws, we are required to set out the legal basis for the processing of your personal data. In accordance with the purposes for which we collect and use your personal data, as set out above, the legal basis for us processing your personal data will typically be one of the following:

• Your consent;
• Our own or our third parties’ legitimate business interests (for example, in maintaining and promoting our business by providing customers with feedback opportunities or other instances where we have carried out a legitimate interests assessment and have established an existing legitimate interest); or
• Compliance with our legal obligations, including reporting Adverse Events.

Uses made of the information

We use information held about you in the following ways:

• Information you give to us. We will use this information:
  • To provide you with the information, products and services that you request from us;
  • To support you access the collected resources and material as well as to listen or download the recorded videos and uploaded guides and booklets and other pdf material that might interest you;
  • To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
  • To notify you about changes to our service;
  • To ensure that content from our Site is presented in the most effective manner for you and for your computer.
  • To comply with legal or regulatory obligations and the directions of law enforcement agencies and court orders, such as in relation to reporting for the safety of information and product quality complaints. As part of our safety reporting obligations, we may use reporter’s personal data to investigate the adverse event, contact reporters for further information about the adverse event reported and process and analyze adverse event information received by Recordati UK LTD to support safety monitoring of the product, as well as report the adverse event to the respective regulatory authorities.
• Information we collect about you. We will use this information:
  • To administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • To improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
  • As part of our efforts to keep our Site safe and secure.

Disclosure of your information

We may share your personal information with:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.Selected third parties including:
• Selected third parties including:
  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • analytics and search engine providers that assist us in the improvement and optimisation of our Site (if you provide your permission to do so).

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If Recordati UK LTD or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers/ individuals interacted with, will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Recordati UK LTD, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Security and storage of your personal data

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy, applicable data protection laws and regulations as well as international security standards. The data that we collect from you is stored inside the European Economic Area (“EEA”) and accessed and used subject to our security policies and standards. All information you provide to us is stored on our secure servers. We have implemented reasonable physical, technical and managerial controls and safeguards to keep your personal data protected from unauthorised access, disclosure, alteration, and destruction. Your access to your personal data is limited to a restricted number of our staff whose duties reasonably require such information and third parties with whom we contract to carry out business activities on our behalf. Our staff has been trained on the importance of privacy and how to handle and manage personal information appropriately and securely. However, your information may also be transferred within or outside the EU/EEA where privacy laws may be less strict than in the EU-EEA/UK. In such case, we will implement reasonable and appropriate legal, technical and organizational security measures with the aim to ensure the security of the processing and in particular to protect your personal data from unauthorised access, use or disclosure. In the absence of an adequacy decision adopted by the European Commission or a competent data protection authority, we will implement appropriate data transfer mechanisms (such as the UK or EU Standard Contractual Clauses) for any cross-border data transfers located in a non-EU/EEA third country with the aim to secure such transfers and achieve an adequate level of data protection. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Records retention

We will keep your personal data for as long as we need it for the purposes set out above, and so this period will vary depending on your interactions with us. Data may be retained for a longer duration where applicable laws or regulations require, or allow us to do so. Where we no longer have a need to keep your information, we will delete it.

Records retention

We will keep your personal data for as long as we need it for the purposes set out above, and so this period will vary depending on your interactions with us. Data may be retained for a longer duration where applicable laws or regulations require, or allow us to do so. Where we no longer have a need to keep your information, we will delete it.

Your data protection rights

Under applicable data protection laws and subject to any legal restrictions, you may have the right to request us to: (i)access information held about you(ii) request access to all the personal data we hold about you; (iii) request that any inaccurate personal data we hold be corrected; (iv) to object to certain types of processing of your personal data we carry out (including the right to opt-out of any direct marketing); (v) request that we delete the personal data we hold about you; (vi) to request a copy of your personal data in a machine reasonable, commonly used format (or to request we transfer your personal data in such a format to a third party service provider); (vii) restrict certain aspects of the processing of your information and (viii) to stop a particular processing when you withdraw your consent. You can exercise these rights by writing to us or by sending an e-mail to privacy@recordati.com. For EU residents: In case we do not handle your request timely or if you are not satisfied with our response to any exercise of these rights, you are entitled to lodge a complaint with the competent supervisory authority of your place of residence. Further information and contact details of the European competent supervisory authorities can be found here. For UK residents: In the UK, the responsible Data Protection Authority for the management of public complaints is the Information Commissioner’s Office (ICO); you can contact ICO here: The Information Commissioner’s Office | Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF | Website: https://ico.org.uk | Tel. +44 1625 545 700 | Helpline number: 0303 123 1113. For non-EU/EEA residents: As per above, you are entitled to lodge a complaint with the competent supervisory authority of your place of residence.

Redirect to other web sites

Our Site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites as the terms in this policy apply solely to information collected by Recordati UK LTD.

Social media features

Our Site may also include social media or lead generation features, such as Facebook or Twitter buttons and widgets, such as the share this button. These features may collect your IP address, which page you are visiting on our Site and may set a cookie to enable the feature to function properly. Social media and lead generation features and widgets may be hosted by a third party. Your interactions with these features and widgets are governed by the privacy policy of the company providing it.

Changes to our privacy policy

Recordati UK LTD reserves the right to amend this policy from time to time to reflect technological advancements, legal and regulatory changes, and our business practices, subject to applicable laws. Any changes we make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@recordati.com.

Updated June 2024