Privacy Notice by Roche Pharma (Switzerland) Ltd
Last revised: March 2022
General Notice on Data Privacy
Roche appreciates the importance of protecting your privacy and thus attaches considerable significance to protecting your personal data. Roche has therefore taken the necessary steps to meet the data privacy requirements applicable all over the world and accordingly observes the
provisions of the EU and of Switzerland and the other applicable local laws, as well as the Roche Group directive on data privacy.
Roche Pharma (Switzerland) Ltd (“Roche”) is a company in the F. Hoffmann La Roche Group.
This Privacy Notice outlines the types of personal data Roche collects; the means by which Roche collects, uses or shares your personal data; steps Roche takes to protect your personal data; and the choices available to you regarding the use of your personal data.
This Privacy Notice applies to any Roche websites, online resources and communication tools (such as email, contact forms, chat messages and other online tools, e.g. for appointment scheduling) that refer to this notice. This notice does not apply to personal data that is collected via offline resources and communication tools, except in cases where such personal data is combined with personal data collected online by Roche. Our websites may also contain links to third-party websites. We do not support and are not responsible for the content of third-party websites or resources. Our Privacy Notice does not apply to the websites of suppliers who are not part of Roche even if you reach these websites via a link on our website. We recommend that you review the privacy policies of any third-party websites before providing any information.
Your personal data is only processed to the extent that is legally permitted and in observation of the applicable laws. We collect and process your personal data either on the basis of your consent, i.e. we will ask you for permission to use information relating to you for particular purposes, or to fulfil our legal obligations or on the basis of our legitimate business interests.
In connection with this Privacy Notice, “personal data” refers to all information that could be used to identify you personally, either directly or indirectly. This includes your name, address, e-mail address and phone number, for example.
This website is not designed or intended for use by children under the age of 13. We do not knowingly collect any personal data from anyone under the age of 13 without the prior, verifiable consent of a parent or guardian. The parent or guardian concerned is entitled, upon request, to view the information provided by the child and to demand that it be deleted. Moreover, all minors should seek permission from a parent or guardian prior to using or disclosing any personal data on this website or online resource.
Responsible Party and Contact Details
The responsible party is Roche Pharma (Switzerland) Ltd, Gartenstrasse 9, 4052 Basel, Switzerland.
You can reach us at the address provided above with the addition “c/o Data Privacy Coordinator” or by sending an email to email@example.com
We can collect your personal data on our websites, via online resources and communication tools. The personal data we may collect, by which you can be directly identified, includes your name, your contact details, your email address and other details in combination with this information. We may also collect certain personal data that does not directly identify you by name but could be used to identify the specific computer or device that accessed our website.
We process your personal data on our websites or online services for many reasons, including:
- to respond to your requests or inquiries;
- to complete a transaction;
- to manage a business relationship;
- to personalise your user experience;
- to perform website analytics and measure website performance;
- to track and monitor adverse effects and other activities related to pharmacovigilance; and
- to maintain the website, including for security purposes.
There are a number of functions on our websites or online services that require you to enter your personal data if you wish to use them.
These may be, for example, questionnaires, registrations or content sharing functions (i.e. “e-mail to a friend” links). Roche and its business partners (such as service providers or other third parties who provide certain services to Roche) collect this information about you only if you provide it to us voluntarily. Please be aware that certain features of these websites may not be available to you if you elect not to provide certain personal data. All personal data you provide to us will be used in accordance with this Privacy Notice.
The following sections outline each processing activity in greater detail, provide information on the various categories of data collected for each activity and state the legal processing basis for each of these activities.
Responding to Requests or Inquiries. Certain parts of our websites and online resources allow you to submit your personal data to us for various purposes. For example, you may submit a request for medical information, obtain information about a product, take part in surveys, book an appointment or subscribe to one of our mailing lists. If you subscribe to one of our eNewsletters, we will process the personal data that you voluntarily enter for this purpose to manage your subscription based on your stated preferences. You can cancel the newsletter subscription at any time. The Unsubscribe link for this is included in every newsletter. In these situations, we may use the data you provide in order to take the necessary steps to respond to your request. Depending on your request, we may collect your contact details (such as your name, postal address, telephone number, job description or any other details required to register you), your interests and preferences (such as products or areas) as well as any other information you provide to us. For more information about how Roche collects and processes personal data for Medical Information Requests, please refer to our Privacy Notice for Pharmacovigilance, Medical Information and Product Complaints.
Completing Transactions. On certain pages of our website we may collect personal data via fax or email to provide services you have requested, e.g. to manage your registration and participation at Roche events, to fulfil business relationships with you and to understand your interests and preferences. In these cases we may collect your contact details, the required registration details as well as a history of your previous transactions with us (such as previous orders and customer account details). If you purchase or order a product or service from us, we use this information to perform our agreement with you.
Managing Business Relationships With You. Your personal data is collected and used to help Roche select suitable therapeutics experts for its various medical and/or scientific engagements (including speakers at internal or external medical educational events, advisory boards, training, etc.). We use your personal data to send you information about our products, services or therapeutic areas that is relevant or corresponds to your preferences. This also applies to surveys and invitations. We may combine the personal data you provide to us with other information that we collect via our websites, online resources, communication tools, or from public sources on the internet or Roche offline records or which third parties have provided to us.
Personalising Your Experience. We can collect certain information about you, your preferences, and how you have interacted with us in the past in order to understand your interest in our products and services so that we can best serve you. This may include information about your contact and product preferences, languages, marketing preferences, as well as demographic data. If we collect these details in an automated way, we collect and process them based on our legitimate business interests. In other cases, we collect and process this information on the basis of your consent.
Website Analytics and Tracking. Where permitted by law, we may link personal data you provide with other information you have provided to Roche through our websites. As far as legally permitted, we may also link personal data that we have collected via our websites and online resources, with offline records and information kept by Roche that was provided to us by third parties, to analyse and better understand your needs, preferences and interests. You can find more information about this in the following section and in our Cookie-Policy.
Tracking and Monitoring Adverse Events and Pharmacovigilance. Certain parts of our platform may collect personal data relating to adverse events or other aspects of pharmacovigilance. This information is very important for public health and is used for the detection, assessment, understanding and prevention of adverse events or other medicine-related problems. We collect and process your information for these purposes in order to meet our statutory obligations. We may also be required, if applicable, to report the data to the regulatory authorities. For more detailed information on how we use and disclose personal data for the purposes mentioned please refer to our Privacy Notice for Pharmacovigilance, Medical Information and Product Complaints.
Operation and Maintenance of Our Websites. We use the respective information to secure our websites, network systems and other assets. This may include information concerning your IP address, geographic location, any resources you accessed and similar information.
Certain web browsers and other programs can be used to notify Roche if and how it or a third party are permitted to collect data about your online activities. Roche does not currently respond to such signals.
Recipients of Your Personal Data
We can share your Personal Data with Roche affiliates around the world. Our Roche affiliates use your Personal Data for the same purposes as we do. A list of Roche’s affiliates is available in the current Roche Annual Report which can be found in the Investors section of www.roche.com.
Furthermore, we may pass on your personal data to external third parties, e.g. service providers who perform various services on behalf of Roche, including market research institutes and event organisations for the following purposes:
- to help Roche execute its business transactions better;
- to conduct technical maintenance of our websites and other web platforms;
- to facilitate a merger, consolidation, transfer of control or other corporate reorganisation in which Roche participates, or pursuant to a financial arrangement undertaken by Roche;
- to respond to appropriate requests by legitimate government authorities, or where required by applicable laws, court orders or government regulations; and
- where needed for corporate audits or to investigate or respond to a complaint or security threat.
Transmitting Your Personal Data Abroad
All personal data that you provide to us when you use our website, online resources or in other communication tools, may be transferred to and stored in geographical regions in which other data privacy laws apply than in your country of residence. This may mean that your personal data may be sent to a country with less restrictive data protection laws than your own. Any such transfer will be conducted in compliance with applicable legislation.
For the transmission of personal data to a third country without an adequacy decision, we draw up contracts containing the standard EU contract provisions with business partners and service providers within the Roche Group. These provisions represent appropriate and suitable guarantees to ensure that the Swiss data protection laws are observed, in accordance with the decisions of the EU Commission of 27 December 2004 (2004/915/EC) and 05 February 2010 (K(2010)593) or in accordance with the decision of the EU Commission of 4 June 2021 (EU 2021/914), depending on which is applicable.
The length of time for which we will store your personal data depends on the purpose for which we have collected and are processing the data. In most cases, we retain the data for three (3) years following our last interaction with you. We may, however, retain your data for longer if we are legally required to do so. For example, reports relating to pharmacovigilance are kept for a minimum of ten years after the withdrawal of the product in the last country in which it was marketed.
According to the applicable legislation, you have certain rights relating to the use and processing of your personal data. Please note that if the data processing is based on your consent, you have the right to revoke this consent at any time. However, this does not affect the lawfulness of the processing that took place with your consent prior to your revocation of consent.
Roche and its business partners take reasonable steps to protect personal data we collect or receive through this website from loss, misuse, and unauthorised access, disclosure, alteration or destruction.
Nevertheless, Roche makes no guarantee as to the security of your personal data. We disclaim, to the fullest extent permitted by law, all liability and damages caused by loss, misuse or unauthorised access, disclosure, alteration or destruction. We recommend that you take all precautions available to you to protect the personal data you submit via our platform.
From time to time, Roche may revise this Privacy Notice. Any such changes will be reflected on this page. Roche recommends that you review this Privacy Notice regularly for any changes. The date on which this notice was last revised can be found at the beginning of this notice.