Privacy Notice by Roche Pharma (Switzerland) Ltd

For data processing according to this Privacy Policy, the following company is the "controller", i.e. the body primarily responsible for data protection: Roche Pharma (Switzerland) Ltd, Grenzacherstrasse 124, CH-4058 Basel, Switzerland

If you have any questions about data protection, please contact: Roche Pharma (Switzerland) Ltd, ℅ Data Privacy Coordinator, Bau 1 / 25.S, Grenzacherstrasse 9, CH-4058 Basel or

It may be that you send someone else’s details to us (e.g. authorized representatives, deputies). In this case, we assume that these details are correct and that you are authorized to send them to us. Since we often do not have direct contact with these individuals and cannot inform them directly about our data processing, we ask you to inform them about our data processing (e.g. by referring to this Privacy Policy).

We process your personal data in different contexts for different purposes. Select the context you are interested in when Roche processes your data. 

The personal details that we process from you come from different sources:

• Transferred data: Personal data that you voluntarily provide to us when you transmit data to us or communicate with us (e.g. contract, communication, preference data)  

• Collected data: Personal data that we collect about you either through direct interactions (e.g. physical or virtual meetings) or automatically through your use of our websites or online resources

• Data obtained: Personal data obtained from third parties or publicly available sources, including websites, social networks, journals and third-party platforms.

Roche Pharma (Switzerland) Ltd operates several sites under different domains. This Privacy Policy applies exclusively to Roche websites that refer to this policy. 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.

We may collect personal data from you on our websites. Personal Data that we may collect that directly identifies you include your name, contact details, email address and other information in combination with these data. We also may collect certain Personal Data that does not directly identify you by name, but could be used to identify that a specific computer or device has accessed our website. 

Several places on our website require you to provide your Personal Data if you choose to use them, including surveys, registration, and content-sharing features (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 voluntarily provide it to us. Please be aware that certain features of this site may not be available to you if you elect not to provide certain Personal Data. Any Personal Data you provide to us on our websites will be used in accordance with this Privacy Policy.

This website is not designed or intended for use by children under the age of 16. We do not knowingly collect any Personal Data on this website from anyone under the age of 16 without the prior, verifiable consent of a parent or guardian. Such parent or guardian may have the right, upon request, to view the information provided by the child and require that it be deleted. Moreover, all minors should seek their parent’s or guardian’s permission prior to using or disclosing any Personal Data on this website or online resource.

We process your Personal Data on our websites for many reasons, including:

1. Registration or Responding to Requests or Inquiries
   We may use the information you provide to take the necessary steps to respond to your request, such as when you make a medical information request, inquire about a product, create an account, log on to our platforms, or subscribe to one of our mailing lists.

   Depending on your request or as part of the registration process, we may collect your contact information (such as your name, postal address, telephone number or job title), your interests and preferences such as products or areas of interest to you, and any other information (your settings) that you provide to us. For more information on how personal data is collected for medical information requests, please refer to our
   
   

2. Completing Transactions
   Some parts of our website may collect your Personal Data to fulfil services that you have requested and to understand your interests and preferences. In these instances, we may collect your contact information as well as a history of your previous transactions with us (such as order history, customer account information). We use this information to fulfil our agreement with you.
   
   

3. Personalizing Your Experience
   We may 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, and demographic data.
   
   

4. 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. Where permitted by law, we may also combine Personal Data collected through our websites and online resources with Roche’s offline records and information provided to us by third parties. You can find more information about this in the section below and in our
   
   

5. Tracking and Monitoring Adverse Events and Pharmacovigilance
   Some specified parts of our websites may collect Personal Data related to adverse events or other activities related to 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. For more information about how we use and disclose Personal Data for these purposes, please see ourWe collect and process your information to comply with our legal obligations and may be required to report the data to regulatory authorities.
   
   

6. Operation and Maintenance of our Websites
   We automatically process connection-related data to secure our websites, network systems, and other systems. For technical reasons, certain log files (log data) are generated during each use of our websites and are temporarily stored. This may include information concerning your IP address, geographic location, any resources you accessed and similar information.

Our websites and online resources also capture other basic information about you which does not directly identify you but which may be linked to you or a specific device. We use some of this information to enable our websites to operate, as well as to learn more about how our websites and online resources are used and to otherwise improve and manage the website. We also use this information to enable us to deliver information tailored to your interests and preferences, based on your use of the site. For example, we may collect the IP address assigned to your computer by your internet service provider. This address may change each time you connect to the internet (a "dynamic" IP address), or it may remain the same (a "static" IP address). In most cases, we collect this information automatically. You will find more information about the types of cookies and other tracking technologies we use and for which purposes in our

Certain web browsers and other programs may 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.

We will not sell or transfer your personal data to any non-affiliated entity for their own direct marketing purposes unless we have provided clear notice to you and obtained your explicit consent. We use third party advertising companies to place adverts on other websites. These companies may use data about your visits to this and other websites in order to measure advertising effectiveness and to provide advertisements about our goods and services that may be of interest to you. If you would like more information about this practice and your choices to opt out of having this information used by these companies, see our

Roche, service providers and cooperation partners take reasonable steps to protect your personal data we collect or receive through this website from loss, misuse and unauthorized access, disclosure, alteration or destruction. Nevertheless, Roche assumes no liability for the security of your personal data. We disclaim, to the fullest extent permitted by law, all liability and damages caused by loss, misuse or unauthorized access, disclosure, alteration or destruction. We recommend that you take all the security precautions you have at your disposal to protect the personal data you submit to this website.

1. Contact, inquiries and communication (email, chat, contact form, personal contact)
   You can contact us in various ways, e.g. by e-mail, chat, by filling in a contact form or in person, e.g. at a trade fair or at an event, or by telephone. We process the personal data you provide (contact data, company/practice, profession), the communication or request content, as well as information about the type, time and, if applicable, the location of the communication, for the purpose of processing the query or for carrying out the communication. You can also book an appointment with an employee using Google Calendar, or you can contact your Roche contact directly. For appointments, we will contact you directly or will commission a company to do so on our behalf. The service provider will receive your contact details from us and will collect any appropriate information that you provide when booking the appointment (e.g. questions, comments).
   
   

2. Reporting and tracking of suspected adverse reactions (pharmacovigilance), medical inquiries and product complaints
   If you contact us to report a possible side effect of a Roche medicinal product, if you have a medical or pharmaceutical question or a question or complaint relating to a Roche product, we will process the personal data you provide. We process your personal data for the purpose of reporting and tracking suspected adverse reaction cases (pharmacovigilance) on the basis of legal requirements and further regulations (GVP) (contact data, affiliations/profession of the reporting person, information on the suspected case, any additional information on health data of the person affected by an adverse reaction), to answer your medical or pharmaceutical inquiry and to store it in our information database (contact data, affiliations/profession of the reporting person, possibly further information on the inquiry), to process a product complaint and to fulfil legal requirements (contact data, affiliations/profession of the reporting person, information on the suspected case, additional information required to assess the complaint). If you give us feedback on how Roche handles your request or request, we will collect your feedback to improve our service quality.

   The data in this context are stored in central systems of the Roche Group. They are shared with business partners or service providers if this is necessary to maintain Roche's central databases and comply with legal requirements. We are also obliged to pass on relevant information regarding pharmacovigilance and product complaints to health authorities worldwide. The reports to the authorities will contain details of the respective incident, but only limited personal data. In the case of patients, for example, age, year of birth and gender, but not the patient’s name, are provided. The reporting persons will pass on the information (contact details, profession), if you provide said information, in order to allow the authorities to contact you with inquiries. Please also note the
   
   

3. Marketing communication (information letters, newsletters, etc.)
   We process your contact data for the purpose of sending marketing communications, direct mail advertising or telephone campaigns. We will send you electronic newsletters if you have consented to receive the newsletter or if you have registered for this purpose. You can unsubscribe from our newsletters at any time. We process tracking information (e.g. information about your IP address, browser, whether the newsletter was opened and which links were clicked on) to measure the success of our marketing communication at an aggregated level so that we can provide all recipients with the most relevant content possible.
   
   

4. Events, virtual meetings, webinars, etc.
   We collect and process your necessary personal data to carry out events, virtual meetings, webinars, etc. In this context, we process your data for the purpose of inviting, organizing and carrying out the event and accompanying communication (e.g. sending webinar content, gathering feedback). If it is necessary for the organization, we may pass on your data to accommodation and event venues; this is usually evident from the invitation. We conduct events with and without recording of voice and text inputs as well as video and image. If records are to be made available to a broader public, the exact purpose will be communicated to you when you consent to the recording.
   
   

5. Roche social media presence (Facebook, LinkedIn, Instagram, Twitter)
   Roche maintains an online presence on social media and on social networking platforms. We process your personal data as long as you interact with us via the respective network, i.e. write messages or posts, for the purpose of processing inquiries and communication or for fulfilling legal reporting obligations in the area of pharmacovigilance, see also the "Reporting and tracking of suspected adverse reactions (pharmacovigilance), medical inquiries and product complaints" section. In principle, we do not receive any information about you from the provider of the social network; with regard to usage statistics, we only receive aggregated data that cannot be used to identify individuals. Please note that the social network platform will processes data relating to your visit to enable you to use it as well as for other purposes mentioned in the Privacy Policy of the provider. We process and store your data only for as long as this is necessary to achieve the respective purpose and to fulfil our contractual, legal or regulatory obligations. We will only delete entries made by you if they have content that violates laws or the platform's Terms of Use. You usually have the option to delete the post yourself. We delete messages at regular intervals as long as this is permitted by the respective social network and as long as there is no legal obligation to store them in individual cases.
   
   

6. Social media monitoring and listening
   We monitor social networks to identify trends and issues that are relevant to Roche, especially to detect adverse events and for marketing and public relations purposes.  Roche monitors its own online presence both by means of personal inspection and automatically with the aid of technical solutions ("social media monitoring"). In addition, Roche uses technical solutions to automatically evaluate content from other publicly available sources on the Internet, in particular social media, news sites and blogs, to identify trends and issues of relevance to Roche, particularly on the basis of keywords ("social media listening"). Only publicly accessible sources are used. In particular, no blogs, websites or closed user groups that require a login are evaluated. The data recorded in this context are generally only stored temporarily and used in aggregated form, i.e. without identifying individual persons. In specific cases, however, individual persons may be identified and their data processed on the basis of the recognized content. This is the case when Roche encounters processes in which Roche is legally obliged to report to the authorities, in particular in the event of recognized adverse events related to the use of a Roche medicinal product (pharmacovigilance) or medical devices. If we store or process your data in an identifiable way in this context, you will be informed separately.
   
   

7. Market, opinion and customer satisfaction surveys
   In order to gain experience and opinions in connection with our products and services, we carry out market, opinion and customer satisfaction surveys. In this context, we collect and process the information you provide, in particular your opinions on products and services (survey content). Service providers may also carry out surveys, but they will indicate that the survey is being conducted on behalf of Roche, especially if the survey report identifies you. However, Roche may only receive an anonymized, aggregated report which will not identify you. In these circumstances, you may not be informed that Roche is the client.
   
   

8. Contract/cooperation partners
   We process your personal data if you are in contact with us in a business relationship, i.e. as a contract or other cooperation partner (or as a representative in a patient organization). Processing is necessary and in direct connection with the initiation, management and processing of contracts, supplier management or accounting, and this includes in particular contact data (e.g. name, address, professional email, company/practice/organization, function/position), contract data (e.g. content of the business relationship, data on participation in events and training, payment and bank information, order and transaction history, registration data) and interaction data (e.g. data on contact preferences, with regard to products, languages, and contact made and planned). We may also process personal data from our service providers and suppliers to document any necessary training and for quality control.
   
   

9. Medical professionals (Health Care Professional), customers, business partners
   We process various personal data relating to your profession, as we keep you in our database as a business partner, customer or healthcare professional. Even if there is no business relationship with Roche yet, we may include your professional contact details and your specialization in our database based on your area of expertise. The data that we process specifically and for which purpose we use it is also determined by the contracts and services agreed between us. Please refer to the
   for details on the purposes for which Roche may process your personal data (such as contact information, professional information, financial/transaction information, donations, information on interactions, profile data or usage data and technical data).

   We collect your professional contact data directly from you or receive it from a specialist service provider (SM Service Marketing AG, Switzerland). We may disclose personal data to service providers, in particular to our logistics service provider of our products (Alloga AG, Switzerland), market research institutes, event organizers or third parties tasked with providing certain services for Roche.
   
   

10. Applications
    Please apply exclusively via the RocheYou can find information on how Roche handles your personal data in this context on the portal. Roche will use the personal information you provide to decide whether to enter into an employment relationship with you.
    
    

11. Visit to our site (visitor management)
    When you visit our site, we process your personal data (these may be contact data, and where relevant car registration plates, visiting data, image and video recordings on the site premises) for visitor management purposes. We collect and process your data directly from you, via your Roche contact person or your employer, provided you are working as an authorized third-party company for Roche or are registered as a visitor.

Your personal data will be processed exclusively to the extent permitted by law and in compliance with applicable local laws. Depending on the purpose of data processing, we may rely on different legal bases. We may process personal data in particular if the processing

• is necessary for the performance of a contract or for pre-contractual measures;

• is based on consent;

• is necessary to comply with legal requirements;

• is necessary for the exercise of legitimate, business-related overriding interests.

We may share your personal data with Roche companies worldwide. Our Roche affiliates use your Personal Data for the same purposes as we do. The current Roche Financial Report, which you can find in the Investors section of our website (www.roche.com)contains a list of Roche companies.

We may also forward your personal data to third parties outside the organization or unit area, for example to service providers who provide different services on behalf of the organization or unit area, for the following purposes:

• to enable or improve the performance of business transactions by the organization or unit;

• for technical maintenance of our websites and other web platforms;

• to facilitate mergers, consolidations, transfers of control or other corporate restructuring involving the organization or entity or resulting from a financial arrangement by the organization or entity;

• to respond to legitimate requests from authorities or as required by applicable law, court orders or official regulation;

• where needed, for corporate audits or to investigate or respond to a complaint or security threat.

Any personal data that we collect and process may be transferred to and stored in geographical regions where different data protection rules apply than in Switzerland. This means that your personal data can be transferred to (third) countries whose data protection laws are less stringent than in Switzerland.  Any such transmission will take place in accordance with applicable law.

Not all of these countries have adequate data protection. We conclude contracts, in particular the "standard contractual clauses" of the European Commission and the Swiss supervisory authority of 04 June 2021 (EU 2021/914), to compensate for the lower level of protection. In certain cases, we may also transfer personal data in accordance with data protection requirements without such contracts, e.g., if you have consented to the corresponding disclosure or if the disclosure is necessary for the execution of the contract, for the establishment, exercise or enforcement of legal claims or for overriding public interests.

We process your personal data

• as long as it is necessary for the purpose of processing, 

• as long as we have a legitimate interest in the storage and 

• as long as data are subject to a legal retention obligation

At the end of these periods, we delete or anonymize your personal data. 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.

You have the following rights with regard to your personal data under the prerequisites and within the scope of applicable data protection law:

• the right to information about your personal data held by Roche Pharma (Switzerland) Ltd;

• the right to correct inaccurate or incomplete personal data or to supplement with a statement of disagreement

• the right to receive a copy of certain personal data in a structured, commonly used and machine-readable format, as long as the corresponding processing is based on your consent or is necessary for the fulfilment of the contract.

• the right to object to the processing of your personal data 

• the right to delete or anonymize your personal data

• the right to restrict the processing of your personal data 

• the right to withdraw consent, as long as we process personal data on the basis of your consent. The revocation is only valid for the future, and we reserve the right to continue to process personal data on a different basis in the event of a revocation. 

If you wish to claim a right, please do not hesitate to contact us (section 1). As a rule, we must check your identity (e.g. by means of a copy of your ID). You are also free to submit a complaint against our processing of your data to the competent supervisory authority, in Switzerland to the Federal Data Protection and Information Commissioner (FDPIC).

Roche may revise this Privacy Policy from time to time. Any such changes will be reflected on this page. Roche recommends that you review this Privacy Policy regularly for any changes. The date of the most recent revision is at the beginning of this policy.