Privacy Policy
Laboratorios Servier de Colombia S.A.S, with tax identification number 900.639.312-1; Les Laboratoires Servier with tax identification number 1791780388001; and Servier Centro America y Caribe S.A., with tax identification number 1320561-1-610466, DV:02 (“SERVIER”)
We respect the privacy of everyone who uses the website (hereinafter referred to as “Our Site”) and only collect and use personal data in ways that are described here, and in a manner that is compatible with our obligations and your rights under the law. This Privacy Policy only applies to your use of Our Site.
- What data do we collect?
We may collect some or all of the following personal data from users of Our Site:
- Data that you give to usAs a provider of pharmaceutical products, Servier collects personal information reasonably necessary to carry out its business. The types of personal information we may collect are described below, depending on your interaction with us:
| Healthcare Professional | Member of the public |
This information is collected through some of the followings ways: direct contact, in response to product queries, in connection with providing product related information or services, conducting market research and purchasing such information from third party providers and conducting clinical research in accordance with clinical research guidelines and regulatory requirements. |
This information is collected through some of the followings ways: responding to your queries, participation in Servier’s patient support programs, reporting from your healthcare professional for pharmacovigilance management, conducting market research through recruitment and conducting clinical research in accordance with clinical research guidelines and regulatory requirements. |
| Service Provider | Wholesaler |
This information is collected through some of the followings ways: providing services to Servier, reporting for pharmacovigilance management and completing due diligence questionnaires. |
This information is collected through some of the followings ways: ordering Servier’s products, reporting for pharmacovigilance management and completing due diligence questionnaires. |
Servier will not collect sensitive information without your consent.
Servier will collect personal information directly from you where it is reasonable and practicable to do so. We may also collect personal information from third parties such as:
- Organisations that Servier engages to assist us to carry out our functions and activities (such as conference organisers);
- Healthcare providers or colleagues; and
- Online directory providers or providers of customer contact databases.
Servier may engage third parties such as data verification providers to provide services to us, which may include processing and validating personal information on our behalf.
- Data that we collect automaticallyfor statistical purposes using cookies: pages visited, dates and times of access, preferred content, operating system, type of browser used, type of hardware used, etc. It must be noted that our statistics cookies do not allow the personal identification of a natural person.
In accordance with the General Data Protection Regulation (GDPR), personal data means any information that can identify you directly or indirectly.
- How do we use your data?
Under the GDPR, our use of your personal data must always have a lawful basis. This may be because the data are necessary or because it is in our legitimate business interest to use them.
Your data may be used for the following purposes:
- General sales and marketing and providing information about Servier products and services or those of third parties which may be of interest to you;
- To manage our patient support programs and other similar programs;
- To plan conferences, events and seminars including to organize travel to such events and accommodation and invite speakers and attendees;
- To help Servier research the needs of its users and to market its products and services with a better understanding of individual needs and the needs of users generally;
- To conduct clinical trials and research in accordance with clinical research guidelines, regulatory requirements and ethical principles;
- To establish and run medical boards or to acquire general opinions or publications on medical, scientific, clinical research and patient related issues;
- Administering conferences, symposia, expert panels, webinars, seminars or other similar programs organized by us, which you agree to participate in or be involved with, including any recordings; manage, review, develop and improve our business and operational processes and systems;
- Manage, review and resolve any regulatory, government or other medical authority matters, notifications or requirements (including adverse event reporting);
- To recruit and manage human resourcing requirements and needs;
- Manage relationships with Servier suppliers and vendors;
- Communication and relationship management and promotional and non-promotional activities with healthcare professionals including interactions (eg through our social media accounts and websites), profiling activities, contract management, congress and meetings management and databases;
- Pharmacovigilance and medical management which includes maintaining a record of medical queries, complaints and adverse event or adverse reaction reports relating to our products and reporting these to relevant regulatory bodies, such as the Therapeutic Goods Administration, as may be required;
- To conduct due diligence with respect to our service providers;
- Managing, planning and arranging meetings between healthcare professionals and us, including our sales representatives;
- To gain insights in to how Servier’s products are prescribed and used in practice; and
- Generating customer lists for the purposes of market research;
- If applicable, complying with our transparency obligations to report transfers of value;
- Resolve any legal and/or commercial complaints or issues; and
- Perform any of our other functions and activities relating to our business.
In order to carry out the above purposes, Servier may disclose personal information to persons or organizations such as:
- Servier Head Office in France and its subsidiaries including those based in the US;
- Our in-licensed partner in Japan and its subsidiaries;
- Third party data verification providers who maintain and verify our company databases. Please note that such third party data verification providers may collect and disclose such personal information to their clients such as other pharmaceutical companies;
- Our agents and service providers such as mailing houses, conference organizers and suppliers;
- Our professional advisors;
- Healthcare professionals;
- Persons authorized by or responsible for the individual, including their agents and advisors;
- Government agencies including regulatory authorities, within or outside of Colombia, Ecuador and Central America and Caribbean; and
- Other parties to whom we are authorized or required by law to disclose information.
We do not further process the data in a manner that is incompatible with the purposes described above.
- What are your rights?
You have the right to request access and obtain information about your personal data; update, correct or delete your personal data; restrict or oppose (for legitimate reasons) the processing of your personal data by contacting the SERVIER Data Protection Officer (DPO):
by email, at the following address: Central America and Caribbean dataprivacy-panama@servier.com, or Colombia and Ecuador habeasdata-cep@servier.com.
Should you have any cause for complaint regarding our use of your personal data, you have the right to lodge a complaint with the competent data protection authority of your country.
- How long do we keep your personal data?
Your personal data collected by SERVIER are kept in a form that permits your identification for no longer than is necessary for the purposes for which the personal data are processed. More specifically:
- Personal data collected for audience measurement purposes are kept for 13 months;
- Personal data collected for research activities are kept in the information systems of the data controller, participating centre or healthcare professional taking part in the research until the study product is marketed or until 2 years following the last publication of the study results or, in the absence of publication, until the signature of the final study report. The data are then archived in paper or electronic form for a period in accordance with applicable laws and regulations;
- Personal data collected for pharmacovigilance activities are kept for 10 years after the relevant marketing authorisation has ceased to exist; the data are then deleted or archived in an anonymised form, unless otherwise envisaged by mandatory local regulations;
- Personal data collected for the management of medical information are kept for 3 years after your request;
- Personal data collected for scientific medical liaison with healthcare professionals are kept for 5 years after your last interaction with SERVIER, then are archived for 5 years and deleted;
- Personal data collected for managing relationships with healthcare professionals in connection with clinical trials are kept until the study product is marketed or until the final study report or until the publication of the study results. They are then archived in paper or electronic form for a period in accordance with applicable laws and regulations;
- Personal data collected for communication and relationship management and promotional activities (contacts with healthcare professionals) are kept for 5 years after your last interaction with SERVIER, then archived for 5 years and deleted;
- Personal data collected for transparency management are kept, archived and destroyed in accordance with applicable laws and regulations;
- Personal data collected for any other type of correspondence are kept for 13 months.
- How do we safeguard your personal data?
We have put in place appropriate and commercially reasonable technical and organisational security measures to store your personal data that we collect and keep confidential and to protect them against unauthorised or unlawful disclosure or access, accidental loss, destruction, alteration or damage taking into consideration the state of art of technology and the cost of implementation.
- Do we share your personal data?
Your personal data processed by Laboratorios Servier de Colombia S.A.S, Les Laboratoires Servier, Servier Centro America y Caribe S.A. will only be accessible by a limited list of recipients on a need to know basis or where required by law, including but not limited to:
- The departments and personnel of SERVIER and other legal entities of the Servier Group with a need to know.
- The suppliers and service providers of SERVIER, particularly those responsible for hosting the Site, producing the Site, who may be called upon to access the personal data of Users for purposes strictly necessary for their work.
- The competent authorities such as health authorities in certain legally-defined cases.
- Applicable law
The present policy is governed by Panamanian, Colombian and Ecuadorian laws. All disagreements shall be brought before the courts with jurisdiction of Panama, Colombia and Ecuador, depending on the country where the data subject resides.
Any application of the rules of conflict of laws which restricts full application of Panamanian, Colombian and Ecuadorian laws are consequently excluded hereby. Consequently, Panama, Colombia and Ecuador laws apply to all Users which browse the Website, and which use all or part of its functions.
In the event of a divergence between the information presented in the Spanish version of the Website and that presented in the English version of the said Website, the information presented in the Website’s Spanish version shall take precedence.