PRIVACY AND COOKIE NOTICE
This privacy and cookie notice (“Notice”) is provided by Teva Pharmaceutical Industries Ltd. and its affiliates (collectively, “Teva“). You can view a list of all the Teva affiliates at the following website: https://www.tevapharm.com/contact-us/. Teva is referred to in this Notice as “we”, “us” and “our.”
The identity of the controller of your data, if any, will have been provided to you at the time we started processing your data and can be found in any documents you have which relate to your relationship with us. If you are unsure or would like to confirm which Teva entity is the controller of your data or which of the processing activities apply to you, please contact us using the details below.
1. Scope of this Notice
This Notice applies to most of our general processing of personal data, including when you interact with us as a customer, supplier, healthcare professional or other general member of the public, as the case may be. However, there may be specific scenarios in which a different Privacy Notice is provided to you by us or on our behalf, including for example, if (i) you report adverse events, quality, medical inquiry or other related compliant/communication to us, or (ii) we have specific obligations to record and report “transfers of value” in accordance with transparency requirements, or (iii) you are applying for a position of employment with us.
This Notice describes how we use your personal data, and your data protection rights, including, where applicable, a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Your rights” section.
This Notice applies to personal data we collect through:
- Sites and digital properties
We process your personal data when you visit or use our websites, and other digital properties (such as apps) or platforms (each, a “Site”).The data we collect may include device and network activity information, such as your device type, IP address, device or user identifiers, operating system, internet service provider, the date and time of your website use, information about the links, emails or features or content you interact with, and other log information. We also may receive error-reporting information in the event of a technical error, including the device or software type and version, the time the error occurred, the feature being used, the state of the device or software when the error occurred, and any communications or content provided at the time the error occurred.For Sites where you create an account (for example to access pharmacy ordering), in order to manage your account we may collect information which identifies you, including your contact details and an account username and password, and details of the business or organisation linked to the account.Our Sites may include links to other websites or organisations over which we have no control. Teva is not responsible for the privacy policies or practices of other websites or organisations. If you access these websites via our Sites, you should review the privacy policies of those sites so you can understand how they collect, use and share your personal data.In particular, Teva websites use YouTube API services to display videos. This third party service has separate and independent privacy policies and/or Terms of Service shown below:
- YouTube API Services Terms of Service (https://www.youtube.com/t/terms)
- Conflict of Interest Checks
We will process your personal data if one of our employees has declared a potential conflict of interest (i.e. any situation in which personal, social, financial, political or other interests are placed before those of Teva) that concerns you.
- Healthcare Professionals
Teva collects information about healthcare professionals/experts when you interact with us or our representatives. As well as personal identifiers, including contact details, we collect professional and employment-related information (including professional title, employment institution, credentials and interests). We also maintain records of our communications and meetings with you.Teva also collects personal data from a number of third party data sources, in particular from publicly available sources such as public registers of healthcare professionals, published journals and event materials and from websites of healthcare professionals or their employers. Teva collects and process such publicly available data only to the extent where the purposes for such collection and processing are compatible with and correspond to the initial purposes for which the respective data are made publicly available. Teva also specially makes use of third party data providers to enhance its own knowledge of the healthcare sector. This data will include information about your role(s), your qualifications, your speciality, your employer, your experience, your publications and other information related to your profession.
- Suppliers/vendors and customers
When you engage with Teva as a supplier/vendor, customer or personnel to supplier/vendor, customers, we will process your personal data, including your name, personal identification number, professional contacts, business bank account details and other related information and financial information. We will also maintain order/payment data, survey responses where applicable, and other appropriate records of our interactions with you.
- Facilitators, trainers, educator and speakers at Teva events
We collect and process information about you in relation to engaging you to speak at one of our events or appear in content that we produce.
2. How We Use Your Information
We process the personal data we collect in relation to our Sites for the following purposes/legal bases:
We process your personal data when it is necessary for the performance of a contract with you, or where you have requested us to take steps prior to us entering into a contract together, in particular:
• to fulfil any of our obligations owed to you under such contract such as to manage your orders, arrange the provision or receipt of goods and services, and to make payments to you for services provided, the reimbursement of expenses or rebates;
• where applicable, to manage information related to your attendance at an event, for example, your dietary requirements; and
• managing orders, questions and complaints regarding products where you have placed orders, posed questions in relation to orders, or submitted complaints.
b. Legal obligation
We process your personal data to meet legal (including tax and accounting), regulatory, pharmacovigilance, quality, medical inquiry and compliance requirements, including:
• to respond to requests for information from government authorities;
• to comply with all legal and self-regulatory obligations including transparency and disclosure obligations or anti-gift obligations (this may either be in our legitimate interests or a legal obligation);
• to manage and respond to requests concerning quality or medical information (this may either be in our legitimate interests or a legal obligation);
• prior to entering into a personal services contract with you, to check that your professional expertise and experience match our identified need for that service.
• We may also process your personal data in connection with dispute resolution, legal claims, compliance, regulatory and such investigative purposes as we deem to be necessary (including disclosure of such information in connection with legal process or litigation). We maintain records of any consents, preferences or other settings to enable us to comply with data protection law
c. Legitimate interests
We also process your personal data when it is necessary for the purposes of our legitimate interests as a controller (or those of a third party). Please contact us for more information on our legitimate interests balancing tests using the contact information provided at the end of this Privacy Notice:
• to promote Teva’s goods and services including in relation to promotional and educational events for healthcare professionals;
• to educate and train Teva staff and promote their professional and personal development;
• to respond to your queries or other correspondence you have submitted through our Sites;
• to analyse engagement with our Sites, communications, events and services in order to improve content, optimise performance and enhance their relevance to various audiences;
• to optimise and tailor the use of our Sites and our communication to you;
• to detect, investigate, prevent or report activities that may violate our policies or be illegal;
• to carry out conflict of interest checks and assessments where you have been identified by a Teva employee as having a potential conflict of interest with us and keep records of the same to enable us to take appropriate action to remediate such conflicts;
• to develop and maintain our relationship with you and to better understand the healthcare sector;
• to contact you or otherwise provide you with information regarding Teva products or events (when your consent to receive direct marketing communications is not required);
• to tailor our communications to you based on your expertise and professional interests;
• to assess and analyse your interests and experience based on information our representatives collect during calls or visits;
• to carry out and follow-up training, including by providing you with further information, inviting you to symposia, congresses, seminars, debates and other events;
• to carry out or engage in market research, scientific cooperation or other research activities to better understand our markets and/or increase our expertise;
• to check that your professional expertise and experience matches our identified need for a particular service prior to entering into any personal services contract with you (to the extent that this is not a legal obligation as set out below);
• to manage our business relationship with you;
• to plan for, conduct and monitor our business in relation to our supplier/vendor or customer contracts;
• to handle any questions or complaints you may have about Teva or Teva staff
• to investigate allegations of misconduct; and
• for due diligence prior to setting up a trading account or in the circumstances of mergers and acquisitions, dispute resolution or audit.
Generally we do not rely on consent as a legal basis for processing your personal data. If you are an individual, however, we may ask for your consent prior to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
If we require your consent to process your personal data in any other circumstances we will contact you separately to request such consent.
3. Sharing Your Personal Data
Teva discloses your personal data to the following categories of recipients (in all cases, only when necessary to fulfil their functions):
- our staff (including employees and external consultants), professional advisors and agents;
- other functions and companies in the Teva group of companies worldwide such as Teva Pharmaceuticals Industries Ltd. in Israel, Teva Pharmaceuticals Europe B.V., Teva Croatia (PLIVA HRVATSKA), Teva Romania and Teva Pharmaceuticals USA Ltd., who provide IT support, IT hosting and other group services such as HR, Finance, Compliance, Legal and other support. You can view a list of all the Teva affiliates at the following website: https://www.tevapharm.com/contact-us/;
- third party service providers which process your personal data on behalf of Teva and who are bound by contractual obligations to keep your personal data confidential and appropriately secure, such as:
- IT support, website hosting, CRM hosting, event management and analytics providers;
- in the case of supplier personal data: administrative, consultancy and logistical support service providers
- investment houses for the purposes of benefits management, training providers, inquiry and other database hosting and support; and
- various HR, travel and administration services
- government authorities (including tax authorities), regulatory agencies and law enforcement officials, if required for the purposes specified above, if mandated by law, or if required for the legal protection of our legitimate interests in compliance with applicable laws;
- if you are a healthcare professional, relevant regulators as required, such as EMA and pharmaceutical self-regulatory bodies such as EFPIA in Europe;
- our third party sources of personal data where we need to confirm and have agreed to assist them with the accuracy of information (for example, if you are a healthcare professional, we may share personal data with our third party sources where we become aware that you have moved to a new role);
- in relation to the performance of our relations, the protection of our legitimate interests or the compliance with our legal obligations, we may disclose your personal data to service providers such as banks, postal service providers, lawyers, auditors, etc. When dealing with such providers, we require them to strictly comply with all applicable data protection rules and laws, as well as the specific rules applicable to their activities and the protection of the information they process in the course of such activity;
- if you are a pharmacy customer, your nominated wholesaler;
- in the event that the business is sold or integrated with another business, potentially our advisers, any prospective purchaser’s advisers and any new owners of the business and third parties (and their advisors) with whom we merge with or acquire in future.
4. Cookies and Related Tracking Technologies
Teva uses the following categories of cookies on the Site:
Category 1: Strictly Necessary Cookies
These cookies are necessary for the Site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Site will not then work.
Category 2: Performance Cookies
These cookies collect information on how people use and interact with the Site. We use these cookies to help us understand how users arrive at the Site, browse or use the Site and highlight areas where we can improve such as navigation, user experience and marketing campaigns. Where these are used in emails we use them to understand whether an email was opened, clicked on or sent to spam, time stamps of the above actions, and what device was used. This helps us to understand your level of interest and engagement with the information we send to you. The data collected can be combined with other data we collect to improve how the Site works and the quality and relevance of the information we sent to email recipients. For example we use Google Analytics to better understand how users use the Site. If you don’t want Google Analytics to be used in your browser, you can install this Google add-on: https://tools.google.com/dlpage/gaoptout?hl=en_GB..
Category 3: Functionality Cookies
These cookies are set to enhance functionality and personalisation on the Site. These can then be used to provide you with an experience more appropriate to your selections and to make your visits to the Site more tailored. The information these cookies collect may be non-directly identifiable
Category 4: Social Media Cookies
These cookies are used when you share information using a social media sharing button or “like” button on our Platforms, or when you engage with our content on or through a social site such as LinkedIn or Twitter. These cookies collect information about your social media interaction with the Site, such as whether or not you have an account with the social media site and whether you are logged into it when you interact with content on the Site. This information may be linked to targeting/advertising activities. Please see the “Third Party” section below for more information on social media platforms placing cookies on our Sites.
Category 5: Advertising cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with our permission. They remember that you have visited the Site and this information is shared with other organizations such as advertisers.
Where we place cookies directly, we typically keep information collected from cookies for a maximum of 6 months.
- Google Analytics
Managing these technologies:
If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. If you would like to avoid cookies (web beacons) in your emails, you may refer to your settings in your email reader program and disable the functionality that enables remote images to load and by refraining from clicking on links.
Information on deleting or controlling cookies is also available at www.allaboutcookies.org. Please note that by deleting our cookies (or disabling future cookies) you may not be able to access certain areas or features of Sites.
5. How We Store Your Information
If we have a contract with you, your personal data will be retained for the duration of your contract and for an appropriate duration after its termination in your country to protect us from any legal claim.
Otherwise, your information will be retained for two years, or as reasonably necessary for the purposes set out above, in accordance with applicable laws. For more information on your particular circumstance, please contact us using the contact information listed below.
6. Additional Information on Your Rights
You may be entitled under applicable law to ask Teva for a copy of your information, to correct it, erase or restrict its processing, or to ask us to transfer some of this information to other organisations. You may also have rights to object to some processing. These rights may be limited in some situations – for example, where we can demonstrate we have a legal requirement to process your personal data.
Where you have consented to the processing of your data, you may withdraw such consent at any time. You have an absolute right to opt-out of processing for direct marketing purposes at any time. You can do this by following the instructions in the communication where this is an electronic message or by contacting us using the details set out below. For certain Sites, you may also have an ability to change some marketing preferences online.
7. International Transfers
Teva operates internationally and will transfer your information to the recipients set out in the ‘Sharing Your Personal Data’ section. When transferring information outside your country Teva follows local privacy legislation.
For Europe (including UK and Switzerland): When transferring personal information to Israel, Teva generally relies on the European Commission’s (or local equivalent) adequacy decision with respect to the transfer of personal data to Israel; when transferring personal information to other countries outside the EEA that are not subject to an “adequacy decision” by the EU Commission (or equivalent), Teva generally relies on EU Commission approved standard contractual clauses. Information on the relevant mechanism can be provided upon request to Teva Privacy Office (contact information below).
8. Data Protection Queries – Contact Us
If you have any concerns about how we process your personal data or wish to exercise any of your rights or wish to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with Teva Data Protection Office by contacting us:
For Europe, you can contact us at EUPrivacy@tevaeu.com.
For the United States or Canada, you can contact us at USPrivacy@tevapharm.com.
For other regions, please contact us at IL_Privacy.Tevail@teva.co.il.
We hope that we can satisfy any queries you may have about the way in which we process your personal data. However, if you have unresolved concerns you also have the right to complain to the data protection authority in the location in which you live, work or believe a data protection breach has occurred.
9. Changes to this Notice
This Notice may change from time to time. Teva will place an updated version of the Notice on this page and may otherwise communicate changes as appropriate.
10. Additional Notice to California Residents
This section supplements the description of our information collection and sharing practices elsewhere in this Privacy Notice to provide certain disclosures to California residents whose personal information Teva processes pursuant to the California Consumer Privacy Act (“CCPA”). Please note that these disclosures do not apply to information that is not subject to the CCPA.
Teva may collect personal information from you directly, for example as part of a registration or in response to a questionnaire. Teva may also obtain personal information indirectly, such as from publicly available sources (e.g., websites or publicly accessible databases), third party vendors, healthcare providers and health insurance companies, and third-party partners and collaborators. We may combine personal information from multiple online and off-line sources. During the preceding 12 months, Teva may have collected, used, or shared personal information about you, including the following categories:
- Direct identifiers and contact information, including your name, address, phone number, or email address;
- Registration information, such as your username and password;
- Relationship data, including information about products, treatments and health conditions that are of interest to you;
- Transaction data, including purchases and inquiries;
- Financial account data, such as your credit card number;
- Income and demographic information, such as when you request financial assistance for one of our products;
- Health-related information, such as information about a health condition, safety and health information in relation to any of our products, or insurance and demographic information;
- Payment-related information if you provide a service to Teva.
We generally share personal information with third parties for the business and commercial purposes described above. We do not sell personal information to third parties.
Under the CCPA, California residents may have the right to request that a business that collects consumers’ personal information give consumers additional transparency and access to the specific pieces of personal information that the business has collected about the consumer. California residents also have the right to submit a request for deletion of information under certain circumstances. Please note that these rights are not absolute. For example, we may not delete information we are required to retain for regulatory reasons, certain internal business purposes, or where otherwise provided for by law. In addition, we will not respond to a request if we cannot verify you as the requestor.
Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you for additional information. If you would like to use an agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
Consistent with California law, if you choose to exercise your rights, we will not charge you different prices or provide different quality of services unless those differences are related to your information or otherwise permitted by law. Please submit your request by sending an email to USPrivacy@tevapharm.com or by telephone at 1-800-545-8800.