The Company A. Menarini GmbH ("Company", or "we") takes its users' privacy very seriously and undertakes to comply in full with the applicable law (Swiss Data Protection Law and, if applicable, Regulation (EU) 2016/679 - hereinafter defined as the "GDPR", together referred as "Privacy Laws"). This document ("Privacy Notice") provides information on how the personal data collected by the Company through this website ("Website") are processed. If additional types of personal data are collected on specific websites, the privacy notices which are published there must be oserved, complementing this Privacy Notice.

The Data Controller is A. Menarini GmbH, Thurgauerstrasse 36/38, 8050 Zurich, Switzerland, dataprivacy@menarini.ch ("Data Controller"). The Company representative in the European Union and Data Protection Officer ("DPO") can be contacted at: dpo@menarini.com.

The following categories of personal data we may collect about you include:

• Personal contact information. This will only be collected if you wish to contact us and includes any information you provide to the Company that would allow us to respond to you, such as your name, postal address, e-mail address, social network details, or phone number. Depending on the nature of your request, we may also need your professional qualifications, the content of your request or reports and the additional data, which the Company may acquire, also from third parties, in the course of business.
• User account information. If you have registered to use a website of the Company with restricted access, we will collect your access information (user name, password and personal contact information).
• Health-related information. If you contact the Company concerning an adverse event possibly relating to the treatment of an illness (so-called pharmacovigilance case) we are legally obliged to collect and process such information.
• Information from computer / mobile device. Any information about the computer system or other technological device that you use to access one of our Websites or apps, such as the Internet protocol (IP) address used to connect your computer or device to the Internet, operating system type, and web browser type as well as version. If you access a Company website or app via a mobile device such as a smartphone, the collected information could also include, where permitted, your phone’s unique device ID, geo-location, and other similar mobile device data.
• Websites / communication usage information. As you navigate through and interact with our Websites, the Company uses automatic data collection technologies to collect certain information about your actions. This includes information such as: which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages. This information is captured using automated technologies such as cookies and web beacons, and is as well collected through the use of third party tracking for analytics and advertising purposes. You have among other things the right to object to the use of such technologies, for further details please see Cookie Policy.

• Personal contact information. We use your personal data for consumer service purposes, including responding to your enquiries. This typically requires the use of certain personal contact information and information regarding the reason for your inquiry (e.g. issue, product question / complaint, general question, etc.).
• User account information. This is used to manage access to restricted websites.
• Health-related information. If you contact the Company concerning an adverse event possibly relating to the treatment of an illness (so-called pharmacovigilance case) we are legally obliged to collect and process such information.
• Information from computer / mobile device and Websites / communication usage information. In accordance with applicable laws, the Company collects these merely for statistical purposes and in anonymous form in order to monitor the functioning of the Website and improve its performance. Such data is not collected to be associated with other information regarding, or for the identification of, users; however, such information, by its very nature, may enable the Company to identify users through processing and association with data held by third parties.
  Browsing data are normally deleted following processing in anonymous form but can be stored and used by the Company to detect and identify perpetrators of any computer offences committed to the detriment of the Website or using the Website.
  Without prejudice to this possibility and to the provisions of the Cookie Poilicy, the browsing data described above are stored only temporarily.
  • legal and regulatory requirements;
  • upon behest of the relevant prosecution authorities;
  • protecting its rights in the course of legal proceedings;
  • implementing the Code of Conduct of the Menarini group;
  • protecting of another legitimate interest of the company or a third party;
  • executing of a contract concluded with you. This also applies to the necessary processing procedures to carry out the pre-contract activities;
  • exceptional circumstances, in which your vital interests or those of a third party require a data processing.

• For legal reasons. The company processes your personal data (even without your prior consent) in case of / for the purpose of:

  Your data are processed using automatic and electronic instruments suitable to ensure full security and confidentiality.

The forms to be completed on this website require you to provide only personal data, which are strictly necessary to handle your communications and requests. Such Data are marked with an asterisk [*]. If you do not wish to confer these information we will not be able to handle your communication / request. Conversely, forms may also provide the possibility to provide personal data, which are not strictly necessary to handle your requests: providing such data is optional - failure to do so has no consequence.

This Privacy Notice applies only to the Website as defined above. Even though the Website may contain links to other websites (known as third party websites), please be informed that the Company does not have any influence on access or control over cookies, web beacons or other user-tracking technologies that may be active on such third party websites, on the contents and materials published thereon, or on their methods of processing of your personal data; for this reason, the Company expressly declines any liability for such matters. You should therefore verify the privacy notice of such third party websites and collect information about their terms and conditions and about how they process your personal data. This Privacy Policy applies only to the Website as defined above.

The computers and programmes used by the Company are set up in such a way to reduce the use of personal data to a minimum. Such data are processed only to the extent required to achieve the purposes indicated in this Privacy Notice, and will be stored for as long as strictly necessary for achievement of the specific purposes pursued - in any event, the criterion used to determine the storage period is based on compliance with time limits permitted by law and the principles of data minimisation, storage limitation or rational management of our records.

The Company undertakes to ensure security of your personal data and comply with provisions on security provided by law to avoid data loss, illegitimate or unlawful uses of data or unauthorised access to data. The Company uses many types of advanced security technologies and procedures intended to aid protection of your personal data; for example, personal data are stored on secure servers situated on premises with protected and controlled access. You can assist the Company to update and correct your personal data by communicating any change of address, qualifications, contact information, etc.

Persons belonging to the following categories are authorised to process your data:

• technical and administrative staff,
• IT staff,
• product managers, as well as other staff members who require processing the data for performance of their job duties.

The data can be communicated also in countries outside Switzerland or the EU ("Third Countries") to other companies of the Menarini Group for the same purposes and/or for administrative and accounting purposes.
Additionally, the data can be communicated, also in Third Countries, to:

• professionals, independent consultants - working individually or in partnerships - and other third parties as well as providers which supply to the Company commercial, professional or technical services required to operate the Website (e.g., provision of IT and Cloud Computing services) for the purposes specified above and to support the Company with the provision of the services you requested;
• third parties in the event of mergers, acquisitions, transfers of business or branches thereof, audits or other extraordinary operations as required by law;
• the Supervisory Board, based at the Data Controller's address, in the pursuit of its supervisory activities and for the enforcement of the Menarini Group Code of Conduct.

The mentioned recipients shall only receive the data necessary for their respective functions and shall duly undertake to process them only for the purposes indicated above and in compliance with data protection laws.

The data can furthermore be communicated to other legitimate recipients identified from time to time by the applicable laws.

With the exception of the foregoing, the data shall not be shared with third parties, whether legal or natural persons, who do not perform any function of a commercial, professional or technical nature for the Data Controller and shall not be disseminated.

The parties who receive the data shall perform processing as Data Controller, Processor or persons authorised to process personal data, as the case may be, for the purposes indicated above and in compliance with the applicable Privacy Laws.
Regarding any transfer of data outside Switzerland or the EU, including in countries whose laws do not guarantee the same level of protection to personal data privacy as that afforded by Swiss or EU law, the transfer shall always take place in accordance with the methods permitted by the Privacy Laws, such as, for example,

• on the basis of the user's consent,
• on the basis of the Standard Contractual Clauses approved by the European Commission, with the amendments of the Federal Data Protection and Information Commissioner („FDPIC“) by selecting parties enrolled in international programmes for free movement of data (e.g. EU-USA Privacy Shield), or
• operating in countries considered safe by FDPIC or the Swiss Federal Council and / or the European Commission.

You may at any time, if the necessary conditions are met, exercise the rights you have, notably those listed in the applicable Privacy Laws, namely:

• the right to obtain confirmation of the existence of any personal data related to you;
• the right to check the content, the origin, the veracity, the location (also as regards third countries);
• the right to obtain a copy;
• the right to request a correction;
• the right to object to the use for possible direct marketing purposes (as a whole or for specific actions or channels);
• the right to object to the use for possible direct contact;
• the right to request for erasure / destruction;
• the right to request a restriction of the processing;
• the right to data portability.

You may always withdraw your consent (however, this does not affect the legality of processing activities prior to revocation) and / or make observations on specific issues regarding processing operations of your personal data, which you regard as incorrect or unjustified by your relationship with the Company, or lodge a complaint with the DPO or the local competent data protection authority (for Switzerland the FDPIC).

We last updated this Privacy Notice on 01 September 2023. We may change our Privacy Notice from time to time in particular in the event of changes in the law or in the event of a Company business requirement. Please check this page occasionally to ensure you are aware of any changes that are adopted.

If you have any questions, comments or complaints regarding this Privacy Notice or the processing of your personal data, please contact us using the contact details provided at the beginning of this Privacy Notice.