We take your privacy very seriously and are committed to respecting it to the highest industry standards. For this reason, we would like to inform you about how A. Menarini GmbH, Thurgauerstrasse 36/38, 8050 Zurich, Switzerland, dataprivacy@menarini.ch (hereinafter the "Company" or "we"), in its capacity as data controller, processes your personal data ("Data") and ensures compliance with applicable data protection laws.

1. The purposes for which we process your Data

We process the Data that you submit to us, that you have already submitted to us in previous contacts, or that we collect about you for the following purposes:

So that we can contact you through various channels (visits, mailing, e-mail, telephone, social media) and provide you with the following information or work with you:

(A) "Scientific promotional materials", in accordance with applicable laws and the Pharma Code on professional advertising. This includes, but is not limited to, visits by our sales representatives to promote our product portfolio and/or inform you about our offers and products, etc.

(A1) If you wish, we may also send you the relevant scientific promotional materials via telecommunication channels (e.g. e-mail, telephone, social media). This includes, in particular, communications and updates on our latest campaigns, which may include information on our promoted product portfolio.

(B) "Institutional and non-promotional materials", e.g. the transmission of information, updates and news concerning the Company and/or the Menarini Group. This includes, in particular, updates on the company's social responsibility and sustainability, as well as news concerning the Menarini Group.

(B1) If you wish, we can also send you the relevant institutional and non-promotional materials via telecommunication channels (e.g. e-mail, telephone, social media).

(C) "Continuing medical education", in accordance with applicable laws and the Pharma Code on professional advertising. This includes, but is not limited to, invitations to events organised by us, congresses, webinars and invitations to third party congresses, which may contain, for example, information about our promoted product portfolio.

(C1) If you wish, we can also send you the relevant training materials via telecommunication channels (e.g. e-mail, telephone, social media).

(D) "Personalisation of information and promotional activities" ("profiling"), by identifying your needs, preferences and professional interests, if you provide your consent. In order to provide you with the best possible service, we take into account your preferences (in particular, behaviour in relation to e-mails, participation in events and visits) so that we can tailor our information and promotional activities relating to the materials referred to in (A), (B) and/or (C) to your needs. For these purposes, the digital communications sent to you and/or the digital materials displayed during the visit may contain so-called trackers through which we collect certain information. For example, with respect to digital communications, we may know if and when you opened and/or deleted the communication, what links you clicked on in the communication, your e-mail client, and certain anonymous and aggregated information about users' geographic areas. With regard to digital materials shown during your visit to our field service, we may know, for example, which materials you consulted/viewed, which of them you preferred, as well as the date and duration of the viewing/consultation. We process this information, for example, to monitor the effectiveness of our campaigns, digital communications and digital materials.

(E) "Making your services available" by entering into a collaboration with us to assist us with your expertise for certain defined events and projects, for the prior clarification of potential conflicts of interest for you or the Company, and for the performance of the services agreement.

In connection with our service platform [www.menarni-services.ch], we process your data additionally for the purposes stated below:

(F) "Making use of our offers" by registering for online education via our service platform or by ordering general service materials or product-specific information and advertising materials via our e-catalogue and having them delivered to your business address.

(G) "Use of online tracking" by recording your access to our service platform and tracking your user behaviour so that we can ensure the functionality of the service platform, optimise it and carry out evaluations and personalisations.

(G1) If you consent to the use of the corresponding categories of cookies by means of your selection in the cookie banner, cf. cookie policy [www.menarni-services.ch].

1. What Data we process

In connection with the purposes described above, we may process the following Data from you: (1) professional/academic title; (2) first name; (3) last name; (4) year of graduation; (5) gender; (6) primary visiting address, correspondence address and alternative address (house number, street, city, country, and e-mail address); (7) visiting hours; (8) business phone number; (9) business mobile phone number; (10) professional position (e.g. hospital doctor, general practitioner, nurse, pharmacist), (11) academic and professional qualifications and specialisations; (12) information regarding other activities (e.g. public or political office, member of drug commissions); (13) data related to scientific conferences and other symposia, including advisory bodies, in which professionals participate and which are financially supported by us (e.g. travel data and other booking-relevant data); (14) data relating to the administration of drug samples; (15) data relating to your use and/or viewing/consultation of our electronic/digital information materials; (16) other information arising from preferences expressed by you when interacting with us; (17) adverse reaction reporting; (18) quality defects and product complaints; (19) product/medication enquiries; (20) referral or consultancy contracts and contracts relating to participation in (online) training; (21) sponsorship enquiry forms; (22) IP address and other technical data; (23) Rx or DocCheck login.

We collect some of this Data from you or from publicly available sources, and some we receive from service providers.

The processing of your Data is necessary so that we can carry out our information and advertising measures. For this reason, we ask you to provide at least the data highlighted in bold above: If you withhold these, we will not be able to send you information and promotional materials.

1. On what basis we process your Data

If data protection laws require a legal basis, we rely on the following legal bases for the data processing operations described above:

(A) (B) (C) The Company's legitimate interest in contacting you and providing you with "promotional scientific materials" and "institutional and non-promotional materials" as well as providing you with access to "continuing medical education". In particular, our legitimate interest includes the following activities: Maintaining and nurturing the company's business/professional relationships with professionals who are existing professional contacts or who have expressed an interest in the services offered; creating individual customer profiles from feedback from professionals to our sales representatives and other information; organising and planning the company's scientific information activities; tracking/reporting the day-to-day activities of our sales representatives to professionals; and conducting statistical analysis on our information and promotional activities.

(A1) (B1) (C1) Your consent (if you give it to us) to receive "promotional scientific materials" and "institutional and non-promotional materials" and to be granted access to "continuing medical education" via telecommunications channels (e.g. e-mail, telephone, social media). In the event that you consent, we are committed to providing you with a simple and free opt-out option at all times. If you do not consent, we cannot send you such information and advertising measures by digital means.

(D) Your consent (if you give it to us) to enable us to personalise our information and promotional materials to match your needs, preferences and interests as closely as possible. For the same purposes, we may combine behavioural and preference data as well as master data and technical data associated with you to better understand you as a professional with your interests and other characteristics. If you do not consent to profiling, we will not be able to tailor our services to your needs, preferences and interests.

(E) The performance of a contract if we engage you as a speaker or consultant for certain projects/events and our legitimate interest in conducting business relationships in a transparent and responsible manner.

(F) The fulfilment of a contract if you make use of our services such as participation in (online) training courses, for which a cost contribution is incurred due to the duration and design, or orders via the e-catalogue on our service platform.

(G) Your consent (if you give it to us) to use techniques on our service platform that enable us to recognise you when you use it and, in some circumstances, track you across multiple visits, see Cookie Policy [www.menarni-services.ch].

In addition, we may also process your data without your consent in order to comply with legal or regulatory obligations and official orders (e.g. accounting for the dispensing of sample packs or traceability of medical devices), to assert or defend legal claims or to pursue other legitimate interests (e.g. to exchange data between the companies of the Menarini Group).

1. How we process your Data

The Data is processed both in paper form and electronically and entered into our systems in accordance with applicable laws - including aspects of data security and confidentiality - and in accordance with the principles of transparent and lawful processing. Your Data will only be retained for as long as is strictly necessary to fulfil the purposes for which it was collected; in any case, due consideration will be given to compliance with relevant legal and regulatory requirements, the principle of Data minimisation and the need for the Company to manage records in a rational manner when determining the length of retention. We may retain your Data after we have performed our services for you, but only for as long as is necessary to comply with contractual and legal obligations and to fulfil the purposes set out above. We update and maintain our databases on an ongoing basis to ensure that your Data is always accurate and up to date.

1. With whom we share your Data

Within our company, our employees only have access to your Data to the extent necessary to fulfil the respective purpose. Your Data may be processed by employees belonging to the following categories: administrators, medical staff, field representatives, product managers, legal and compliance , internal auditors, etc. The Data may also be processed by all other staff members to the extent necessary for the performance of their duties.

For organisational, administrative, financial, accounting or other internal management purposes, or where necessary for the fulfilment of the purpose in question, your Data may also be transferred to the parent company, A. Menarini IFR Srl, based in Florence (Italy), as well as to other companies of the Menarini Group, including those in third countries outside the EEA area and/or Switzerland.

Due to legal and regulatory requirements that we are obliged to comply with, we may be required to disclose your Data to Swissmedic, the Federal Office of Public Health, ScienceIndustries, national and local health authorities, health centres and universities, other public bodies, association bodies and other recipients.

In addition, we may share your data with other companies, such as external address suppliers, IT and cloud computing service providers, marketing agencies, event organisers, website analytics service providers, shipping and logistics service providers, and other service providers and companies that perform fiscal/administrative tasks on our behalf.

When transferring Data to third countries - i.e. countries that may not guarantee the same standards of protection as the EEA and/or Switzerland - we ensure that the Data is only processed in accordance with the applicable data protection laws, e.g. based on your consent, the conclusion of standard contractual clauses approved by the EU Commission and the Swiss Federal Data Protection and Information Commissioner ("FDPIC") and/or other competent Swiss authorities or other guarantees. Upon request, we will provide you with a list of the countries to which your Data will be transferred.

1. Your Rights

You can contact us at any time at our postal address (see above) or at dataprivacy@menarini.ch to exercise the rights to which you are entitled under the applicable data protection laws, in particular:

• Right of access/information: you have the right to receive information at any time about whether and which of your Data is being processed by the company.
• Right to rectification: you have the right to have inaccurate or incomplete Data rectified or completed and to be informed after rectification or completion has been made.
• Right to erasure or destruction: you have the right to request the erasure or destruction of your Data if the Data is no longer needed to fulfil the purpose for which it was collected, if you have withdrawn your consent and there is no other legal basis for processing, or if the Data is processed unlawfully.
• Right to restrict processing: under certain circumstances, you have the right to request that the processing of your Data be restricted.
• Right to data transfer in machine-readable format: you have the right to receive from us the Data we have received from you in a machine-readable format.
• Right to revoke consent: you have the right to revoke your consent to data processing at any time. Please note that the revocation does not affect the lawfulness of the data processing carried out up to the time of the revocation.
• Right to object: you can object to the processing of your Data at any time.
• Right to lodge a complaint with the competent supervisory authority: in Switzerland, the FDPIC is competent (Feldeggweg 1, 3003 Bern, Tel. +41 (0)58 462 43 95).

This Privacy Policy was last updated on 1 October 2023.