Privacy Notice

Last update: 01.07.2020

General Privacy Statement

Thank you for visiting our Internet websites, our digital platforms or interacting with us through email. Internet websites and digital platforms will hereinafter be referred to as "Websites".

These websites contain information from Roche Servicios S.A. and / or its subsidiaries, affiliates and / or owned by the same economic group (hereinafter “Roche”), and all the terms and conditions included herein apply to them.

At Roche we are committed to protecting your personal information. This Notice only applies to websites. Our websites may also contain links to third-party websites. We do not endorse and are not responsible for the content of third-party websites or resources, and our privacy notice does not apply to any sites under different ownership, even if access to them is done via a link on our website. You should review the privacy policies of any third-party site before providing any information. We do not share your personal data with third parties, unless you explicitly consent. Please read this privacy notice carefully to understand how we collect, use, share and protect online information.

For purposes of this Privacy Notice, "Personal Data" is any information by which you can be individually identified directly or indirectly, including, but not limited to your name, address, e-mail address and telephone number.

Visitors to these websites confirm and respond, in any case, to the veracity, accuracy, validity and authenticity of the personal data provided by them, and undertake to keep that information duly updated.

Minors

This website is not designed or intended for use by children under the age of 16. We do not knowingly collect any personal data from anyone under the age of 16 without the prior 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.

How We Get Your Personal Data and Why We Process Them

On this website, we may request personal data about you. Examples of personal data that we may collect and that directly identifies you includes your name, contact information, email address, and other information in combination with these identifiers. We may also 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.

We process your personal data on our websites for many reasons, including:

  • to respond to your requests or inquiries;
  • to complete a transaction;
  • to personalize your experience;
  • to perform website analytics and monitor website performance;
  • to track and monitor adverse events and other activities related to pharmacovigilance; and
  • to maintain the website, including for security purposes.

Several sections on our Website require 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 collect this information about you only if you voluntarily provide it to us. Please be aware that certain features of this website may not be available to you if you elect not to provide that information. Any personal data you provide to us will be used in accordance with this privacy notice.

More Information on our Processing Activities

This section outlines each processing activity in greater detail and provides information on the categories of information collected for each activity, as well as the legal basis of their processing.

Responding to Requests or Inquiries: Certain sections of our Website and online resources allow you to submit your personal data for various purposes. For example, you may submit a medical information request, inquire about a product, or subscribe to one of our mailing lists. In those cases, we may collect the information you have provided to us to reply to your request. Depending on your request, we may collect your contact information (name, email address, telephone number, job title), your interests and preferences (such as products or areas of interest), and any other information you provide to us. We collect and process your personal data for these purposes based on your consent. If reporting is required, we may process your data to comply with our legal obligations.

Completing Transactions: Some sections of our Website may collect your personal data to fulfill 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). If you purchase or order a Roche product or service, we use such information to improve our agreement with you.

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. In cases where we collect this information automatically, we collect and process this information for our legitimate business interests. In other cases, we will collect and process this information pursuant to your consent.

Website Analytics and Tracking: Where permitted by law, we may combine personal data you provide with other information you have provided to us through our Websites. We may also combine personal data collected from online resources with our offline records and information provided to us by third parties. More information about this can be found in the section below and in our Cookie Notice.

Tracking and Monitoring Adverse Events and Pharmacovigilance: Some specified sections of our Websites may collect personal data related to adverse events or other pharmacovigilance related activities. This information is very important for public health and will be used for the detection, assessment, understanding, and prevention of adverse events or other medicine-related problems. We collect and process your information for these purposes to comply with our legal obligations and may be required to report the data to health authorities. For more information about how we use and disclose personal data for these purposes, please see our Privacy Notice for Pharmacovigilance.

To Run and Maintain our Website: We use this information to secure our Websites, network systems, and other assets. This may include information concerning your IP address, geographic location, resources you have accessed, and similar information. We collect this information automatically, for our legitimate business interests.

Cookies and Other Tracking Technologies

Our Websites and online resources also collect other basic information about you which may not directly identify you, but which may correspond with you or a particular device. From Roche, we use this information to learn more about how our websites and online resources are used, and to otherwise improve and administer the site. 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, this information is collected automatically, for our legitimate business interests. In some jurisdictions, we ask for your consent before collecting this information, in which case you will be presented with a choice as to whether you wish to allow the collection and use of this type of information. Please see our Cookie Notice for more information.

Cookies: Our Websites may use a tracking technology called "cookie." A cookie is a small data file that a website can download to your computer's hard drive, where the files from your internet browser are found. Cookies allow us to recognize when a computer used to access our Website has already browsed a Roche website or online resource. Cookies may also be used to enable a site to "remember" the information previously entered by the user. Both we and a third party we are related to can place cookies on your computer, such as web analytics services and network advertising services.

Web Beacons:  On certain Websites or emails that we send you, we may use a technology called “web beacon” (also known as an “action tag” or “clear GIF technology”). Web beacons help determine which emails were opened and if any action related to it was taken. In addition, they help analyze the efficiency of web pages by measuring, for example, the number of visits to a page or how many clicks have been made on key elements of the site.

Social plugins: This Website may use social plugins (e.g., the Facebook "Like" button) to enable you to easily share information with other users. When you visit this Webite, the operator of the social plugin may be able to place a cookie on your computer, enabling that operator to recognize individuals who have previously visited this Website. If you have logged before into the associated social media Website (e.g., Facebook) before browsing this Site, the social plugin allows that social media website to receive information that you have visited specific pages in this Site. The social plugin may collect this information from any visitor who has registered on social media, whether or not they specifically interact with the plugin on our Sites (for example, by clicking "Like" or "Share"). The social plugin could allow the social website to share information with other social network users about your activities on our websites. For more details about the information shared through a certain social network, you should refer to that social media site's privacy statement.

Certain web browsers and other programs may be used to signal your preferences to Roche about how or whether Roche or third parties may collect information about your online activities and if they can do it. Currently, Roche does not respond to such signals.

Use of Data for Marketing

Roche will not sell or transfer your Personal Data to any non-affiliated entity for their own direct marketing use, unless we provide clear notice to you and obtain your explicit consent. We use third party advertising companies to place ads 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. For more information about this practice and your choices to opt out, see our Cookies Policy.

Uses and purposes of personal data: The personal data you provide to us, including sensitive information, will be treated in accordance with this Privacy Notice and with the provisions of the Law on protection of personal data and its corresponding Regulations for the purpose of contacting you and:

General Public and Health Professionals:

1.     Comply with legal obligations, derived from a legal and / or contractual relationship that you have or will have,

2.     For administrative and / or monitoring purposes,

3.     Receive the support and benefits of Roche’s products and / or services,

4.     Create databases for statistical, scientific purposes

5.     Collect, monitor, investigate and evaluate information on suspicions of possible Adverse Events and prepare and submit reports to health authorities

6.     Attend to and respond to your information request,

7.     Share your name, email, phone number in recruitment campaigns,

Health professionals:

8.     create databases for statistical and scientific purposes, for the exchange of scientific data and integrate general information related to medical practice,

9.     invite you to participate in promotional events and / or continuing medical education events,

10.  send you notifications, notices, material for advertising and educational purposes, within the parameters allowed by applicable law,

11.  send you information, magazines and news from the medical industry or topics that are of interest to you, as well as news about Roche,

12.  create a database of health professionals to:

  • contact you by electronic means, including, email, cell phone, mobile applications, instant messaging, and / or through home visits to send you informational communications for promotional and educational purposes,
  • conduct analyzes to determine the effectiveness of our programs, sending or delivery of patient support materials, provision of promotions and awards,
  • register you to receive information of interest about Roche or a particular topic,
  • allow your participation in clinical studies (with due and prior informed consent, study and corresponding approval, and in accordance with applicable legal provisions),
  • carry out inspections by authorities, internal and external audits and by authorities,
  • make surveys,
  • participate in disease awareness programs,
  • develop new products and services, know the market and company performance in it, market research,
  • track sales towards customer satisfaction, customer service,
  • register you in contests, events, congresses or symposiums,
  • give access to digital platforms,
  • present a testimony or anecdote or participate in disease awareness programs,
  • have a directory of specialists on the Roche Dialogue website so that registered doctors can find colleagues from other specialties,
  • present a testimony

Information Sharing / Recipients of Personal Data

Recipients of your Personal Data

Roche may share your Personal Data with our affiliates around the world. Our Roche affiliates will use your Personal Data for the same purposes as we do. A list of Roche’s affiliates is available in the current annual report, which can be found in the Investors section of www.roche.com.

We may also share your Personal Data with third parties, such as our information processors, for the following purposes:

  • To help fulfill Roche business transactions;
  • To conduct technical maintenance of our websites and other web platforms;
  • To facilitate a merger, consolidation, transfer of control or other corporate reorganization in which Roche participates, or pursuant to a financial arrangement undertaken by Roche;
  • To respond to appropriate requests of legitimate government authorities, or where required by applicable laws, court orders, or government regulations; and
  • Where needed for corporate audits or to investigate or respond to a complaint or security threat

International Transfers of Your Personal Data

Any Personal Data you provide to us through your use of these websites may be transferred to or stored in a geographic region that imposes different privacy obligations than your country of origin. This means that your Personal Data may be sent to a country with less restrictive data protection laws than your own. Any such transfer will be conducted in compliance with applicable law.

Storage Period of Your Personal Data

The length of time in which we will store your Personal Data will differ depending on the purpose for which we have collected and processed your data. In most cases, we will keep the data for three (3) years following our last interaction with you. However, we may maintain your data for a longer period of time if we are required by law. For example, reports related to pharmacovigilance are kept for a minimum of 10 years after the withdrawal of the product in the last country where the product is marketed.

Description of Your Rights Regarding Your Personal Data

Your rights if your data is protected by Law No. 8968 on the Protection of the Person Concerning the Treatment of Personal Data.

Roche recognizes the rights to access, update, cancel, rectify and delete any personal data provided by you on our Sites. In this way, the holders of personal data who have provided their data on our Sites may, at any time, obtain information about them and, if deemed appropriate, request their update, cancellation, rectification and / or deletion.

To exercise these rights, please send a written request to email address cac.legal_compliance@roche.com, providing your first and last name, a copy of your identity document, postal and email addresses in which you wish to be notified.

The owner of the personal data has the power to exercise the right to access such data, free of charge, in intervals of not less than six months, unless a legitimate interest to that effect is established, in accordance with the provisions by article 7, subsection of Law. No. 8968.

The CITIZENS DATA PROTECTION AGENCY, Controlling Body of Law No. 8968, has the power to address the complaints and claims filed by those whose rights are affected due to non-compliance with current regulations on the protection of personal data.

Data Security

Roche and its business partners take reasonable steps to protect Personal Data we access or receive through this Website from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Nevertheless, Roche makes no guarantee as to the security of your Personal Data and disclaims, to the fullest extent permitted by law, all liability and damages caused by loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We recommend that you take any available precautions to protect Personal Data you submit on this website.

Updates to Privacy Notice

From time to time, we may revise this Privacy Notice. Any such changes to this Privacy Notice will be reflected on this page. Roche recommends that you review this Privacy Notice regularly for any changes. The date on which this notice was last revised is located at the top of this notice.

This website contains product information for a wide variety of audiences and may contain product details or information not accessible by other means or not valid in your country. Please note that we assume no responsibility for access to information that may not conform to legal processes, regulations, registrations or uses in your home country.

Purposes and Legal Basis for Processing – Medical Inquiries

Any personal data you provide to Roche related to a medical inquiry may be used to answer the inquiry, follow up on such requests and maintain the information in a medical information database for reference. Where required by law (such as for pharmacovigilance), we may also be required to report the data to regulatory authorities. Your data will not be used for any other purposes.

We collect and process your data to respond to your inquiries based on legitimate interests. If reporting of an adverse event is required, your data may be processed to comply with Roche legal pharmacovigilance obligations (GVP, good pharmacovigilance practice).

Categories of Personal Data Processing

The type of information that we collect from you will depend on the concerned party and the type of processing activity:

  • Pharmacovigilance: We collect the name, contact details, and affiliations/profession of the reporting individual. We may collect some additional personal data related to health and medical history of the individual experiencing an adverse event, if required for processing of adverse event for pharmacovigilance purposes.
  • Medical Inquiries: We may collect the name, contact details and affiliations/profession of the individual making the inquiry.

Recipients of Your Personal Data

Roche may share the data you provided to us among Roche Group companies and affiliates, business partners and service providers, where required to operate Roche global pharmacovigilance database, and comply with regulations on pharmacovigilance.

Roche is also obliged to report certain pharmacovigilance and product relevant information to Health Authorities worldwide, including those with different level of data protection compared to EU. The reports contain details about the incident but will only contain limited personal data:

  • Patients: The information provided, including age or date/year of birth (where permitted by regulations) and gender (note that patient name will never be provided)
  • Reporting Individuals: The information provided to allow the regulatory authority to follow up with the reporting individual, including name, profession, initials, address, email and phone number.

It is possible that in the exchange of data within the Roche Group, business partners and service providers, your personal data may be transferred to countries that do not provide the same level of protection as your own. In this case, contracts containing the standard contractual clauses in accordance with the provisions by the Citizens Data Protection Agency constitute adequate security guarantees to ensure compliance with Law 8968.

Storage Period

As information related to pharmacovigilance (reports about adverse events) are important for public health reasons, reports are kept for minimum of 10 years after the withdrawal of the product in the last country where the product is marketed. Personal data retained as part of a medical information inquiry are kept for minimum of 10 and maximum of 15 years after receipt.

Information About Your Rights

Your data is protected by Law No. 8968 on the Protection of the Person Concerning the Treatment of Personal Data. Consequently, you have the right to request information about your personal data already stored and processed by Roche. In addition, you may request access, update / modification and / or erasure of your personal data. The elimination or limitation of processing is possible only to the extent that such processing is based on consent or legitimate interest. It should be noted that due to our legal obligations under pharmacovigilance legislation, Roche may not be able to erase or limit the processing of your data, if it was processed for pharmacovigilance reasons.

If data processing is based on consent, kindly note that you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. If you would like to contact us to exercise your right to withdraw consent, please email us at cac.legal_compliance@roche.com

To prevent your data from being entered into our systems again after your request for erasure, in your interest and for us to comply with current regulations, we may keep your name and e-mail address with a flag “Don’t contact anymore” in our systems.

In the event you have the impression that our data processing is non-compliant with valid regulations, you are entitled to file a complaint with the responsible supervisory authority.

This website contains product information for a wide variety of audiences and may contain product details or information not accessible by other means or not valid in your country. Please note that we assume no responsibility for access to information that may not conform to legal processes, regulations, registrations or uses in your home country.