This Privacy Notice is for Health Care Professionals (“HCP Privacy Notice” ) and describes the Personal Data that EUSA companies ( “us” or “EUSA”) based in the EEA region,  collect data about you as a healthcare professional (“HCP”) when EUSA interact with you. 


Set out below is the how we process your data.


“Personal Data” is data that identifies you as an individual, or relates to an identifiable individual.  EUSA will collect Personal Data when you participate in EUSA educational programs, industry events, sponsored congress, or in connection with your communications with us.  


EUSA also collect Personal Data from data companies (like Veeva) providing information services in the healthcare sector, publicly accessible sources of professional information, and marketing partners. 


Personal Data that EUSA may collect includes:

If you choose not to provide data that is necessary for EUSA or its agents to provide requested services or perform contractual obligations,  EUSA may not be able to provide you those services. 
 


HOW EUSA USE PERSONAL DATA

Personal Data is used  to  interact and engage with you when EUSA have a contractual relationship, or a legitimate interest.  This may include:

Operating our business includes:


WHAT ARE YOUR RIGHTS?

Under the European Privacy laws,  you can request to review, correct, update, suppress, restrict, object or delete Personal Data that you have provided to us, withdraw a consent or if you would like to request to receive an electronic copy of such Personal Data for purposes of transmitting it to another company, you may contact us at privacy@eusapharma.com


In your request, please tell us what Personal Data you would like to have reviewed corrected or  changed, whether you would like to have it suppressed from our database, or otherwise let us know what limitations you would like to put on our use of it.  For your protection, EUSA may need to verify your identity before implementing your request.  EUSA will try to comply with your request as soon as reasonably practicable. 


Please note that EUSA may need to retain certain Personal Data for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion, such as finance details to comply with reporting obligations.



HOW EUSA DISCLOSE PERSONAL DATA

EUSA disclose Personal Data as follows: 


DISCLOSURES OF TRANSFER OF VALUE

Public disclosures of the  transfers of value that you receive from any EUSA company according to local Code of Conduct and/or applicable local law (such as payment of professional fees, travel, accommodations and out of pocket expenses) will be disclosed in accordance with reporting laws of that country.


Unless otherwise required by law, EUSA will disclose your identity, city and country of professional practice, date, nature and amount of value that you received from EUSA. If local laws require,  we may use your ID or social security number. These disclosures will be published on our EUSA websites and/or local pharmaceutical industry association websites.  If legally required, disclosure will also occur on relevant government websites. The data, once published, will be available for 3 years (unless another legal period applies in your country). EUSA disclose this data pursuant to consent, law or legitimate interests.


DATA SECURITY

EUSA seek to use reasonable organizational, technical and administrative measures to protect your Personal Data.  


HOW LONG WILL EUSA KEEP YOUR DATA?

EUSA will retain your Personal Data for as permitted in light of the purpose(s) for which it was obtained and as outlined in this Privacy Notice. The criteria used to determine our retention periods include:  (i) the length of time EUSA have an ongoing relationship with you and (ii) whether there is a legal obligation to which EUSA is subject; or (iii) whether retention is advisable in light of our legal position (e.g statutes of limitations, litigation or regulatory investigations).
 


CROSS BORDER TRANSFERS

The data EUSA collect through this notice may be stored and processed in any country where EUSA have facilities or in which EUSA engage service providers, including in the U.S. and where our affiliate operate.


Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, EUSA have put in place adequate measures, such as by ensuring that the party handling your Data is bound by EU Standard Contractual Clauses, to protect your Personal Data.