Privacy and Cookie Notice
This website is operated by Teva Pharmaceuticals Industries Ltd. with its registered seat at 124 Dvora HaNevi’a St., Tel Aviv 694402 Israel, and is the controllers of your personal data when you visit and interact with this Site and communicate with us (“Teva” or “we”, “us”).
The purpose of this Site is to provide information about a proposed clinical study into the health impacts suffered by individuals suffering from asthma and who are under the age of 18 years old (“child” or “children”) and provide a way for you to enquire further about clinical study participation.
Scope of this Privacy Notice
This Privacy Notice is a global notice. Whilst we have included country specific sections within the body of this Notice, there is a regional annex for Europe at the end of this Notice which may be relevant to you.
This Privacy Notice applies to personal data we collect both through the Site and further communications with us. It describes how we use personal data, and individual’s’ data protection rights, including 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 How we store your information and your rights section below.
Information We Collect
When you visit the Site we collect the following personal data:
Contact Data – your name and telephone contact details.
Cookie Data – your cookie preferences and device IP address, when you first visit the Site and make changes to your cookie settings.
We also collect and use the following additional data directly from you, either via this Site, or if you prefer, via our call centre:
Health Data – health and medical data of your child.
Additional Contact Data – your address, mobile and land line telephone numbers and your email address.
Additional information for individuals in Australia – Providing the above data is not a legal obligation, so you may refuse to provide data or to give your consent to their processing, but if you do not permit us to collect such data or you refuse your consent, Teva may not be able to respond to your request for more information about the proposed clinical study or assess the eligibility of your child.
How We Use Your Information
We collect and use personal data for the following reasons:
| Purpose of Processing | Categories of Personal Data and Legal Basis |
|---|---|
| To determine whether your child will be eligible to participate in the proposed clinical study. |
Contact Data with your consent. Health Data with your consent as the parent or guardian of your child or having already obtained the consent of your child where they can legally give their consent. Additional Contact Data for our legitimate interest in being able to communicate with you in accordance with your communication preferences. |
| Place cookies and similar technologies, as described below. |
Cookie Data for non-necessary cookies with your consent. Where non-necessary cookies can be legally placed on your device without consent, Teva places them for its legitimate interest in ensuring that the Site is secure, safe and can be used by you. |
| Ensuring compliance with our policies and applicable laws, as well as protecting our business interests and legal rights |
Cookie Data, Contact Data, Health Data and Additional Contact Data are all used by Teva to compliance with applicable laws relating to data protection and pharmacovigilance and also for its legitimate interest in ensuring its processes comply with its internal policies. |
| Sale of or restructure of a Company and/or business, measurement of the performance of our third party suppliers, operational improvements, business success decision making. | Metrics on success of recruitment for clinical trials may be used by Teva for its legitimate interest in managing its business. |
Where Teva is required by certain data protection laws to provide more detailed information on its personal data processing, for example, in most European countries, this is set out in the Annex to this Privacy Notice.
Sharing Your Personal Data
We may need to transfer or disclose your personal data to Teva affiliates globally within the Teva group, internal Teva teams which will include Teva individuals in clinical trials. In some circumstances relating to complaints, exercise of your rights, requests for personal data from government and regulatory authorities, we may need to share your personal data with Internal Support Teams, Legal & Compliance, Internal Audit, Corporate Security and IT Security, as the circumstances require.
We also share your personal data with our third-party service providers for recruitment. These include:
- Elligo Health Research, Inc. who provides the website development for this Site, manages the Site and operates the call centre that will contact you where you have consented to this. These services are provided globally;
- IT service providers including Optimizely, a US company which hosts this Site in Europe on Teva’s behalf;
- Legal & Compliance (external consultants including law, tax, accounting or consultancy firms, government and regulatory authorities). We may share information with national and/or regional authorities when required in accordance with pharmacovigilance, adverse event reporting or other laws. In such cases, we are unable to control their use of any information we share.
Cookies and Related Tracking Technologies
We use cookies and similar technologies such as web beacons to collect information about you and store your online preferences to enable us to give you a better experience of our Site. This information is your personal data which we collect with your consent when you first land on this Site. You can adjust your cookie preferences at any time. Please see Managing these technologies section below, for more information on this.
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a Site. The Cookies are then “read” when you return to the Site: this is useful because it allows the Site to recognise your device. To find out more about cookies please visit www.allaboutcookies.org. Web beacons are electronic images (sometimes known as clear gifs) that allow us to count users who have visited these pages or read our emails. Web beacons collect information on web behaviour such as a cookie number, time and date of a page view, and a description of the page on which the web beacon resides.
Teva uses the following categories of cookies on the Site:
Category 1: Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for (such as seeing the Site in your preferred language) cannot be provided, and the Site would be unable to function. The use of such cookies does not require your consent.
Category 2: Performance Cookies
These cookies collect information on how people use and interact with our 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 us and the information we send to you. The data collected can be combined with other data we collect to improve how our Site works and the quality and relevance of the information we send you.
Category 3: Functionality Cookies
These cookies remember choices you make (such as language choices). 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.
Storing Your Information and Your Rights
We retain all the information we gather about you and where you consent, your child, for 2 years in accordance with Teva’s data retention schedule and applicable laws. For further information, please see the “Data Protection Queries – Contact Us” section below on how to get in touch with us.
Under applicable law you may exercise certain rights in relation to your personal data that we processed. Depending on the applicable law, you have the to review the personal data we process, a right of access, to rectification, erasure, objection (including objection to automated decision making), restriction of the processing, data portability, as well as to withdraw any consent initially provided (but withdrawal does not affect the validity of the processing of personal data carried out based on your consent before the withdrawal). Where your request for erasure is fulfilled, your personal data will no longer be available within Teva’s systems, so you will not be able to exercise any of your other rights in the future.
Please note that we may require you to provide proper identification before we comply with any request personal data.
Please note that your rights may be limited in some situations – for example, where we can demonstrate we have a legal requirement to process your personal data. If you feel your concerns have not been resolved, you have also the right in some countries to lodge complaints with the relevant data protection authority.
Security
Teva takes measures to secure your personal data from accidental loss and from unauthorized access, use, alteration or disclosure. Data is transferred securely using SSL encryption and stored on secure servers. Additionally, we take further information security measures including access controls, stringent physical security and robust information collection, storage & processing practices. However, the internet is an open system and Teva cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your personal data for improper purposes.
International Transfers
Teva is a global group of companies and as a result, your information may be transferred outside your country to one that may have different data protection laws. Teva will always take steps to ensure your information is adequately protected if transferred to these countries. For the EEA, the UK and Switzerland when transferred to Teva in Israel, this is protected under Israeli law which is recognized by the European Commission to provide adequate protection; when transferred to USA, Teva generally relies upon European Commission’s Standard Contractual Clauses and the UK’s International Data Transfer Addendum to those Standard Contractual Clauses.
For other countries: Transfers abroad (including to countries that provide a lower level of privacy protection) are based on a relevant mechanism to safeguard transfers, such as your consent provided when registering with the Site, or appropriate agreements.
For more information on the relevant mechanism, please contact our Teva Data Protection Office (contact details below).
Changes to this Privacy Notice
If our privacy notice changes in any way, Teva will place an updated version on this page and may otherwise communicate changes as appropriate. Regularly reviewing this page ensures that you are always aware of what information we collect, how Teva uses it and under what circumstances, if any, we will share it with other parties.
Data Protection Queries – Contact Us
If you have any questions about the processing of your personal data, please contact the following:
Europe – Data Protection Officer: EUPrivacy@tevaeu.com
Other: IMPrivacy@tevapharm.com
Addendum for Individuals in Europe
Data protection laws in the European require Teva to provide additional details on processing purposes and the legal basis on which each purpose is based. This is in addition to the information set out in the How we store your information and your rights section above. When you share your personal data with us, we rely on the following:
Legitimate interest – there are instances where we have a legitimate interest to use your data. Our legitimate interest will vary depending on what we are using your data for. Please see the How we use your information section where we explain what the interest is and how it relates to the processing operations that we are carrying out. Where we process personal data on the basis of a legitimate interest, then – as required by applicable data protection law – we have carried out a balancing test to document our interests, to consider what the impact of the processing will be on individuals and to determine whether individuals’ interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details at the end of the notice.
Legal obligation – Teva is required to comply with legal, regulatory and other requirements under laws in many countries where Teva operates including pharmacovigilance and adverse event reporting laws. We have to use your data to meet these obligations.
Consent – in some circumstances we may only be able to collect your personal data with consent. For example when you provide your child’s health and medical data, which is classified as special category personal data under data protection laws in Europe. You have the right to withdraw consent at any time by contacting us. Please see the How we store your information and your rights section for more information on this. Please note that if you fail to provide certain information when requested, we may not be able to fulfil your request, or we may be prevented from complying with our legal obligations.
We will use your personal data only for the purposes for which it was collected, unless we reasonably consider that we need it for another purpose that is compatible with the original purpose. If we need to use your personal data for an unrelated but compatible purpose, we will notify you in advance of our use of your personal data and explain the legal basis for this. Note that we may process your personal data without your knowledge or consent where this is required or permitted by applicable law.
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