1. Important Information and Who We Are

What is the purpose of this document?
Glenmark Pharmaceuticals Limited including its subsidiaries, affiliates, successors, assigns and representatives worldwide (“Glenmark”) respects your privacy and is committed to protecting your personal data.

In this Privacy Notice we will explain how we handle personal data that we or our service providers process through your interactions with us or them, through your use of our websites or similar environments, such as mobile websites or apps that are operated and maintained by us and from which you can access this privacy notice (jointly called the “website” or “websites”).

Application and Scope
This Privacy Policy is global in scope and applies to all Glenmark websites. This Policy does not apply to Glenmark Life Sciences Limited, Ichnos Sciences Inc., USA, or their subsidiaries.

Our websites are not intended for children. We do not knowingly collect or process data relating to children.

Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their processing of personal data. When you leave our website, we encourage you to read and consider the privacy notice of every website you visit to ensure this is acceptable to you and meets with your expectations.

Access to Sections of the Website Restricted to Professional Groups
Whilst some of the web pages and functions provided by us can be visited anonymously, some pages are only open to specific groups of people and therefore require formal registration. We may only make certain information about prescription-only medications (POMs) or medical content accessible if you belong to so-called professional groups (for example, healthcare professionals such as doctors and pharmacists). Please be aware that the information we offer you on our website through our services that require registration is of a general type and cannot be used to provide any advice for the treatment of patients in individual cases.

Against this background, we may offer members of the relevant professional groups the opportunity to register for the closed section of our website in order to be able to retrieve the information about our medicines described above. Access to these closed sections takes place either through direct registration with Glenmark – in this case, you will receive a password from us that allows you to visit this section – or by means of a DocCheck password. For this, you will need your DocCheck access data. DocCheck is an external service provider that gives you the opportunity to set up a user account at www.doccheck.com. DocCheck ensures that you are an actual member of the stated professional group(s). You can then also use this access data as login data for our website (as well as for numerous other similar websites). For information on the handling of your data by DocCheck, please also see the
DocCheck privacy notice (available at https://more.doccheck.com/en/privacy) prior to registration.

Changes
We may modify this privacy notice without warning. You should therefore periodically visit this page to be sure that you have read our most current privacy notice and to ensure that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Most of our services do not require any form of registration, allowing you to visit our sites without telling us who you are. Some services may require you to provide us with personal data, which may include your direct identifiers, such as:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;

Usage Data includes information about how you use our website, products and services; and

Marketing and Communications Data includes your preferences in receiving marketing material from us and our third parties and your communication preferences.

3. How We Collect Your Personal Data

We use different methods to collect data from and about you including through automated technologies or interactions.

As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and similar technologies. Please see our Cookie Policy for further information

4. How We Use Your Personal Data

We may use personal data about you:

• to answer your enquiries and meet your requests, for instance to send you requested information.
• to provide important information about our business relationship with you, about our terms of business or use or to send you other information related to processing of your personal data.
• to comply with legal or regulatory obligations that apply to us, which include monitoring safety, managing adverse events, carrying out prevention and investigatory activities, or carrying out administrative formalities, registration, declarations or audits.
• to provide patient and healthcare support services, patient engagement and prescription information or to manage claims, including insurance claims.
• to conduct research and development.
• to promote our business interests, for example for data analysis, for checks, for the development of new products and services.
• to conduct direct marketing activities, including sending you targeted emails and offers but only when you opt-in to any direct marketing activities and for as long as you do so.
• to improve our interactions with you, to enhance our website, to personalise your use of our website, by presenting you with products and offers tailored to you, as well as to identify the effectiveness of our advertising campaigns. In this respect, we adhere strictly to local legal requirements and as far as possible only use anonymised data, which does not allow inferences to be made about you as an individual. The law may provide separate preconditions for the individual uses of data.
• to operate use-based online information (more information on this can be found in our Cookie Policy).
• to process payments we may need to issue in a specific situation, which includes verifying your financial data.
• to offer donations and sponsorships.
• to respond to legal requests from administrative or judicial authorities, in accordance with applicable laws.

5. Our Legal Basis for Using Your Data

We will only use your personal data when the law permits us to do so.

We must have a valid basis for using your personal information and we may not collect, store or use information shared via our website other than as described in this privacy notice. There are four ways we may have a valid basis for using your personal information:

Fulfilling a contract: The information we collect from you may be necessary to allow us to fulfil our contract with you or to enter into a contract with you.

Consent: You may provide your consent for us to contact you or to collect your information for example, by consenting to the use of cookies on our website or by opting-in to receiving emails or other direct marketing communications. If you have given consent to our use of your personal information, you are entitled to withdraw this consent at any time by unsubscribing via the link provided within marketing emails we send to you or by contacting us at dpo.glenmark@glenmarkpharma.com.

Legitimate interest: We may also have a legitimate interest in using your personal data to enable us to give you the best service/product and the best and most secure experience. If this is our reason for using your personal information, we must make sure that our interests do not override yours and you can object to this use of your personal information.

Legal obligation: Lastly, we may have a legal obligation to use your personal information in certain ways or to protect your interests, for example we may exchange information with other companies and organisations for the purposes of fraud protection and credit risk reduction or to monitor adverse effects of marketed products.

6. Disclosures of Your Personal Data

Who has access to personal data
If necessary and where legally permitted to do so, we may pass your personal data to the following third parties:

Companies that form part of the Glenmark group, but only for the purposes identified in this privacy notice and within the scope of permitted transfers. In any event, we remain fully responsible for the handling of personal data for shared use and will ensure this is done so in accordance with applicable privacy laws.

Our business partners, but we will only transfer your personal data if we have your consent or it is permitted by law. In addition, we do not allow our business partners to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Service providers, who provide services such as website hosting and moderation, the processing of your reviews of products and services, the provision of call centre services, the hosting of mobile applications, data analysis, payment handling, order handling, infrastructure provision, IT services, customer services, delivery services for e-mails and direct advertising, credit-card settlements and audits, in order to carry out these services. Here, too, the partners are contractually obliged to only use the personal data according to our specifications before the personal data is transferred.

Third parties to whom we are required to transfer personal data because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding.

International Transfers
The personal data we collect from you may be stored, accessed or processed in any country where we maintain branches or employ service providers, for example in India (where our parent company, Glenmark Pharmaceuticals Limited, is located). Whenever we export your personal data, we ensure a similar degree of protection is afforded to it by using specific contracts that ensure the importer of such data has appropriate and equivalent safeguarding measures in place.

7. How We Protect Your Data

We have put in place appropriate technical, organisational and security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. How Long We Will Use Your Data For

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Your Legal Rights

Under certain circumstances, you may have rights under data protection laws in relation to your personal data:

Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (as explained below). Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. In such circumstances we may reserve the right to delete your personal data rather than hold it but restrict processing, where our processes are not set up to enable a restriction.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Request information about your personal data. On request, we will disclose to you the categories of personal information Glenmark collected, used or shared about you, which third parties were involved (if any) and why they collected, used or shared that information.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

10. Sale of data

We do not sell your personal data to other businesses or third parties under any purposes of processing.

11. Data protection officer

We have appointed IG Smart as our global Data Protection Officer (DPO) to oversee compliance with this privacy Notice and our privacy obligations generally. If you have any questions about this Notice or how we handle your personal information, or wish to exercise any of your rights contained hereunder, please contact us by email at dpo.glenmark@glenmarkpharma.com or alternatively contact our global DPO directly at dpo@ig-smart.com.

12. Complaints

If you are unhappy with the way in which we have processed your personal data please address any complaint to dpo.glenmark@glenmarkpharma.com. In any case, you also have the right to lodge a complaint with the relevant supervisory authority which can be found at https://pdpecho.com/the-list/