Privacy Portal

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”) respect your privacy and are committed to protecting your personal data.

Almost all of the jurisdictions in which Glenmark do business have privacy and data protection laws which govern how organisations can collect, use, and disclose the personal data of their commercial partners and Glenmark is committed to using any personal data fairly, lawfully and in accordance with all applicable laws.

This Privacy Notice covers the collection, storage, use and disclosure of personal data collected in relation to Glenmark’s marketing and promotional activities. In this privacy notice we will explain how we handle personal data that we or our business partners and service providers process through your interactions with us or them. This Privacy Notice also describes your legal rights with respect to such activities.

Application and Scope
This privacy notice is global in scope and applies to all Glenmark entities. This privacy notice does not apply to Glenmark Life Sciences Limited, Ichnos Sciences Inc., or their subsidiaries.

Our marketing and promotional activities are not intended for children. We do not knowingly collect or process data relating to children.

2. The Personal Data We Collect About You
Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

The information we may gather about you may include but is not limited :

Identity Data first name, last name, title, job title, qualifications, date of birth, email address, telephone number and business address.

Technical Data internet protocol (IP) address, MAC 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 information about how you use our website, products and services.

Marketing and Communications Data your preferences in receiving marketing and promotional material from us and our third parties including your communication preferences such as type, format and frequency.

3. Ways in which Personal Data is Provided
We use different methods to collect data from and about you including through automated technologies or interactions.

Information you provide. We may ask you to provide, or you may choose to provide information. Such information may be provided to us at various times, including, without limitation: when you fill in specific forms (online or offline); when you register on a Glenmark website or on other Glenmark platforms; when you register for an event or webinar via a Glenmark website/platform or by contacting us offline; and when you request information about or receive products and services from Glenmark.

Information collected through your business relationship with Glenmark or with its business partners such as data providers. We may collect information from you through your relationship with Glenmark, including when you have shown interest in Glenmark (e.g. during business meetings, events or conferences with Glenmark employees and/or interactions with our sales representatives) as well as via our business partners for example where you have provided your consent to them to share personal data with third parties whose products and services they deem may be of interest to you.

Information collected automatically. If you interact with our website or other online portals and systems, 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 Cookies Policy for further information.

Information collected automatically from combined sources. In some cases, personal data that you provide to us via Glenmark websites, apps and/or platforms may be combined with personal data collected through your business relationship with Glenmark employees and/or our sales representatives. In such cases, the data may be used for all purposes defined in the “How We Use Your Personal Data” section below, unless and until you notify us that you do not longer wish us to use the data for these purposes.

4. How We Use Your Personal Data
Within the scope of marketing and promotional activities we may collect and store your personal information using a Glenmark Customer Relationship Management (CRM) system or otherwise. Subject to the provisions contained in the section entitled ‘Our Legal Basis for Using Your Personal Data’ below, your personal data may be used for the following purposes:

to conduct research and development including requests to involve you in market research.
for statistical purposes.
to promote our business interests, for example for data analysis, for checks, for the development of new products and services.
to send you targeted emails for example with invitations to promotional meetings or sharing promotional materials.
to present you with product information and services tailored to you, as well as to identify the effectiveness of our marketing campaigns.
to respond to queries and requests for professional information, for example by medical liaisons.

Processing activities on your personal data may be performed by Glenmark either manually or automatically according to the purposes indicated above and for the time strictly necessary to pursue these purposes.

5. Our Legal Basis for Using Your Personal Data
We will only use your personal data when the law permits us to do so and for the purposes of marketing and promotional activities such contact typically requires your prior consent.

If you have given consent to our use of your personal information for marketing and promotional activities, you are entitled to withdraw this consent at any time by
(i) unsubscribing via a link provided within our CRM platforms or marketing emails that we or our third party business partners send to you; or
(ii) by sending an email request to dpo@glenmarkpharma.com.

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. We may allow them to determine the purpose and control the manner in which they process your personal data in order to achieve the specified purposes for which such personal data is being processed.

Service providers, who provide services such as CRM systems, online file or website hosting and moderation, the processing of your feedback and reviews of products and services, the provision of call centre services, the hosting of mobile applications, data analysis, infrastructure provision, IT services, delivery services for e-mails and direct marketing, in order to carry out these services.

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 the aforementioned parties are located, 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, business partners, service providers, contractors and other third parties who have a business need to know.

Glenmark will carefully select such third parties and we will enter into appropriate written agreements and including a duty of a confidentiality. To the extent required, we will ensure that such third parties collect, store, use and disclose your personal information in accordance with applicable local privacy laws. Under certain circumstances, it may be appropriate to allow these companies to determine the purpose and means of processing of your personal data in order to achieve specified purposes but this should never extend to the use of your personal data for third party marketing and promotional activities without your consent. You should refer to the contents of their respective privacy notices for further information in respect to the manner in which they process your personal data and any queries or complaints arising therefrom should be addressed to them directly.

8. How Long We Will Use Your Data For
We will only retain your personal data for as long as we have your consent or as is necessary to fulfil 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 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.

These rights can be exercised (i) via the self-service function within our CRM platforms (where offered); or (ii) by sending an email request to dpo@glenmarkpharma.com. We will respond to your request as soon as practically possible and within the timeframes set forth by applicable law.

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

11. Revisions to this privacy notice
Glenmark may update this privacy notice from time to time. In order to keep uptodate with the ways in which Glenmark handles your personal data we request that you regularly visit and review the relevant privacy notices available from our privacy portal.

12. 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@glenmarkpharma.com or alternatively contact our global DPO directly at dpo@ig-smart.com.

13. Complaints
If you are unhappy with the way in which we have processed your personal data please address any complaints to dpo@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
You are now leaving Glenmark’s website, and are being connected to a third party website. Please note that this website is third party owned and access will be subject to the cookie, privacy and legal policies of the external website.
Glenmark is not responsible for the information, content or product(s) found on any third party web sites.

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

This privacy notice is being shared with you because you have either proactively or reactively applied for work with us (whether as an employee, worker or contractor) and in doing so have provided or will provide personal information relating to yourself or others.

It makes you aware of how and your personal data will be used during a recruitment process and for how long it will typically be retained.

Data protection principles
At all times, Glenmark will comply with relevant data protection laws and principles, which means that your data will be:

Used lawfully, fairly and in a transparent way;
Collected only for valid purposes that we clearly explain to you and not used in any way that is incompatible with those purposes;
Relevant to the purposes we tell you about and limited only to those purposes;
Accurate and kept up to date;
Kept only as long as necessary for the purposes we have told you about or that you have provided us with consent to retain; and
Kept securely.

The kind of information we hold about you
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

The information you have provided to us in your curriculum vitae (CV) and any covering letter or assessment.
The information you have provided on our application form or via the Glenmark or a third-party recruitment agency or job portal (as applicable), including name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications.
Any information you provide to us during an interview process.

Where necessary and lawfully permitted to do so, we may also collect, store and use the following types of more sensitive personal information:

Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions;
Information about your health, including any medical condition, health and sickness records;
Information about criminal convictions and offences; and
Previous or current salary level.

How is your personal information collected?
We may collect personal information about you from the following sources:

You, the candidate;
The recruitment agencies with which you have registered and via which your application was submitted;
Background check providers (if lawfully permitted);
Credit reference agencies (if lawfully permitted);
Your named referees (if applicable);
Publically accessible sources (including but not limited to for example LinkedIn, Facebook, Twitter);

How we may use information about you
We may use the personal information we collect about you to:

Assess your skills, qualifications, and suitability for the role;
Carry out background, identification and reference checks;
Communicate with you about the recruitment process;
Keep records related to our hiring processes including a reasonable means to identify candidates who have previously applied for a role with us;
Ensure compliance with equality, diversity and inclusivity policies; and
Comply with legal or regulatory requirements.

If you fail to provide personal information
If you fail to provide information when requested and which is necessary for us to consider your application (such as evidence of qualifications or work history), we may not be able to process your application successfully. For example, if we require references for this role and you fail to provide us with relevant details, we may not be able to take your application further.

How we use particularly sensitive personal information
Glenmark may use particularly sensitive personal information disclosed by you in the following ways:

Disability status - to consider whether Glenmark needs to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview or otherwise.
Ethnicity, race and religion - to ensure meaningful equal opportunity monitoring and reporting.

Information about criminal convictions
Glenmark may need to process information about criminal convictions.

If so and where lawfully permitted, Glenmark may collect information about your criminal convictions history only if we would like to offer you the work or role (conditional on checks and any other conditions, such as references, being satisfactory).

International Data Transfers
The personal data we collect from you may be stored, accessed or processed in the country in which you reside as well as any country where we maintain branches, for example in India (where our parent company, Glenmark Pharmaceuticals Limited, is located) or where our contracted business partners and service providers are present. 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. All entities within the Glenmark group of companies as well as our business partners and service providers are required to take appropriate measures to protect your personal information in line with applicable data privacy laws.

Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Third Parties
Where we are lawfully permitted to do so, we may transfer or assign personal data to third parties that provide products or services to or on behalf of Glenmark. We limit access to your personal information to those employees, business partners, agents, contractors and other third parties who have a business need-to-know.

Glenmark will carefully select such third parties and we will enter into appropriate written agreements including a duty of confidentiality. To the extent required, we will ensure that such third parties collect, store, use and disclose your personal information in accordance with applicable local privacy laws. Under certain circumstances, it may be appropriate to allow these third parties to determine the purpose and means of processing of your personal data in order to achieve specified purposes. You should refer to the contents of their respective privacy notices for further information in respect to the manner in which they process your personal data and any queries arising therefrom should be addressed to them directly.

How long will you use my information for?
In the event that you are unsuccessful in your application, we will retain your personal information for no longer than is legally required. After this period, we will securely destroy or anonymise your personal information in accordance with applicable laws and regulations with the exception of limited personal data necessary to enable us to identify candidates who may have previously applied for a role at Glenmark. This data will be minimal and proportionate to that necessary for achieving the aforementioned purpose.

If you would like Glenmark or Glenmark wishes to retain your personal information on file on the basis that a further opportunity may arise in future and for which you could be considered, explicit consent to retain your personal information will be required.

Your rights in connection with personal information
Under certain circumstances you may have the right to:

Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information Glenmark hold about you and to check that we are lawfully processing it.
Request correction of the personal information that Glenmark holds about you. This enables you to have any incomplete or inaccurate information Glenmark hold about you corrected.
Object to processing of your personal information where Glenmark is relying on a legitimate interest (or those legitimate interests of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
Withdraw consent to our processing of your personal information in circumstances where we are relying on your consent. This will not impact the lawfulness of any processing conducted prior to such withdrawal but may result in us being unable to further progress your application for work.
Request erasure of your personal information. This enables you to ask Glenmark to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask Glenmark to delete or remove your personal information where you have exercised your right to object to processing (see immediately above).
Request the restriction of processing of your personal information. This enables you to ask Glenmark to suspend the processing of personal information about you, for example if you want Glenmark to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.

If you want to exercise any right to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that Glenmark transfer a copy of your personal information to another party, please contact us by email at dpo@glenmarkpharma.com.

Sale of Personal Data
Glenmark do not sell personal data to other businesses or third parties under any circumstances.

Revisions to the Privacy Notice
Glenmark may update this privacy notice from time to time. In order to keep up-to-date with the ways in which Glenmark handles your personal data we request that you visit and review the relevant privacy notices on our privacy portal on a regular basis.

Questions
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 privacy notice, how we handle your personal information or wish to exercise any of your rights contained hereunder, please contact us by email at dpo@glenmarkpharma.com or alternatively contact our external DPO directly at dpo@ig-smart.com.

Complaints
If you are unhappy with the way in which Glenmark has processed your personal data please address any complaint to dpo@glenmarkpharma.com or alternatively contact our DPO directly at dpo@ig-smart.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
You are now leaving Glenmark’s website, and are being connected to a third party website. Please note that this website is third party owned and access will be subject to the cookie, privacy and legal policies of the external website.
Glenmark is not responsible for the information, content or product(s) found on any third party web sites.

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

This privacy policy outlines our practices regarding the collection, storage, use and disclosure of personal data meaning individually identifiable information about you or any other individual, that is collected or otherwise received by or on behalf of Glenmark as a result of:

the reporting of an adverse or unexpected drug event or reaction actually resulting from or suspected to result from a Glenmark pharmaceutical product;
the submission of product quality complaints;
the supply of safety or medical information relating to Glenmark products; or
product availability and stock issues and other product enquiries of a general commercial nature.

It makes you aware of how and why your personal data will be used, with whom it will be shared and for how long it will typically be retained.

Please be aware that this notice does not apply to Glenmark Life Sciences Limited, Ichnos Sciences Inc., or their respective subsidiaries.

Use of Personal Data
Glenmark by itself or through its nominated business partners or service providers, may collect, use and disclose personal data connected with the above mentioned activities and for the following purposes which may include but are not limited to:

assistance with the identification of rare and very rare adverse events;
the creation, management, review and updating of safety databases for the purposes of identifying drug risks and the detection of signals and patterns as well as to identify different profiles of known adverse reactions with regards to severity, nature or outcome;
responding to quality complaints regarding Glenmark products such as any fault of quality and/or effectiveness, stability, reliability, safety, performance or usage;
responding to medical information queries, for example in relation to clinical data, dosing and administration, formulation and stability and interactions with other drugs, foods and conditions;
responding to general information queries, for example product availability and stock issues;
answering other questions or requests and improving our products and services;
complying with our policies and local legal, regulatory and compliance requirements; and
conducting audits and defending litigation.

The Personal Data Collected
The personal data that may be collected, stored, used and disclosed includes but is not limited to:

Name (of patient and person reporting issue or complaint if applicable)
Contact information (of patient and person reporting issue or complaint if applicable) including home address, home phone number, mobile phone number, and email address
Citizenship and country of residence
Date of birth (age)
Gender
Weight
Dietary requirements
Health-related personal data such as medical history
vaccination status relating to an individual and in case of exceptional situations or serious threats to health such as a pandemic spread of a lethal contagious disease, their family members and in accordance with applicable laws and provided that proportionate to the aim pursued and with appropriate safeguards
other personal data contained or revealed through the use or maintenance of communications methods such as use and maintenance of Glenmark internal or external communications networks, equipment, applications or devices (for example, through voicemails, conference calls, telephone, video or telepresence, e-mails, correspondence, documents, and other work product and communications).

Methods of Collecting Personal Data
We may collect this personal data in various ways including the following:

directly from you;
from the reporter of the adverse event or adverse reaction on your behalf (for example, friend, family member, carer, pharmacist, doctor or other healthcare professional); or
via third party business partner(s) engaged to conduct medical information query handling and adverse event and product quality complaint reporting services on our behalf. Please be assured that 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 and applicable privacy laws;

On What Basis Do We Use Your Personal Data?
We collect and use your personal data only when there is a legal requirement or it is in our legitimate interest to do so in managing adverse events, addressing medical or general information queries and product quality complaints. Glenmark may process sensitive personal data such as that relating to health as this is necessary for it to discharge its pharmacovigilance duties as well as for reasons of substantial public interest such as ensuring the safety of medicines.

Access to Personal Data
Access to your personal data will be given to those who need such access for the purposes listed above or where required by law. These parties include, amongst others:

the Glenmark customer services team, medical affairs function, members of the quality assurance team and on limited occasion, information technology and legal departments;
third party business partners and service providers retained by Glenmark to assist with the performance of the activities outlined under this privacy notice.
regional or national regulatory authorities in their capacity of controlling pharmacovigilance databases; and
any national and/or international regulatory, enforcement, public body or court where we are required to make such disclosure by applicable law or regulation or at their request.

Where is Your Personal Data Stored?
Glenmark operates globally, and your personal data may be stored and processed by it or its affiliates as well as retained third party business partners and service providers in multiple jurisdictions including India where Glenmark is headquartered as well as nationally in the country in which you reside.

We maintain reasonable administrative, technical, and physical safeguards to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. In the event that we do transfer any personal data, we will only do so in accordance with applicable law, and will require that there is an adequate level of protection for the personal data and that appropriate security, technical and organisational measures are in place. We will at all times remain ultimately responsible for the protection of your personal data.

Glenmark has policies and procedures in place to ensure that we comply with all applicable laws in the event of a security incident leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data.

Your Rights
You may have certain rights regarding the personal data that we collect, use and hold about you. These rights may include the following rights:

to access the personal data we hold about you;
to block or suppress further use of your personal data;
to request the correction to or rectification of the personal data that we hold about you if that information is inaccurate or incomplete;
to object to certain types of processing;
to request the deletion or removal of your personal data;
to lodge a complaint with the competent data protection supervisory authority about the way we handle or process your personal data;
to withdraw your consent to our processing of your personal data at any time if this is the basis under which your personal data is being processed; and
to obtain from us, the personal data that we hold about you in a structured, commonly used and machine-readable form so you can reuse it for your own purposes across different services.

To request the exercising of these rights, please contact dpo@glenmarkpharma.com however, please note that in the case of blocking or suppression or further use of personal data, we may need to retain or continue processing certain information, for example on the grounds of substantial public interest in ensuring the safety of medicines and for legal purposes.

We will respond to your request as soon as practically possible and within the timeframes set forth by applicable law.

Retention and Accuracy of Personal Data Collected
Glenmark intends to keep personal data in its control accurate and up-to-date. We will retain personal data only as long as is necessary to carry out the purposes for which it was obtained and as described in this privacy notice.

Glenmark has internal retention policies and procedures that build upon the following criteria to determine suitable retention periods for personal data in the context of the above-mentioned purposes:

Sensitivity of the personal data
Safety and security reasons
Applicable statutes of limitation; and
On-going or potential investigations, litigation or disputes.

Sale of Personal Data
Glenmark do not sell personal data to other businesses or third parties under any circumstances.

Questions
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 privacy notice, how we handle your personal information or wish to exercise any of your rights contained hereunder, please contact us by email at dpo@glenmarkpharma.com or alternatively contact our external DPO directly at dpo@ig-smart.com.

Complaints
If you are unhappy with the way in which we have processed your personal data please address any complaint to dpo@glenmarkpharma.com or alternatively contact our DPO directly at dpo@ig-smart.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
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EMPLOYEES AND CONTRACTORS

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Purpose and scope
Glenmark, comprising Glenmark Pharmaceuticals Limited and its subsidiaries, affiliates, successors, assigns and representatives worldwide respect your privacy and are committed to protecting your personal data.

This Glenmark privacy policy outlines our practices regarding the collection, storage, use and disclosure of personal data meaning individually identifiable information about you or any other individual that is collected or otherwise received by Glenmark as a result of our commercial relationship.

It does not extend to Glenmark employees, directors, interns and permanent or temporary workers or agency staff and there is a separate privacy policy detailing the protection of their personal data available on Glenmark’s intranet site.

This privacy notice does not apply to Glenmark Life Sciences Limited, Ichnos Sciences Inc., or their subsidiaries.

Use of Personal Data
We may use and disclose personal data for purposes connected to:

the engagement or prospective engagement of you or your company for the supply of services to Glenmark;
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; and
to respond to legal requests from administrative or judicial authorities, in accordance with applicable laws.

The Personal Data that Glenmark Collects
The personal data that Glenmark may collect, store and use includes but is not limited to:

Name
Contact information (including home address, home phone number, mobile phone number, and email address)
CVs, qualifications and areas of subject matter expertise
Citizenship and country of residence
Date of birth (age)
Social Insurance Number or similar government-issued identification numbers
Gender
Bank account details
Marital status and incidentally, sexual orientation (when processing information related to marital status, family or dependents, such processing may unintentionally reveal a person’s sexual orientation by way of the name and gender of the partner)
immigration status and information, such as passport and other identity documentation, citizenship, residency and other visas, details regarding family composition (names, genders, ages, including re spouse, dependents, and parents) and criminal convictions
Languages spoken
Photographs
Signatures
Moving image and voice from video (both CCTV and creative videos)
Localisation data
Hobbies and interests
Driver’s licence, driving record, vehicle licence plate, parking tickets, traffic fines, GPS location, and route(s) travelled
Dietary requirements
Health-related personal data such as vaccination status relating to an individual or their family members in case of exceptional situations or serious threats to health such as a pandemic spread of a lethal contagious disease, in accordance with applicable laws and provided that proportionate to the aim pursued and with appropriate safeguards
Personal data contained or revealed through the use or maintenance of communications methods such as use and maintenance of Glenmark internal or external communications networks, equipment, applications or devices (for example, through voicemails, conference calls, telephone, video or telepresence, e-mails, correspondence, documents, and other work product and communications)
Next of kin.

Methods of Collecting Personal Data
We may collect this personal data in various ways including the following:

Directly from you
From the public domain
During your activities in the course of our engagement, such as through your performance and interaction with other workers or through your use of our systems; and
From other parties, such as:
- Reference providers
- Data providers
- Former workers; and
- Miscellaneous third parties such as background checking agencies, due diligence service providers, police departments, company-approved and third party travel management systems.

On What Basis Do We Use Your Personal Data?

We collect and use your personal data when this is necessary for the performance of a commercial contract (or other similar type of agreement) with Glenmark.

We may process some of your personal data when there is a legal requirement or it is in our legitimate interest to do so. This is the case, for example, when we collect and use your personal data to:

respond to a query you have raised
comply with regulatory or legal requirements (pursuant to and amongst others, labour, tax, and social security laws
secure our premises and IT systems
handle and investigate complaints through our Code of Conduct Hotline
prevent or investigate fraud or other criminal activities
undertake intra-group administrative transfers
provide seasonal or national holiday related gifts and bonuses
respond to an application for charitable gifts or donations
organise company events

Please note that personal data shared with Glenmark as part of a medical information query or the reporting of a product adverse event or product complaint is handled under a separate privacy notice entitled ‘Product Queries, Quality Complaints and Adverse Event Reporting’ available from our online Privacy Portal.

Sometimes, we may only process your personal data after you have given us your prior consent. For example, in certain circumstances we will ask your prior consent for marketing and promotional activities (please see our separate privacy notice entitled ‘Marketing Activities’ available from our Privacy Portal), before using your photos or videos as part of our corporate communications strategy or where we would like to retain your personal information perhaps for prospective future engagements but have no necessity or legal requirement to do so.

What Happens if You Do Not Provide Us with the Personal Data We Request or Ask That We Stop Processing Your Personal Data?
Our ability to perform our obligations derived from the commercial contract (or similar type of agreement) with Glenmark and our ability to comply with our legal and contractual obligations sometimes depend on Glenmark having access to and being able to use certain personal data.

Therefore, depending on the circumstances, if you do not provide us with the personal data we request or if you ask that we stop processing your personal data, we may not be able to perform our contractual obligations (such as paying you for your work) or we may be in breach of one or more legal obligations imposed upon us. In some cases, if we are not allowed to process your personal data, this may result in us being required to terminate our work relationship with you.

Access to Personal Data
Access to your personal data will be given to those who need such access for the purposes listed above or where required by law. These parties include, amongst others, the Glenmark human resources department, relevant business managers and, on limited occasions, members of the Information Technology ("IT"), finance, tax, legal and compliance departments.

Where we are lawfully permitted to do so, we may also transfer or assign personal data to third party business partners who provide products or services to or on behalf of Glenmark. These third parties may include and are not limited to pharmaceutical product licensing and commercial partners, payroll administrators, benefits administrators, financial consultants and financial services providers, professional advisers, IT systems providers (including enterprise resource planning and cloud-based software providers and consultants), outside counsel, expense claims providers, data management solutions providers, timekeeping solutions providers, hardware providers, travel and mobility companies (including company car management) and general administrative service providers.

Finally, personal data may be disclosed and transferred to respond to law enforcement requests, court orders, government regulations (including disclosures to tax, social security, and other authorities) or government entities to manage or administer Glenmark’s financial and tax affairs. We may also disclose personal data to external legal counsel to assist us with the establishment and defence of legal claims or to other third parties also engaged in such legal matters (for example, to the adverse party in court proceedings, to judicial experts or to other stakeholders involved in the claim).

Where is Your Personal Data Stored?
The aforementioned recipients of your personal data and their information storage systems may be located in other countries. Equally, Glenmark operates globally, and your personal data may be stored and processed by it in multiple jurisdictions such as India where the company is headquartered as well as locally in the country in which you reside.

In the event that we or our partners transfer any personal data, we will ensure that this is only done so in accordance with applicable law, and will require that there is an adequate level of protection for the personal data and that appropriate security, technical and organisational measures are in place.

Glenmark has policies and procedures in place to ensure that we comply with all applicable laws in the event of a data breach leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data.

For more information about the safeguards relating to cross border personal data transfers or data breach please contact dpo@glenmarkpharma.com

Your Rights
You may have certain rights regarding the personal data that we collect, use and hold about you. These rights may include the following:

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.

Object to processing of your personal data In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

These rights can be exercised by contacting dpo@glenmarkpharma.com however, please note that in the case of blocking or suppression or further use of personal information, we may need to retain or continue processing certain information, for example for legal or administrative purposes (for example the maintenance of social security records).

We will respond to your request as soon as practically possible and within the timeframes set forth by applicable law.

Retention and Accuracy of Personal Data Collected
Glenmark intend to keep personal data in its control accurate and up-to-date. We will retain personal data only as long as is necessary to carry out the purposes for which it was obtained and as described in this privacy notice. If there are any changes to your personal data, please notify the business function with whom your Glenmark relationship is held or the human resources department accordingly. If you inform us of any changes or we otherwise become aware of any factual inaccuracies in your personal data, we will seek to promptly correct such inaccuracies.

Glenmark has internal retention policies and procedures that build upon the following criteria to determine suitable retention periods for personal data in the context of the abovementioned purposes:

End of the contractual relationship with Glenmark
Sensitivity of the personal data
Security reasons
Applicable statutes of limitation
On-going or potential litigation or dispute; and
Regulatory or legal obligation to retain the personal data (for example, for social security purposes or in the context of CCTV surveillance).

Monitoring
Under certain circumstances, Glenmark may monitor the use of its information systems including for the purposes of detecting and addressing information security threats or improper use of Glenmark’s information systems. This may require the processing of certain personal data of individuals related to their use of information systems.

Sale of Personal Data
Glenmark do not sell personal data to other businesses or third parties under any purposes of processing.

Revisions to this privacy notice
Glenmark may update this privacy notice from time to time. In order to keep uptodate with the ways in which Glenmark handle your personal data we request that you visit and review the relevant privacy notices on our privacy portal on a regular basis.

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 website or similar environment, such as mobile websites or apps that are operated and maintained by us and from which you can access this privacy notice (collectively, the “websites”).

Application and Scope

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

Our websites are neither intended for nor do they offer products and services for children/minors. We do not knowingly collect or process data relating to children/minors.

Third-party links

Our websites 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 websites, 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.

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.

If the terms of this privacy notice are not acceptable to you, then you should not access or use the website in any manner. However, at point of time or after giving your consent, if you wish that we should not process your personal data, you may withdraw your consent in the manner as described in this Privacy Notice. Please note that in case you withdraw your consent, you may not be able to access or use the website or some features of the website.

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).

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

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

Identity Data first name, last name, username or similar identifier, title, job title, qualifications, date of birth, email address, telephone number and address;

Technical Data internet protocol (IP) address, MAC 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 information about how you use our website, products and services;

Financial data shared by you as part of your purchase of pharmaceutical products from our website(s);

Health related data such as medical/health records, treatment plans, health insurance plans, medication history and related data;

Service data relating to products and services offered on our website such as membership details, registrations numbers and product and services reviews and ratings; and

Marketing and Communications data your preferences in receiving marketing and promotional material from us and our third parties including your communication preferences such as type, format and frequency.

3. Ways in which Personal Data is Provided
We use different methods to collect data from and about you including through automated technologies or interactions.

Information you provide. We may ask you to provide, or you may choose to provide information. Such information may be provided to us at various times, including, without limitation: when you fill in specific forms online; when you register on a Glenmark website or on other Glenmark platforms; when you register for an event or webinar via a Glenmark website/platform or by contacting us offline; when you request information or services; and when you purchase products directly from a Glenmark website.

Information collected automatically. If you interact with our websites or other online portals and systems, 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 conduct direct marketing activities, including sending you targeted emails and offers but always and only in accordance with applicable privacy laws.
to improve our interactions with you, to enhance our website, to personalise your use of our websites, by presenting you with product information and services 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. Applicable national laws 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 respond to legal requests from administrative or judicial authorities, in accordance with applicable laws.
to fulfil product purchase orders and service requests placed through our websites.
to provide details about loyalty programs owned and operated by us.
for billing, pricing and administration purposes and to handle your requirements, queries, complaints and feedback.

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 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. Once you have given consent to our use of your personal information, you are entitled to withdraw this consent at any time by various means including unsubscribing via the corresponding link provided within marketing emails we send to you or by contacting us at dpo@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 may seek to object to this use of your personal information accordingly.

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 ensuring your legitimacy to view certain website content 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:

Service providers, who provide services such as website hosting and moderation, order fulfilment, payment processing, the processing of your reviews of products and services, the provision of call centre services, the hosting of mobile applications, data analysis, infrastructure provision, IT services, customer services, delivery services for e-mails and direct advertising. Here too, these service providers are not permitted to use your personal data for their own purposes, however, we may allow them to determine and control the manner in which they process your personal data in order to achieve the specified purposes for which such personal data was originally provided.

International Transfers

Glenmark is a global company. The personal data we collect from you may be stored, accessed or processed in any country where we maintain branches or the aforementioned parties are 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, service providers, contractors and other third parties who have a business need to know.

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.

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.

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.

These rights can be exercised by sending an email request to dpo@glenmarkpharma.com. We will respond to your request as soon as practically possible and within the timeframes set forth by applicable law.

10. Sale of data
We do not sell your personal data to other businesses or third parties under any circumstances.

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@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@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
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Glenmark is not responsible for the information, content or product(s) found on any third party web sites.

May 2024

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