Privacy POLICY

EUSA Pharma (UK) Limited (“We” our”, “us”) recognizes the importance of protecting the privacy of personal data we may receive about Patients (“you”, “your”) as visitors by visiting this website and we are committed to protecting and respecting your privacy.

This policy (together with our Terms of Use, our Cookies Policy and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us by visiting our website. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.mysylvant.com (the “Site”) you acknowledge that you have read and understood the practices described in this policy.

This website is a disease awareness website operated by EUSA Pharma (UK) Limited. Its content is addressed only to adult iMCD patients who are HHV-8 and HIV negative, already in treatment with SYLVANT (siltuximab), a FDA/EMA approved therapy for idiopathic Multicentric Castleman Disease (iMCD), from the United Kingdom and Europe. For the purpose of the UK Data Protection Act 2018 (the Act) and the EU General Data Protection Regulation (GDPR), the controller is EUSA Pharma (UK) Limited of Breakspear Park, Breakspear Way, Hemel Hempstead, Hertfordshire, HP2 4TZ.

Information we collect from you

In most cases, we will collect data directly from you (e.g., when you visit our website; you contact us). In particular, we will collect and process the following data about you:

• Information you give us. This is information about you that you give us such as declaring that you are a patient having already a Sylvant prescription or by corresponding with us by phone, e-mail or otherwise when you reach out to a EUSA Pharma medical information contact (Sylvant^® support).
  
  The information you give us may include your name, address, e-mail address and phone number, financial and credit card information.
• Information we collect about you. With regard to each of your visits to our Site we will automatically collect the following information:
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), listening data (descriptions of the title, episodes, segments included in a podcast/video of patients’ journey, time and date stamps for download material and playback events, session IDs and information about the device or platform used to download or play a particular file), products you viewed; page response times, download errors, duration of page visits, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate (as mentioned above) or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this Site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, healthcare professionals, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our Site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

The legal basis for processing your personal data

In order to comply with applicable data privacy laws, we are required to set out the legal basis for the processing of your personal data. In accordance with the purposes for which we collect and use your personal data, as set out above, the legal basis for us processing your personal data will typically be one of the following:

• your consent;
• our own or our third parties’ legitimate business interests (for example, in maintaining and promoting our business by providing customers with feedback opportunities or other instances where we have carried out a legitimate interests assessment and have established an existing legitimate interest); or
• compliance with our legal obligations.

Uses made of the information

We use information held about you in the following ways:

• Information you give to us. We will use this information:
  • to provide you with the information, products and services that you request from us;
  • to support you access the podcast/videos, material as well as to listen or download the recorded podcasts/videos or pdf material that might interest you;
  • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
  • to notify you about changes to our service;
  • to ensure that content from our Site is presented in the most effective manner for you and for your computer.
  • to comply with legal or regulatory obligations and the directions of law enforcement agencies and court orders - for example to detect, prevent, and respond to intellectual property infringement claims or violations of law.
• Information we collect about you. We will use this information:
  • to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
  • as part of our efforts to keep our Site safe and secure.
• Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your information

We may share your personal information with:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
• Selected third parties including:
  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • analytics and search engine providers that assist us in the improvement and optimisation of our Site (if you provide your permission to do so).

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If EUSA Pharma (UK) Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers/ individuals interacted with, will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of EUSA Pharma (UK) Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Security and storage of your personal data

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy, applicable data protection laws and regulations as well as international security standards. The data that we collect from you is stored inside the European Economic Area (“EEA”) and accessed and used subject to our security policies and standards. All information you provide to us is stored on our secure servers. We have implemented reasonable physical, technical and managerial controls and safeguards to keep your personal data protected from unauthorised access, disclosure, alteration, and destruction. Your access to your personal data is limited to a restricted number of our staff whose duties reasonably require such information and third parties with whom we contract to carry out business activities on our behalf. Our staff has been trained on the importance of privacy and how to handle and manage personal information appropriately and securely. However, your information may also be transferred within or outside the EU/EEA where privacy laws may be less strict than in the EU-EEA/UK.

In such case, we will implement reasonable and appropriate legal, technical and organizational security measures with the aim to ensure the security of the processing and in particular to protect your personal data from unauthorised access, use or disclosure. In the absence of an adequacy decision adopted by the European Commission or a competent data protection authority, we will implement appropriate data transfer mechanisms (such as the UK or EU Standard Contractual Clauses) for any cross-border data transfers located in a non-EU/EEA third country with the aim to secure such transfers and achieve an adequate level of data protection.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Records retention

We will keep your personal data for as long as we need it for the purposes set out above, and so this period will vary depending on your interactions with us. Data may be retained for a longer duration where applicable laws or regulations require, or allow us to do so. Where we no longer have a need to keep your information, we will delete it.

Your data protection rights

Under applicable data protection laws and subject to any legal restrictions, you may have the right to request us to: (i)access information held about you(ii) request access to all the personal data we hold about you; (iii) request that any inaccurate personal data we hold be corrected; (iv) to object to certain types of processing of your personal data we carry out (including the right to opt-out of any direct marketing); (v) request that we delete the personal data we hold about you; (vi) to request a copy of your personal data in a machine reasonable, commonly used format (or to request we transfer your personal data in such a format to a third party service provider); (vii) restrict certain aspects of the processing of your information and (viii) to stop a particular processing when you withdraw your consent.

You can exercise these rights by writing to us or by sending an e-mail to privacy@eusapharma.com.

For EU residents: In case we do not handle your request timely or if you are not satisfied with our response to any exercise of these rights, you are entitled to lodge a complaint with the competent supervisory authority of your place of residence. Further information and contact details of the European competent supervisory authorities can be found here.

For UK residents: In the UK, the responsible Data Protection Authority for the management of public complaints is the Information Commissioner’s Office (ICO); you can contact ICO here: The Information Commissioner’s Office | Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF | Website: https://ico.org.uk | Tel. +44 1625 545 700 | Helpline number: 0303 123 1113.

Redirect to other web sites

Our Site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites as the terms in this policy apply solely to information collected by EUSA Pharma (UK) Limited.

Changes to our privacy policy

EUSA PHARMA (UK) Limited reserves the right to amend this policy from time to time to reflect technological advancements, legal and regulatory changes, and our business practices, subject to applicable laws. Any changes we make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our Privacy Policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@eusapharma.com.

Updated 15 December 2021