This Privacy Notice describes how BeiGene Switzerland GmbH (hereafter “BeiGene”, “we”, “our”, “us”) uses, stores and discloses (together “processes”) the personal data we collect through this website. In any event, collection and processing of personal data will only take place conformable to the applicable data protection and privacy law (i.e. the General Data Protection Regulation – GDPR).
1. Use of Data and Legal Basis
1.1. Use of Data and Legal Basis
We process your data in order to provide you with the agreed or requested services on this website:
- If you register and log in;
- if you take part in training courses or events;
- if you send us inquiries about products or possible adverse event.
The legal basis is Article 6 (1) b) GDPR and Article 6 (1) c) GDPR if you send information about possible adverse events (see section 3 for specific information about adverse events).
1.2. Log data
1.3. Cookies and similar technologies
In the following section we will differentiate between different categories of Cookies.
1.3.1. Essential cookies
Essential Cookies are necessary for the website to function properly. Such Cookies make a website usable by providing basic functions such as page navigation and access to secure areas of the website or language settings. Due to their importance for the website’s functioning, you cannot opt-out from this kind of Cookies. We base the related processing of personal data on Art. 6 (1) b GDPR, the contractual provision of our services.
Essential Cookies we use to provide this website include Cookies, which
- detect whether a user uses Java Script,
- allow a visitor to receive site content from one out of multiple servers as the user browses the site,
- determine whether a user has accepted which category in the Cookie banner,
- maintain the status of the user for all page requests.
The lifetime of essential Cookies we use extends from the respective session up to one year.
1.3.2. Cookies for Website Optimisation
We use the following services of third-party providers:
On this website, we use the Piwik PRO Analytics Suite (“Piwik PRO”) analysis program from the company Piwik PRO GmbH, Lina-Bommer-Weg 6, 51149 Cologne, Germany. This software is used to collect data that enables us to tailor our website’s design to user requirements and statistically evaluate visitors’ flow for marketing and optimization purposes. Pseudonymous usage profiles are also created in this context. Cookies are used for this purpose, which are stored on your computer and which enable a pseudonymous analysis of your use of our website. The IP address is immediately truncated after collection and prior to storage. Piwik PRO Marketing Suite Cloud is hosted on Microsoft Azure in Germany.
Piwik Pro always tracks anonymously. If the user consents to the use of Analytics, the tracking is enriched pseudonymously. This makes it possible, for example, to identify returning users and perform more precise analyses.
The legal basis for this processing is our legitimate interest according to Art. 6 (1) (1) f GDPR. The information collected by the cookies about the use of our website is stored on servers of Piwik PRO or service providers commissioned by them in Europe. The IP address is anonymized immediately after processing and prior to storage. The information generated by Piwik PRO is not used to identify visitors personally and is not merged with other personal data of the user.
You can specify in the consent banner as well as subsequently in the footer via the link “Consent Management” whether you consent to us using PIWIK PRO in the manner described. If you choose not to do so, a PIWIK PRO deactivation cookie will be deposited on your end device (“opt-out” cookie). Please note that your browser must accept cookies in order for this cookie to be deposited. If you delete the deactivation cookie, you may have to opt-out again.
Piwik Tag Manager
This website uses Piwik Pro Tag Manager. This service allows website tags to be managed via an interface. Piwik Pro Tag Manager does not set any cookies, only tags, and does not collect any personal data. The service triggers other tags, which in turn may collect data. A tag is only triggered if the user has consented to this beforehand. If the user does not grant specific permissions in Piwik Consent Management, the corresponding tags will not be triggered. Tags that do not process personal data are always loaded. However, Piwik Pro Tag Manager does not access this data. If deactivation has been made at the domain or cookie level, it will apply to all tracking tags implemented with Piwik Pro Tag Manager.
The Cookies related to this service allow us for example to
Create a unique ID for users and enabling us to track visitors across our different domains,
Determine, if Cookies are enabled,
Captures statistics about the user’s visits to the website,
Identify the time (in days) between two visits by the same visitor,
Learn about the number of visits by a single user.
1.3.3. Further purposes for which we process your personal data
We process your personal data to:
meet our legitimate interests, including to:
- complete a corporate transaction (e.g., corporate restructuring, sale or assignment of assets, merger); and
- meet our legal obligations, any court order or other binding decision.
2. Data Transfer
We may share personal information with third parties.
2.1. Reporting obligations to regulatory authorities and enforcement of rights
As a pharmaceutical company, we are subject to specific regulations, such as pharmacovigilance. Therefore, we may share personal data in pharmacovigilance cases as specified in Section 3.
In order to protect our rights or the rights of third-parties, we may also disclose data to rights holders, consultants and authorities in accordance with legal provisions.
2.2. Service provider
We engage service providers to process your personal data for the purposes described in this data protection information. These service providers process the data only on our behalf, in accordance with our instructions and under our control in accordance with this data Privacy Notice.
Service providers are:
Piwik PRO SA, ul. św. Antoniego 2/4, 50-073 Wrocław, Poland providing data and web analytics services.
Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA hosting provider.
infill healthcare communication GmbH, Boserother Straße 37, 53639 Königswinter, Germany, user data handling agent.
2.3. BeiGene companies
As part of a global group of companies, we involve other BeiGene companies that support us in data processing. These group companies process the data exclusively for the purposes stated in this data Privacy Notice.
2.4. Data transfer to recipients outside the EU
Some of these service providers and BeiGene companies process personal data outside the EU. In these cases, we ensure an adequate level of data protection to comply with European law (usually through EU standard contractual clauses published by the European Commission).
3. Specific Privacy Notice for Pharmacovigilance
If you report adverse events or other pharmacovigilance relevant information to a BeiGene product we will use and share this data solely for pharmacovigilance purposes. (Pharmacovigilance is the detection, assessment, understanding and prevention of adverse effects or any other medicine-related problem.)
All reports will be shared with BeiGene, Ltd. and its subsidiaries who are operating the global pharmacovigilance database.
BeiGene is obliged to report pharmacovigilance relevant information to health authorities worldwide (including to countries that may have another level of data protection compared to the EU). Legal basis: Art. 6 (1) c), and for transfers outside EU Art. 6 (1) f) and Art. 49 (1) e) GDPR.
The reports will contain details about the incident but only limited personal data:
- For Patients, the report will only contain, age, gender and initials as provided, but never the patient’s name.
- For the reporting individuals, the report will include the name, profession (e.g. physician, pharmacist), initials or address, e-mail and phone number as provided. The contact information is required to be able to follow-up with the reporter to gain high quality and complete information on adverse events. If the reporter does not wish to provide his contact details to BeiGene or authorities, “Privacy” is entered in reporter’s names field.
Where your data is shared with other BeiGene companies, business partners or service providers outside of the EU, we will provide an adequate protection of personal data.
As reports about adverse events are important for public health reasons, reports are kept for minimum of 10 years after withdrawal of the product in the last country where the product is marketed.
BeiGene processes your personal data for as long as necessary for the purpose of the processing, which mainly is the provision of our services requested by you. This means for example that we send you newsletters for as long as you did not withdraw your subscription or that we store your user account data (login, profession, name etc.) for as long as you maintain a user account with us.
In general we will delete data related to:
- your (customer) requests after 3 years,
- analytics data (website use) after 3 years.
5. Your Rights
Subject to limitations in applicable law, you have a right of access, rectification, restriction, erasure, and portability of your personal data, as well as the right not to be subject to automated individual decision-making.
You also have the right to withdraw your consent at any time.
Right to object
To the extent we base the processing on our legitimate interests, you may opt-out from such processing at any time. In this case, we will not process such personal data any longer unless our interests prevail. You can object to the use of data for direct marketing purposes at any time. You may also object to the processing of your personal data for the transfer to authorities outside the European Union described above in Section 3 for pharmacovigilance cases unless the interests of BeiGene prevail.
Please send your request or any question you have in relation to our processing of your personal data to:
BeiGene Switzerland GmbH