Privacy and Cookie Policy

Last updated June 15, 2018

Boehringer Ingelheim Pharma GmbH & Co. KG and Boehringer Ingelheim Limited and its group of companies (hereafter “Boehringer Ingelheim”, “we”, “us” or “our”) takes the protection of your Personal Data seriously. This privacy statement describes what Personal Data is collected from health care professionals (“you”) and how we use such data. The privacy statement explains different scenarios to give you a clear understanding of what information Boehringer Ingelheim collects and uses for which purposes. We encourage you to click on the “more information” links in each section where you are interested in additional information.

The data controllers are  Boehringer Ingelheim Pharma GmbH & Co. KG, Binger Straße 173, D-55216 Ingelheim am Rhein and Boehringer Ingelheim Limited, of Ellesfield Avenue, Bracknell, Berkshire RG12 8YS (Company Number 711858).

A. What is Personal Data?

Personal data is information that can be used to identify you ("Personal Data").

More information

According to data protection laws, Personal Data is defined as any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, e.g. by reference to an identification number.

Examples for Personal Data are not only your name, your email address and your phone number, but also any other information that is or can be connected with your name. This could, for instance, be your medical specialty: If we store information about samples we sent to a person and that data is not attached to the person's name but to an identifier (such as the number 1234), this data is Personal Data if we can connect the number 1234 to that particular person's name.

B. When do we collect which categories of Personal Data?

We collect Personal Data in a number of different ways:

1. Information you provide us on the website when registering

When you register for a protected area of the website or when you order information material, Boehringer Ingelheim may ask you to provide certain Personal Data (in particular full name, email address, work address, medical specialty etc.).

2. Information you provide us when you interact with us

We collect information from you when you interact with us, e.g. when you sign-up for an event, when you communicate with us via email, when you request and receive samples or other materials, data about visits from representatives (such as feedback about our products).

You are free to determine the scope of our collection and use of your Personal Data in the Your Profile page. Please note that this will affect the information we will provide to you, for example you may receive less accurate communications where we are not able to use some of your Personal Data.

More information

The Personal Data which we receive and use may be the following (based on your choices):

• Name and contact data of you, including first and last name, postal address, email address, phone number or other contact data.
• Credentials including passwords, security questions or other security information.
• Your profession as health care professional as well as your therapeutic fields.
• Your interests, e.g. which events you are visiting, what information you request from Boehringer Ingelheim or other interests we learn about from interactions with you such as sales rep visits.
• Online Behaviour consist of data that is created during your electronic interaction with us. It may include your IP address or any browser information when you navigate on our website (e.g. the Your Profile page), which links you click and more information how you use emails you receive from us.
• Communication from you: We store and process the content of information we receive from you. For instance, if you write us an email, we may store this email to analyze your interests.

3. Log data

When using the website, certain data, including data sent by your browser (e.g. IP address, cookies, referring web page, time and date, content viewed) will be stored temporarily.

More information

Log data may, e.g., contain the following data fields: Requested URL, request method, your IP address, your IP port, the protocol version, your browser language, the last page you visited (referrer) as well as name and version of your browser (user-agent).

4. Information received from third parties

We may collect Personal Data about health care professionals who register from public or third party information sources, especially to verify their professional credentials and their identity.

C. How does Boehringer Ingelheim use your Personal Data and for which purposes?

In this section, we explain to you for which purposes and how we use your Personal Data.

1. General Purposes

We use your Personal Data to maintain your account and to deliver products or services you requested from us. We may also use your Personal Data to protect against unauthorized access and security issues. Further, Boehringer Ingelheim may use aggregated or anonymized information to help improve the websites.

2. Commercial and medical information from Boehringer Ingelheim

When we plan to send you information about our products or our events we consolidate data available about you (e.g. which pages you visited, about your therapeutic fields and events you attended). Based on this information we use software tools to choose the content and combine available channels for a seamless communication with you. You can always change your settings in the Your Profile page to manage the information we may use and the communication channels.

More information

What does "consolidating Personal Data" mean and how do we choose which information we send you? We only want to provide you with information about our product and service offerings such as pharmaceutical and medical products and services, promotions, news and events that we believe may benefit you. Therefore, we may bring together and analyze your Personal Data in order to learn more about you and your professional interests, This includes:

Online behaviour, which means data about your actions when you visit our website such as viewed pages, clicks, materials downloaded, emails opened.

• Interactions between you and us, for instance via a call center, a representative or a third party
• Events you attend, for instance medical conferences, educational events or peer to peer meetings
• Feedback you provide us, for instance through surveys or automated calls
• Requests you might have, for instance regarding promotion material, samples or a visit of a representative
• Information that our representatives collect from you.

How do we get in contact with you? We may provide you with information through emails, mails, calls, our website or other means. We aim to communicate seamlessly over various channels, which means that we strive to not provide you the same information per email, mail and via our representative. Instead, we combine available communication channels (according to your preferences in the Your Profile page) and provide information based on your Personal Data.

When choosing the information we communicate to you we use software tools analyzing the data available to create different groups of recipients which will receive different information.

• Example: If you participate in events that inform you about asthma therapies and download materials containing information about the newest asthma research, we may assume that you are interested in additional information about such asthma therapies. Therefore, we may provide you with additional material over various channels, for instance, a Boehringer Ingelheim representative may visit you and present you related product samples or – if you are very responsive to newsletters – we may send you further e-mails with information about asthma therapies.

3. Reporting obligations to regulators

As a pharmaceutical company, Boehringer Ingelheim is subject to specific regulations, such as pharmacovigilance. Some of those laws may require us to send reports to regulators or other authorities. We will only provide Personal Data to authorities where legally required.

D. Cookies

We use cookies and similar technologies such as pixel tags, web beacons and clear GIFs (referred to hereafter as “Cookies”). Cookies are widely used in order to make websites work, or work more efficiently, as well as to recognize your device on subsequent visits to provide information to the owners of the site.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site.

For more information on cookies go to www.allaboutcookies.org. Boehringer only uses cookies to provide and enhance our services to users.

More information

Different types of Cookies exist:

• Necessary Cookies Necessary Cookies are used for "technical" reasons, such as re-establishing a user’s session at login if their previous session was cancelled due to user inactivity. Such Cookies are not used to analyze the use of our website or emails.

• Analytical Cookies

These Cookies help us analyzing the use of our website and emails: They allow us to analyze activities on our sites in order to improve and optimize the way our sites work. For example, we may use these types of Cookies to ensure that visitors can easily find the information they are looking for on our sites. One way we do this is to recognize and count the number of visitors and see how they move around our site when they are using it. Analytics Cookies also help us measure the performance of our advertising campaigns and to optimize our sites’ content for those who engage with our advertising. Cookies play an important part when we choose which information we send to users (see section C.2 above for more information on this).

One way you can manage the acceptance of Cookies is through your browser’s settings. Most browsers allow control of Cookies through the browser settings (please note that if you use your browser settings to block all Cookies you may not be able to access parts of our websites). The following list provides information on how to adjust the Cookies settings on some popular browsers:

Apple Safari
Google Chrome
Microsoft Internet Explorer
Mozilla Firefox

You can also use a browser plug-in such as Ghostery from Evidon Inc. or the Tracking Protection List from TRUSTe.

Adobe Analytics

We use Adobe Analytics, a web analytics service provided by Adobe Systems Software Ireland Limited (“Adobe”). Adobe Analytics uses Cookies in order to analyze overall traffic and usage patterns on behalf of Boehringer Ingelheim. The IP address collected by the Cookie is anonymized before geo-localization is performed. Boehringer Ingelheim may associate your IP with other Personal Data, which may identify you; however, Adobe will not associate your IP address with any other data held by Adobe. You can prevent Adobe’s collection and use of data (Cookies and IP address) by making use of your options under http://www.adobe.com/privacy/opt-out.html.

E. How and when do we share information?

Boehringer Ingelheim only transfers Personal Data to third parties according to applicable law, especially when you have expressly given your consent, when required to deliver services that you ordered, or when we engage service providers that use Personal Data on our behalf and according to our instructions.

Boehringer Ingelheim undertakes to ensure an adequate protection of Personal Data transferred outside of the European Union (usually using EU Model Contracts which have been issued by the European Commission).

More information

Third parties that may receive Personal Data are the following:

1. Regulators

Where we are legally obliged to do so (see section C.3 above), we will share information including Personal Data with regulators or other competent authorities.

2. Service providers and Boehringer Ingelheim companies

We employ other companies, including other Boehringer Ingelheim Group companies, to store, manage and analyze the Personal Data about you. Where we employ third party companies which do not belong to Boehringer Ingelheim Group or individuals to process Personal Data provided by us (and not collected by themselves), they only process such Personal Data on our behalf, based on our instructions and in compliance with this privacy statement.

One of our service providers is Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland which is providing data and web analytics services.

Involving other companies may be necessary for other services.

Where those companies are located outside of the EU/EEA we ensured by means of contractual clauses or other approved instruments that the Personal Data transferred to those companies is adequately protected. Adequate protection means that the protection of Personal Data complies with the level of protection that exists in the EU/EEA.

3. Healthcare information providers

When we receive incorrect Personal Data from healthcare information providers such as IMS Health (see section B.4 above), we inform these providers where their data is incorrect.

4. Anonymous information

We may also share aggregated or non-personally identifiable information with other parties.

F. How long do we store Personal Data?

We will retain your Personal Data as long as required for the specific business purpose or purposes for which it was collected. We will regularly check if the data we store about you is still relevant for communicating with you. If it is not, we will delete it. We may be obliged to store some data for a longer time than selected by you (e.g. in cases of pharmacovigilance). In this case, we will ensure that your data will not be used for direct marketing purposes.

G. How we secure your Personal Data

We use industry standard practices to protect the confidentiality, integrity, and availability of your data, e.g. by access controls. All Personal Data you provide to us is secured using industry standard procedures. We strive to update our security measures on a regular basis to keep track of new industry standards.

H. Who we are and how to contact us

The Personal Data is collected and used by

Boehringer Ingelheim Limited

Ellesfield Avenue, Bracknell, Berkshire RG12 8YS, and
Boehringer Ingelheim Pharma GmbH & Co. KG

Binger Straße 173

D-55216 Ingelheim am Rhein.

Boehringer Ingelheim is an entity of the Boehringer Ingelheim group of companies (hereinafter the “Boehringer Ingelheim Group”). The Boehringer Ingelheim Group is one of the world's twenty leading research-driven pharmaceutical companies. Its headquarters are located in Ingelheim, Germany.

If you have any questions or other enquiries regarding our collection and use of Personal Data or this privacy and cookie policy or would like to inform us of any incorrect Personal Data held by us, please feel free to contact us at any time:

Boehringer Ingelheim Limited

Ellesfield Avenue, Bracknell, Berkshire. RG12 8YS

communications.bra@boehringer-ingelheim.com

Both entities cooperate closely when using Personal Data and are designated "joint controllers", meaning that each entity is responsible for all use of Personal Data in the platform.

I. What are your rights?

Upon your request, we will inform you in writing or electronically whether and what Personal Data relating to you Boehringer Ingelheim has stored and will review any requests you may have.

You can also withdraw a consent you may have given to the collection and/or processing of your Personal Data at any time with effect for the future via the Your Profile page or by mail/email to the addresses mentioned in section H above.

In case you have any questions or concerns regarding our use of your Personal Data and if you do not wish to contact us directly, you may also contact the data protection authority competent for us which is the Information Commissioner’s Office.

or

"Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Rheinland-Pfalz, Hintere Bleiche 34, 55116 Mainz".

• Right to access, modify or delete your Personal Data

You can always access your Personal Data by asking us what Personal Data we store about you.

As an alternative, you may modify, add, delete or update your Personal Data or request deletion of Personal Data by emailing us at communications.bra@boehringer-ingelheim.com or by contacting us as described in section H above.

In case you request deletion of Personal Data, you may no longer be able to use all features and functions of our services. Please note that we may be required to keep some of your Personal Data for legal reasons, for instance to comply with statutory retention periods or for tax purposes. In such cases, we will mark your Personal Data accordingly to make sure that it is not used for any other purpose than complying with the retention requirement.

• Right to opt-out of marketing

You can unsubscribe from marketing-related emails by following the unsubscribe instructions included in each email. You can also go to our Your Profile page where you can manage specific opt-ins and opt-outs. If you do not want us to use any of your Personal Data for direct marketing or market research purposes, you can inform at us any time using the contact details under section H above.¹

J. How do we make changes to this privacy and cookie policy?

We may update this privacy and cookie policy from time to time and for any reason. We will notify you of any changes to our privacy statement by posting the new privacy statement here or, if the changes are material with regard to information collected from you, by posting a prominent notice on our website or by sending an email to the email address you provided to us prior to the change becoming effective. If required, we may also seek your prior consent. You should consult this privacy and cookie policy regularly for any changes.