Effective Date: October 2022
WHY THIS DOCUMENT?
As part of its day to day operation, SANOFI provides access to a variety of tools and resources which are destined to provide information to all the individuals with whom it has business interactions with (patients and their relatives, participants to clinical trials, healthcare professionals, users of products and services, workers, etc.) regarding its activities.
Such tools and resources may be provided in various formats, including, more specifically in electronic format and by means of online electronic communications, including the website available at UnderstandingTTP.com and any other website made available by SANOFI and to which this policy applies (hereinafter together the “Website”). In order to be able to provide them, SANOFI may need to collect and process Personal Data (as defined below) of their users.
SANOFI is fully committed to the protection of Personal Data and intends to provide you with all relevant information regarding the way in which SANOFI processes your Personal Data on the Website.
WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA ON THIS WEBSITE (THE CONTROLLER)?
Genzyme Corporation is responsible for the processing of Personal Data of individuals using this website and therefore acts as the Controller:
450 Water Street,
Tel.: +1 (617) 252-7500
WHAT PERSONAL DATA DOES THIS WEBSITE COLLECT?
When operating, this Website may collect the following categories of Personal Data:
Connection data: any information regarding your connection and access to this Website (e.g. type of machine and browser used, timestamp of your connection, IP address, pages visited, etc.), browsing history
Location data: information that may be provided by your machine and browser about your location if you allow such information to be shared with SANOFI
Data relating to and data which may be collected by cookies: for more information about cookies, please see below.
FOR WHAT PURPOSES DOES THIS WEBSITE COLLECT PERSONAL DATA?
Any processing of Personal Data must be implemented for a defined purpose. In this respect, the collection and processing of Personal Data on this Website is conducted for the following purposes:
To allow you to navigate this Website
To personalize your browsing experience: when using our services; ensure that our services are presented in the way that best suits you; understand your professional and personal interests in our content, products and services or other content and adapt our content to your needs and preferences; present you products and offers tailored to you
To improve our products and services identify usage trends and develop new products and services; understand how you and your device interact with our services; track and respond to safety concerns; determine the effectiveness of our promotional campaigns, conduct surveys;
To allow us to communicate with you; respond to your requests or inquiries; provide support for products and services; provide you with important information, administrative information, required notices, and promotional materials; send you news and information about our products, our services, our brands, our operations; organize and manage professional events and congresses, including your participation to such events
ON WHAT GROUNDS DOES THIS WEBSITE PROCESS YOUR PERSONAL DATA?
For the purposes of this Website, your Personal Data is only processed on the basis of:
the “legitimate interest” of SANOFI in the sense of applicable data protection law. In such a case, SANOFI shall consider your fundamental rights and interests in determining whether the processing is legitimate and lawful.
HOW LONG IS THE PERSONAL DATA COLLECTED ON THIS WEBSITE RETAINED?
The Personal Data collected on this Website will be retained for the following periods, depending on the categories of Personal Data processed
Connection data: Up to 26 months
Location data: Up to 26 months
WHO HAS ACCESS TO PERSONAL DATA
SANOFI may transfer your Personal Data both internally (i.e. to other SANOFI entities) and/or externally to third party service providers for the purposes of: to allow you to navigate this Website, to personalize your browsing experience, and to improve our products and services and to allow us to communicate with you.
Where such internal or external transfer of Personal Data implies the transfer of your Personal Data to a country providing a lower level of protection to Personal Data than generally afforded in your jurisdiction, SANOFI will ensure that a sufficient level of protection is provided to your Personal Data by implementing adequate safeguards such as the European Standard Contractual Clauses, the SANOFI Binding Corporate Rules or asking for your prior explicit consent.
YOUR RIGHTS: SANOFI WILL ENSURE THAT YOU CAN EXERCISE YOUR RIGHTS PERTAINING TO YOUR PERSONAL DATA
You can exercise your rights as provided by applicable data protection laws.
To that end, SANOFI informs you that you are entitled:
to have access upon simple request to your Personal Data – in which case you may receive a copy of such data (if requested), unless such data is made directly available to you, for instance within your personal account;
to obtain a rectification of your Personal Data should your Personal Data be inaccurate, incomplete or obsolete;
to obtain the deletion of your Personal Data in the situations set forth by applicable data protection law (‘right to be forgotten’);
to withdraw your consent to the processing of Personal Data processing without affecting the lawfulness of processing, where your Personal Data has been collected and processed on the basis of your consent;
to object to the processing of your Personal Data, where your Personal Data has been collected and processed on the basis of legitimate interests of SANOFI, in which case you will need to justify your request by explaining to us your particular situation;
to request a limitation of the processing of Personal Data processing in the situations set forth by applicable data protection law;
to receive your Personal Data for transmission from SANOFI to a third-party or to have your Personal Data directly transferred by SANOFI to the third-party of your choice, where technically feasible (data portability right allowed only where the processing is based on your consent)
If you would like to exercise any of these rights, please contact us as described in the “How to Contact Us” section below and we will take necessary steps to respond as soon as possible.
You may also file a complaint before a competent data protection authority regarding the processing of your Personal Data. While we suggest that you contact us beforehand, if you wish to exercise this right, you should contact directly the competent data protection authority.