The Company A.Menarini GmbH ("Company", or "we") takes its users' privacy very seriously and undertakes to comply in full with the applicable law (Swiss Data Protection Law and Regulation (EU) 2016/679 - hereinafter defined as the "GDPR"). This document ("Privacy Policy") provides information on how the personal data collected by the Company through this website ("Website") are processed, and constitutes "an information notice to the data subjects" under the terms of art. 13 of the GDPR. If additional types of personal data are collected on specific websites, further privacy notices are published there, complementing this Privacy Policy.

The Data Controller is A.Menarini GmbH, with registered offices in Thurgauerstrasse 36/38 - CH-8050 Zurich ("Controller"). E-Mail: info@menarini.ch

The Company representative and Data Protection Officer (DPO) in the European Union can be contacted at the following address: DPO@menarini.com

The contact person in charge of the data privacy in Switzerland can be contacted at the following address: info@menarini.ch

The following types of personal data we may collect about you include:

• Personal contact information. This will only be collected if you wish to contact us and includes any information you provide to the Company that would allow us to respond to you, such as your name, postal address, e-mail address, social network details, or phone number. Depending on the nature of your request, we may also need your professional qualifications, the content of your request or reports and the additional data, which the Company may acquire, also from third parties, in the course of business.
• User account information. If you have registered to use a website of the Company with restricted access, we will collect your access information (user name, password and personal contact information).
• Health-related information. If you contact the Company concerning an adverse event possibly relating to the treatment of an illness (so-called pharmacovigilance case) we are legally obliged to collect and process such information (article. 9.2.a, 9.2.g and 9.2.i GDPR).
• Information from computer/mobile device. Any information about the computer system or other technological device that you use to access one of our Websites or apps, such as the Internet protocol (IP) address used to connect your computer or device to the Internet, operating system type, and web browser type and version. If you access a Company website or app via a mobile device such as a smartphone, the collected information could also include, where permitted, your phone’s unique device ID, geo-location, and other similar mobile device data.
• Websites/communication usage information. As you navigate through and interact with our Websites, the Company uses automatic data collection technologies to collect certain information about your actions. This includes information such as: which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages. This information is captured using automated technologies such as cookies and web beacons, and is as well collected through the use of third party tracking for analytics and advertising purposes. You have among other things the right to object to the use of such technologies, for further details please see Cookie Policy.

• Personal contact information. We use your personal data for consumer service purposes, including responding to your enquiries. This typically requires the use of certain personal contact information and information regarding the reason for your inquiry (e.g. issue, product question/complaint, general question, etc.).
• User account information. This is used to manage access to restricted websites.
• Health-related information. If you contact the Company concerning an adverse event possibly relating to the treatment of an illness (so-called pharmacovigilance case) we are legally obliged to collect and process such information (article. 9.2.a, 9.2.g and 9.2.i GDPR).
• Information from computer/mobile device and Websites/communication usage information. In accordance with applicable laws, the Company collects these merely for statistical purposes and in anonymous form in order to monitor the functioning of the Website and improve its performance.
  Such data is not collected to be associated with other information regarding, or for the identification of, users; however, such information, by its very nature, may enable the Company to identify users through processing and association with data held by third parties.
  Browsing data are normally deleted following processing in anonymous form but can be stored and used by the Company to detect and identify perpetrators of any computer offences committed to the detriment of the Website or using the Website.
  Without prejudice to this possibility and to the provisions of the Cookie Poilicy the browsing data described above are stored only temporarily.

For legal reasons. The company processes your personal data (even without your prior consent) in case of/for the purpose of:

• Legal and regulatory requirements (legal basis: article 6.1.c GDPR);
• At the behest of the relevant prosecution authorities (legal basis: article 6.1.c GDPR);
• Protecting its rights in the course of legal proceedings (legal basis: articles 6.1.f and 9.2.f GDPR);
• Implementing the Code of Conduct of the Menarini group (legal basis: articles 6.1.f and 9.2.f GDPR);
• Protecting of another legitimate interest of the company or a third party (legal basis: article 6.1.f GDPR);
• Executing of a contract concluded with you. This also applies to the necessary processing procedures to carry out the pre-contract activities (legal basis: article 6.1.b GDPR);
• Exceptional circumstances, in which your vital interests or those of a third party require a data processing (legal basis: articles 6.1.d and 9.2.c GDPR).

All your data are processed using automatic and electronic instruments suitable to ensure full security and confidentiality.

The forms to be completed on this website require you to provide only personal data, which are strictly necessary to handle your communications and requests. Such Data are marked with an asterisk [*]. If you do not wish to confer them, we will not be able to handle your communication /request. Conversely, forms may also provide the possibility to provide personal data, which are not strictly necessary to handle your requests: providing such data is optional - failure to do so has no consequence.

This Privacy Policy applies only to the Website as defined above. Even though the Website may contain links to other websites (known as third party websites), please be informed that the Company does not have any influence on access or control over cookies, web beacons or other user-tracking technologies that may be active on such third party websites, on the contents and materials published thereon, or on their methods of processing of your personal data; for this reason, the Company expressly declines any liability for such matters. You should therefore verify the privacy policies of such third party websites and collect information about their terms and conditions and about how they process your personal data.

In compliance with Article 5.1.c GDPR, the computers and programmes used by the Company are set up in such a way to reduce the use of personal data to a minimum. Such data are processed only to the extent required to achieve the purposes indicated in this Policy, and will be stored for as long as strictly necessary for achievement of the specific purposes pursued - in any event, the criterion used to determine the storage period is based on compliance with time limits permitted by law and the principles of data minimisation, storage limitation or rational management of our records.

The Company undertakes to ensure security of your personal data and comply with provisions on security provided by law to avoid data loss, illegitimate or unlawful uses of data or unauthorised access to data, with particular but not exclusive reference to Articles 25-32 GDPR. The Company uses many types of advanced security technologies and procedures intended to aid protection of your personal data; for example, personal data are stored on secure servers situated on premises with protected and controlled access. You can assist the Company to update and correct your personal data by communicating any change of address, qualifications, contact information, etc.

Persons belonging to the following categories are authorised to process your data:

• technical and administrative staff,
• IT staff,
• product managers, as well as other staff members who require processing the data for performance of their job duties.

The data can be communicated also in countries outside Switzerland or the EU ("Third Countries") to other companies of the Menarini Group for the same purposes and/or for administrative and accounting purposes pursuant to Article 6.1.f and Recital 48 GDPR.
Additionally, the data can be communicated, also in third countries, to:

• institutions, authorities, public bodies for their institutional purposes;
• professionals, independent consultants -working individually or in partnerships- and other third parties and providers which supply to the Company commercial, professional or technical services required to operate the Website (e.g., provision of IT and Cloud Computing services) for the purposes specified above and to support the Company with the provision of the services you requested;
• third parties in the event of mergers, acquisitions, transfers of business or branches thereof-, audits or other extraordinary operations as required by law;
• the Supervisory Board, based at the Controller's address, in the pursuit of its supervisory activities and for the enforcement of the Menarini Group Code of Conduct.

The mentioned recipients shall only receive the data necessary for their respective functions and shall duly undertake to process them only for the purposes indicated above and in compliance with data protection laws.

The data can furthermore be communicated to the other legitimate recipients identified from time to time by the applicable laws.

With the exception of the foregoing, the data shall not be shared with third parties, whether legal or natural persons, who do not perform any function of a commercial, professional or technical nature for the Controller and shall not be disseminated.

The parties who receive the data shall perform processing as Data Controller, Processor or persons authorised to process personal data, as the case may be, for the purposes indicated above and in compliance with the applicable data protection law.
Regarding any transfer of data outside Switzerland or the EU, including in countries whose laws do not guarantee the same level of protection to personal data privacy as that afforded by Swiss or EU Law, the transfer shall always take place in accordance with the methods permitted by the GDPR, such as, for example,

• on the basis of the user's consent,
• on the basis of the Standard Contractual Clauses approved by the European Commission, by selecting parties enrolled in international programmes for free movement of data (e.g. EU-USA Privacy Shield), or
• operating in countries considered safe by Switzerland and/or the European Commission.

You may at any time, if the necessary conditions are met, exercise the rights you have, notably those listed in articles15 to 22 GDPR, namely:

• the right to obtain confirmation of the existence of any personal data related to you,
• the right to check the content, the origin, the veracity, the location (also as regards third countries),
• the right to obtain a copy,
• the right to request a correction,
• the right to object to the use for possible direct marketing purposes (as a whole or for specific actions or channels),
• the right to object to the use for possible direct contact,
• the right to request for erasure,
• the right to request a restriction of the processing,
• the right to data portability.

You may always withdraw your consent (however, this doesn’t affect the legality of processing activities prior to revocation) and/or make observations on specific issues regarding processing operations of your personal data, which you regard as incorrect or unjustified by your relationship with the Company, or lodge a complaint with the Data Protection Authority.

You may contact the Controller (info@menarini.ch ) and/or Data Protection Officer (dpo@menarini.com ) at the addresses displayed above to make any requests regarding personal data processing by the Company, to exercise your legal rights and to obtain an updated list of the parties who have access to your data.

You also have the right to complain to a supervisory authority, in Switzerland this is the Swiss Federal Data Protection and Information Commissioner (info@edoeb.admin.ch).

We last updated this Privacy Notice on 24 May 2018. We may change our Privacy Policy from time to time in particular in the event of changes in the law or in the event of a Company business requirement. Please check this page occasionally to ensure you are aware of any changes that are adopted.

If you have any questions, comments or complaints regarding this Privacy Policy or the processing of your personal data, please contact us either at

A.Menarini GmbH
Thurgauerstrasse 36/38
CH-8050 Zürich

or by e.mail at:
info@menarini.ch, oder
DPO@menarini.com

This privacy notice describes how A. Menarini GmbH , Thurgauerstrasse 36/38, 8050 Zurich, Switzerland, dataprivacy@menarini.ch („Menarini“), processes your personal data when you use your profile on the social network such as, by way of example, Facebook, YouTube, Twitter, Instagram, or LinkedIn and similar networks or portals (“Social Networks”) to interact with Menarini’s account/page/profile on those Social Networks, or surf Menarini’s websites (each a “Page”) while logged in to those Social Networks.

This document only addresses the personal data processing operations carried out by Menarini: your data are in fact collected and processed in the first place by the Social Network on which you have a profile (which acts as “Data Controller” of your personal data), and only if you interact with Menarini’s Page, will Menarini access to and process a small portion of the data about yourself held by the Social Network. Menarini is an “independent Data Controller” in respects to the personal data about you received from the relevant Social Network: this means that Social Networks and Menarini autonomously decide the purposes and methods with which they process the personal data about you they respectively access.

The processing operations carried out by Menarini are described here below. If you are interested in knowing how Social Networks process your data, we invite you to read the Privacy Policies available via your Social Network profile(s). If you interact with Menarini’s Page, Menarini may process the following personal data about yourself, inferred from your profile: name, surname, username and other biographical and professional information, age, gender, information voluntarily made public by you or shared via the Social Network by means of posts or other functionalities; your activities on the social network on Menarini’s Pages and on the Social Networks, such as “likes”, comments, public posts, tags and hashtags; content of private messages addressed to Menarini.

Moreover, the Social Network – if you provided your consent via your Social Network profile and browser’s settings – may make available to Menarini additional information about activities and preferences you expressed when surfing the internet. This information may also be collected with instruments such as cookies, web beacons and pixel tags: for more information, we invite you to check your browser settings, your Social Network profile settings or the policies of the websites you visit. Please be informed that when said instruments are used on Menarini websites, the relevant details are provided in the respective cookie and privacy policies. We clarify that if you have logged in to your account on the Social Network and surf on the internet with the same device, Menarini may be able to detect some of the information connected to your Social Network profile, such as age group, “likes”, etc., and in some cases also to identify you.

Your personal data will be processed for the following purposes:

• answer your posts, requests and queries, and enable you to take part in the activities performed via the Page; manage and optimise the Page’s content, perform statistical analyses and market research on the users who interact with the Pages or our websites.
• to fulfil its legal obligations, as well as to clear its obligations pertaining to the protection of public health, which require the monitoring, follow-up and reporting to the authorities/other bodies (licensors, licencees, etc.) any information about actual or potential adverse events related to the use of Menarini’s products.
• ensure you comply with the Netiquette; enforce Menarini’s legal rights; enforce Menarini’s Code of Ethics and Group Code of Conduct.
• carry out promotional campaigns pertaining to Menarini’s activities, products or services (in compliance with the applicable laws on promotional activities of health-related products and services) by means of Menarini’s Social Network account, including by sending ads or messages provided that – where necessary – you consent to it.
• sending you targeted ads (“profiling”) pertaining to the activities, products and services outlined at the previous bullet point provided that – where necessary – you consent to it.
• regarding user data collected in connection with job openings published by Menarini via the Social Networks, assessing and/or establishing a professional relationship.

In case you publish data pertaining to third parties, it is your responsibility to clear any requirements pertaining to information and consent collection, in compliance with the applicable data protection laws.

Regarding your consent to the processing of the data about yourself that Menarini receives via your Social Network profile, we clarify that: (i) the relevant consents are conferred by you when you register with the Social Networks, and you may personalise them at any time (Menarini does not, however, control these operations in any way – they are managed entirely by the Social Networks); (ii) data processed by Menarini are those made available by the Social Network: this means Menarini is not responsible for any unauthorised disclosure of information by the Social Network or for the receipt of unwanted ads/messages, in breach of the options you have selected.

Your personal data will be processed mainly electronically, and will be entered in its IT systems in compliance with the applicable data privacy laws, including data security and confidentiality aspects, in line with the principles of lawfulness and fairness. Personal data will be stored for as long as strictly necessary to achieve the specific purposes pursued - in any event, the criterion used to determine the storage period is based on compliance with time limits permitted by law and the principles of data minimisation, storage limitation or rational management of our archives.

Menarini’s staff belonging to the following categories are authorised to process your personal data: technical and administrative staff, IT staff, product managers, internal audit and compliance as well as other staff members who require processing the personal data for performance of their job duties.

The personal data can be communicated also in foreign countries and/or outside Switzerland and/or the EU/EEA (“Third Countries”) to other companies of the Menarini Group (also located abroad) for administrative and accounting purposes.

Additionally, the personal data can be communicated, also in Third Countries, to Menarini’s supervisory body, to third-party companies, such as providers and sub-providers of IT and cloud computing services, networking service providers which manage Menarini’s Pages and companies that carry out consulting activities (e.g., tax, administrative, etc.) on Menarini’s behalf, institutions, authorities, public bodies for their institutional purposes, based on the applicable law; third parties in case of audits, mergers and acquisitions (also abroad). Recipients shall process data for the purposes indicated above and in compliance with the applicable laws.

Regarding any transfer of personal data outside Switzerland and/or the EU/EEA, including in countries whose laws do not guarantee the same level of protection to personal data privacy as that afforded by applicable privacy laws, Menarini informs that the transfer shall in any event take place in accordance with the methods permitted by the applicable privacy laws, such as, for example, on the basis of the user’s consent, on the basis of the Standard Contractual Clauses approved by the European Commission as adapted by the Swiss Federal Data Protection and Information Commissioner (FDPIC) or operating in countries considered safe by the respective Swiss authorities (FDPIC or federal council). Upon request we provide you with a list of countries where your personal data is transferred to.

By contacting Menarini at the e-mail address dataprivacy@menarini.ch , you may exercise the rights afforded by the applicable privacy laws, including: obtain confirmation of the existence of personal data which relate to you, check its content, origin, correctness, location (also with reference to any Third Countries), request a copy, request correction and in cases provided by law, restriction of processing, deletion/destruction, oppose to direct contact activities (also limited to particular means of communication). Likewise, you may always express any concern you may have about the processing of your personal data or lodge a complaint with the competent supervisory authority (for Switzerland the FDPIC). To withdraw the consent(s) you conferred to Social Networks you need to address your request directly to the Social Networks themselves.

Terms of use for the social media channels of A. Menarini GmbH

Dear user, thank you for your interest in the social media channels (especially LinkedIn, Facebook and Instagram, hereinafter referred to as the “Channels”) of A. Menarini GmbH (hereinafter referred to as the ”Company”). There are a number of things you need to know in case you wish to comment or post material on these Channels. The mission of the Company is to improve people's lives by providing high quality products to patients. In order to achieve this goal, the Company has the social and moral duty to adopt, support and promote ethically correct behaviour in line with the values of integrity, correctness and transparency, which have always distinguished it. The Company has adopted these principles and objects to any action and approach, which may promote, or even tolerate, behaviour, which is not in accordance with this. The Company operates in sectors governed by specific provisions; any discussions must therefore be in line with the terms of use set out below. Your data shall be processed in compliance with the applicable law. For more information, click here.

Any user who posts a message or replies to one of the posts published on any of the Company's Channels agrees to comply with these terms of use. They shall apply in addition to the conditions of use or any other legal notices provided to the users by the Company or by any companies that own the Channels used.

Whenever possible, the medical and scientific information made available is for informational use only and cannot be considered as professional advice replacing medical intervention or giving any customised treatment indication.

The user acknowledges that, where posting is permitted, any data, texts, graphics, pictures, their selection and arrangement and any other material the user decides to post by using the IT functions and tools of the chosen Channel (the "Contents") are the sole responsibility of the person who generated them.

Quotations, likes and comments are allowed, whereas discussions concerning products of the Company or of any other pharmaceutical companies, or treatment options, are not allowed.

Management and moderation are entrusted to people in charge of this, who carry out periodic checks on posted messages at least every 48 hours. In any case, the user acknowledges that the Company that manages the relevant Channel may not carry out any preventive oversight on the Contents, declining any responsibility for the Contents uploaded, posted or otherwise made available by the users.

Where provided for, the user also acknowledges that the Channel may allow sharing of Contents published with other social networks; the Company that manages the relevant Channel has no control over the subsequent processing of the Contents and refuses any responsibility or liability therefor.

The Company shall use its best efforts to respond to any users’ comments and questions; however, it is not possible to address certain topics, such as any matters directly related to the legal field, confidential information or information concerning medical disorders. If it is not possible to reply to a comment, a private message with the motivation may be sent, where allowed and permitted by the functionality of the chosen Channel.

In any case, it is absolutely forbidden for each user to send messages that include:

• profanity, defamation, calumny; offensive, discriminatory or degrading, vulgar, xenophobic contents or any contents harmful to the dignity and sensitivity of others, praising hatred, violence or illegal behaviour;
• intellectual and/or industrial property rights of third parties (such as trademarks or logos), or copyrighted materials (such as music, videos, texts) without the express consent from the holders of such rights;
• any treatment indications;
• political propaganda contents;
• off-topic contents, or any contents written to disturb the discussion or offend those who manage and moderate the Channel;
• offering medical or otherwise health advice in general;
• commercial contents: for example, selling products / services, advertising campaigns, or recruiting fans and followers;
• excessively repetitive and/or disturbing contents for the community or spamming;
• any matters directly related to the legal field, confidential information or information concerning medical disorders;
• any contents that violate the rules of conduct of the chosen Channel.

• posted contents must never mention any drugs, medical devices or active ingredients of the companies of the Menarini Group or of any other pharmaceutical companies;
• as provided for by the regulations in force, under no circumstances may promotional contents relating to drugs and medical devices be posted;
• in no case should any legal proceedings, disputes / pending suits be mentioned;
• the user has to obtain, before uploading any information that allows the identification of third parties (such as name, phone number, address, pictures and/or videos in which such third parties are portrayed), their prior consent to the publication and possible sharing via the Channel, it being understood that posting – through the functionalities and the IT tools available on the site – any pictures or Contents that concern a user automatically implies the consent of that user to their diffusion and sharing;
• any use or mention of the user Contents or materials transmitted through the Channel's functionalities and IT tools or obtained by the user through said functionalities or IT tools is at the user's own risk.