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Roche Legal and Privacy

Privacy Policy

 

Roche Diabetes Care India Private Limited (“Roche”) is committed to protecting your privacy. Thank you for visiting a Roche website or interacting with us via e-mail. At Roche, we understand that protecting the privacy of visitors to our websites is very important and that information about your health is particularly sensitive. That is why we have taken the necessary steps to meet applicable data privacy requirements. We treat and protect your “personal data” according to the guidelines stipulated under the laws of India, and other applicable local laws which regulate the storage, processing, access and transfer of personal data. This Privacy Policy may be amended from time to time in compliance with the evolving regulations.

 

Please review this Privacy Policy (“Policy”/ “Statement”) to learn more about how we collect, use, share and protect your personal information. This Statement applies to personal information (as defined below) collected from Roche online resources and communications (such as websites, e-mail, and other online tools) that display a link to this Statement. This Statement does not apply to third-party online resources to which Roche’s websites may link, where Roche does not control the content or the privacy practices of such resources.

 

Information Collected

 

There are two general methods that Roche uses to collect information from you online:

 

Information We Get

 

- Personal identifiable information: You can visit our websites without providing any personal information. We may collect your personally identifiable information (such as name, address, telephone number, e-mail address or other identifying information) only when you choose to submit it to us. We may also collect health information about you that you provide by responding to our questions or surveys.

- Aggregate information: In some cases we also remove personal identifiers from data you provide to us and maintain it in aggregate form. We may combine this data with other information to produce anonymous, aggregated statistical information (e.g. number of visitors, originating domain name of the Internet Service Provider), helpful to us in improving our products and services.

 

Automatically Collected Information

 

We and some third-party providers automatically receive certain information whenever you interact with us on our sites and in certain e-mails we may send each other. Information that may be automatically collected by mere use of our website and exchange of emails may include, but is not limited to, web server logs/IP addresses, cookies and third party application and content tools.

Web Server Logs/IP Addresses. An IP address is a number assigned to your computer whenever you access the Internet. All computer identification on the Internet is conducted with IP addresses, which allow computers and servers to recognize and communicate with each other. Roche collects IP addresses to conduct system administration and report aggregate information to affiliates, business partners and/or vendors to conduct site analysis and website performance review.

Cookies. A cookie is a piece of information that is placed automatically on your computer’s hard drive when you access certain websites. The cookie uniquely identifies your browser to the server. Cookies allow us to store information on the server to help make the web experience better for you and to conduct site analysis and website performance review. Most web browsers are set up to accept cookies, although you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you refuse cookies.

 

Cookies and other tracking technologies do not automatically obtain personally identifiable information about you. Only if you voluntarily submit personally identifiable information, such as by registering or sending e-mails, can these automatic tracking technologies be used to provide further information about your use of the websites and/or interactive e-mails to improve their usefulness to you.

 

Roche will store information collected about you securely and access will only be allowed to those authorised and then only for the purpose for which it was collected and in the case of sensitive information for the purpose for which you have provided consent. Roche will delete from its records personal information no longer required or in use for the purposes identified in this Privacy Policy, other than information which we are required to retain. If possible, such information will be retained in a way that you cannot be identified. In most cases, RDC India will keep the personal information for a time period permitted under the applicable data privacy regulations. RDC India may however maintain your personal information for a longer period if necessary to comply with any obligations under any law for the time being in force in India. In the event you would like us to erase your personal information, you may get in touch with the RDC India customer care team.

Information collected from or about you may be stored and processed in India or any other country in which Roche or its affiliates worldwide, or its or their subcontractors or agents maintain facilities. Roche will ensure that if information is transferred outside of India, it will still be treated in accordance with this Privacy Policy aligned with the applicable data privacy regulations. The countries in which your personal information may be disclosed include the United States and countries within the European Union.

    

Services: We may provide services based on third party applications and content tools on certain Roche websites. These third parties may automatically receive certain types of information whenever you interact with us on our sites using such third party applications and tools.

 

Your Choices

You have several choices regarding your use of our websites. You could decide not to submit any personally identifiable information at all by not entering it into any forms or data fields on our sites and not using any available personalized services. If you choose to submit personal data, you have the right to see and correct your data at any time by accessing the application. Certain sites may ask for your permission for certain uses of your information and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will work to remove your information promptly. We will address your request and amend our records accordingly. We may require additional information before we can process your request.

As described above, if you wish to prevent cookies from tracking you anonymously as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note however that some portions of our website may not work properly if you refuse cookies.

 

Security

Roche uses technology and security precautions, rules and other procedures to protect your personal information from unauthorized access, improper use, disclosure, loss, modification, interference or destruction. To ensure the confidentiality of your personal information, Roche uses also industry standard firewalls and password protection. It is, however, your personal responsibility to ensure that the computer you are using is adequately secured and protected against malicious software, such as trojans, computer viruses and worm programs. You are aware of the fact that without adequate security measures (e.g. secure web browser configuration, up-to-date antivirus software, personal firewall software, no usage of software from dubious sources) there is a risk that the data and passwords you use to protect access to your data, could be disclosed to unauthorized third parties.

 

Use and Disclosure of Personal Information

The purposes for which your personal information may be collected, held, used and disclosed include:

 

to contact you (or provide information and/or materials to you):

with respect to Roche products and/or services;

to administer and conduct consulting and service arrangements with Roche;

to administer or conduct educational and /or commercial meetings or programs;

to update you on medical congress, events and news; and

to conduct relevant market research;

to fulfil obligations under relevant industry codes of conduct, meet regulatory requirements and legal obligations;

to maintain your contact details in our records;

to monitor the safety and efficacy of our products;

to fulfil your requests;

or as otherwise disclosed to you in this Policy from time to time.

Roche will not disclose personal information about you to any person except in accordance with the Act, and only where necessary. The circumstances in which we may disclose that information include:

where Roche notified you at the time of supply of the information to Roche or it is expressly permitted under any agreement with you;

where it is necessary to provide you with a service or goods which you have requested;

where required for the ordinary operation of our business (for example, to send you information about our goods and services);

where it is necessary for support services to be provided in relation to our business activities (please note that such disclosures will only be to people and entities required to meet the same standards of data protection and which are prevented from using the information for their own marketing purposes);

where we consider the law requires it, or in response to any demand by law enforcement authorities;

regulatory authorities where Roche is required to provide your personal information to the particular authority;

third parties that we use in the ordinary operation of our business, such as for conference organising, marketing, selling our products, data processing and associated printing and mailing. For example, it may also be provided to Clinical Research Organisations for the purposes of medical research. We will only provide your personal information to reputable third parties and then only on a confidential basis where we are satisfied that those third parties will similarly comply with the applicable India regulations. These activities may involve the export of your personal information overseas as described above;

companies related to Roche for the same kinds of purposes as listed above. Subsequent use and disclosure by the related company will be in compliance with the applicable privacy principles and the regulations;

another company for the purpose of ensuring continuity of product supply and/or service if the supply of the product or service has been transferred to that company; and

 

Your personal information may be aggregated with data from other Roche sources and stored or processed on computers or Web-based database systems located outside India where data protection laws may differ from ours. Your personal information may be stored, maintained and processed on computers or web-based database systems at Roche which may be accessed by and shared with any affiliate within the global Roche Group (Roche Affiliates), third-parties working with Roche affiliates and/or regulatory authorities or as required by law. Where practicable we will implement measures to require these third parties working with Roche to comply with the Act and the terms of this Policy. 

 

Data Sharing and Transfer

Roche shares personally identifiable data about you with service providers or agents doing technological maintenance or working on our behalf to help fulfill business transactions, such as providing customer services, sending marketing communications about our products, services and offers, hosting and maintenance services, analysis services, e-mail messaging services, delivery services, handling of payment transactions, solvency check and address check. We may also share personally identifiable data with our company's subsidiaries and affiliates. All these companies and agents are required to comply with the terms of our privacy policies.

We may also disclose personally identifiable information for these purposes:

in connection with the sale, assignment or other transfer of the business of the site to which the data relates;

in connection with fulfilling orders for Roche products placed by you on the Roche website;

to respond to appropriate requests of legitimate government agencies or where required by applicable laws, court orders, or government regulations; or

where needed for corporate audits or to investigate or respond to a complaint or security threat.

 

Sensitive Personal Data. We do not store or share your sensitive personal data with any third-party partners. Sensitive personal data may include your financial information, health records, or any such information that is designated as such by applicable laws in India. We further do not process or store your sensitive personal data outside India, except in manner permitted by applicable laws in India.

 

Direct Marketing

At any time you may opt out of receiving any communications from Roche (other than as required for the operation of our business, e.g. regarding account payment if you have one with us), although Roche may then be unable to provide you with all of the information regarding our programs, events, services or products which may be of benefit to you. If you decline to provide us with your personal information (or subsequently opt-out) it will likely preclude the provision of relevant services to you by Roche. 

 

Piwik Pro. Roche websites may use Piwik Pro, a web analytics service provided by Piwik Pro GmbH. ("Piwik Pro"). Piwik Pro uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Piwik Pro on servers in the Sweden. Piwik Pro will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Piwik Pro may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Piwik Pro's behalf. Piwik Pro will not associate your IP address with any other data held by Piwik Pro. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, as mentioned above please note that if you do this you may not be able to use the full functionality of a Roche website. By using a Roche website, you consent to the processing of data about you by Piwik Pro in the manner and for the purposes set out above.

 

Links to Other Sites

Our sites contain links to a number of websites that may offer useful information to our visitors. This Privacy Statement does not apply to those sites, and we recommend communicating to them directly for information on their privacy policies.

 

Privacy Statement for Children

Our websites are directed at an adult audience. We do not collect any personally identifiable information from anyone we know to be under the age of 18 without the prior, verifiable consent of his or her legal representative. Such legal representative has the right, upon request, to view the information provided by the child and/or to require that it be deleted.

 

Additional Information on websites

If a website has particular provisions relating to privacy that differ from those stated here, those provisions will be disclosed to you on the page on which personally identifiable information is collected.

 

Note to Users of Business or Professional websites

If you have a business or professional relationship with Roche, we may use information you submit on our sites, including sites intended specifically for business and professional users, to fulfill your requests and develop our business relationship with you and the entities you represent. We may also share such information with third parties acting on our behalf.

 

Updates to Privacy Statement

From time to time, Roche may revise this online Privacy Statement. Any such changes to this Privacy Statement will be promptly communicated on this page. Continued use of our sites after receiving notice of a change in our Privacy Statement indicates your consent to the use of newly submitted information in accordance with the amended Roche Privacy Statement. 

 

Access, Corrections and Further Information

You may request access to your personal information from Roche holds about you by sending an email to global.rdc [email protected] or if you would like to:

request access to your personal information held by Roche;

request an amendment or correction of your personal information held by Roche;

ask us to remove your personal information from our system; or

ask us questions about this Privacy Policy;

request a copy of this Privacy Policy.

Your request should provide as much detail as possible to assist us to identify information relevant to you, such as your name and contact details, any former names and the information you believe Roche may hold about you. You do not have to provide a reason for requesting access. Where Roche holds information that you are entitled to access, we will endeavour to provide you with a suitable range of choices as to how you may access it (e.g. emailing or mailing it to you). In any event Roche will acknowledge receipt of your request within a reasonable period and in any event within 10 working days and endeavour to respond to your request within 30 days. 

If you believe that personal information Roche holds about you is incorrect, incomplete or inaccurate, then you may request we amend it. We will consider if the information requires amendment. If Roche does not agree that there are grounds for amendment, then we will add a note to the personal information we hold stating that you disagree with it. Any questions about this policy, or any complaint regarding treatment of your privacy by Roche, should be made through the contact details below.

 

How to Contact Roche

For questions or if you wish Roche to amend or delete your profile, please contact us in writing (by post), as follows:

 

Roche Diabetes Care India Pvt Ltd.

146-B, 166A unit No. 7,8,9,

8th Floor, R-city Office, R city mall,

Lal Bahadur Shastri Marg, Ghatkopar West,

Mumbai – 400086

Maharashtra

India