Privacy statement

Privacy Statement

 

This learning platform (hereinafter “Platform “) is provided to you by Bayer Middle East FZE, United Arb Emirates (hereinafter “us”, “our” or “we”). As controller for the processing of information relating to you (your “personal data” or “information”) in connection with your use of the Platform, we wish to provide you in the following with the necessary information on this data processing. For further information regarding the provider of the website, please refer to our imprint.

 

Legal basis for processing your information

Unless otherwise indicated in the following sections, the legal basis for the processing of your personal data results from the fact that such handling is required to make available the functionalities of the website and to operate the Platform (Art. 6(1)(f) General Data Protection Regulation): Purpose of processing and categories of personal data

We process personal data about you to operate the Platform, e.g. give you access, make available its functionalities to you, enhance and personalize your experience with the Platform, provide related support to you, as well as improve the engagement with you. This may include the processing of:

• Identification information (such as your name, surname and email address)
• Information related to the browser or device you use to access the Platform
• Information about your learning and other activities, available on the Platform, and how you use the Platform
• Information you provide e.g. by communications or adding it to your user profile
• Information you provided related to your workplace.

You are not obligated by law or contract to provide your personal data. However, in case of failure to provide, you might not be able to use the functionalities of the Platform. For more details on the purposes of processing and categories of personal data processed please see the following sections.

Accessing our Platform

When you access our Platform, your browser will transfer certain information to our web server. This is done for technical reasons and required to make available to you the requested information. To facilitate your access to the website, the following information are collected, briefly stored and used:

• IP address
• Date and time of access
• Time zone difference to Greenwich Mean Time (GMT)
• Content of request (specific site)
• Status of access/HTTP status code
• Transferred volume of data
• Website requesting access
• Browser, language settings, version of browser software operating system and surface

Moreover, to protect our legitimate interests, we will store such information for a limited period of time in order to be able to initiate a tracking of personal data in the event of actual or attempted unauthorized access to our servers Art. 6(1)(f) General Data Protection Regulation).

Registration, verification and login

In order to use our Platform, you must first register an account with us, where you can determine your personal login credentials and be able to access your personal account.

The Platform shall only be made accessible to healthcare professionals belonging to the pharmacist expert’s community. Bayer sends an invitation to the pharmacy owner and provide him/her with a dedicated link to the registration page or Bayer code to ensure that the correct user is accessing the website. If owner provides a valid link or the correct Bayer code upon registration and complete the registration process, he/she will be a full access member. Then the owner can invite his/her pharmacy group members to the Platform. To verify that you are an authorized person to access the site, we are therefore obliged to request proof of your status as a member of the pharmacy by sending an e-mail which contains your name and surname to the owner of the pharmacy. Each pharmacy owner manages his/her team members. Only when an owner approves a new team member, he/she will be able to have full access to the Platform. Until to achieve this approval, the user will have restricted access to the Platform.

For this registration and subsequent login procedure, we collect the following information about you:

• Name and surname
• Email address
• Password
• Role in the pharmacy
• Pharmacy group
• Log file of your logins incl. timestamp

We process this personal data in order to provide you with an access to our Platform. They are deleted in case you delete your user account.

User Profile

When you become a member of our Platform, you have to create a user profile. It contains your personal data composed by the data that you have provided in the registration process to the Platform (i.e. name and surname, email address, role, pharmacy group, consents) and the performed activities on the Platform (e.g. trainings, achievements, etc.). Also, as user you can voluntarily add further information to your profile such as your:

• Picture
• Preferences/interests
• Description
• Password
• Role
• Language
• Time zone
• Pharmacy Name

Furthermore, you have the possibility to upload on the Platform the images which will be attached to your profile/activities.

You can share and receive recommendations with your pharmacy team members. However, no one else, except yourself and the manager and/or owner of the pharmacy, will be able to search for and view your profile or learning collection and activities.

 

The owner/manager of a pharmacy will be able to see the team members names, surnames, photos of his or her own pharmacy.

Notifications/updates via email and within the platform

Under the section “Notifications” we will use, based on our legitimate interest (Art. 6(1)(f) General Data Protection Regulation) to offer you better user experience, necessary information from your profile and about your learning activities for providing you different relevant information for you as updates (e.g. new activities related with your interests, new  learning suggestions matched to your skills and prior learning activities, achievements, content sharing form your pharmacy group members ) and notifications ( e.g. new functionalities of the platform, platform notifications about pharmacy team or user status, recommendations of your pharmacy group team members). Some notifications (e.g. new pharmacy team members, approvals or removed users) are required to maintain the correct workflow of the Platform and will be sent to you additionally via email.

During registration and later on the Platform under "Settings" and "My Profile" you may choose to receive these notifications and updates via email as well. If you do so, we will, based on your consent (Art. 6(1)(a) GDPR), use your email address for this reason. You may at any time change the settings back to stop receiving further emails.

Learning and other activities

When you conduct trainings and other activities (user surveys, challenges, etc.) on the Platform, we keep a record and your rating of it. This information is used to keep track of your completed courses, points, achievements, etc.

Connection to our Customer Relationship System

Based on our legitimate interest (Art. 6(1)(f) General Data Protection Regulation) we transfer the information from your profile and about your trainings and other activities into our Customer Relationship System in order to improve the collaboration with you.

Support for technical & content issues

In case of technical or content issues, we provide on the Platform the possibility to request support by email (contact form).If you use this, we may process the following information about you:

• Name and surname
• Email address
• Date and time of report
• Report details (e.g. description of problem)

We process this information exclusively for the processing of your specific request.

Setting of cookies

What are cookies?

This Platform uses so-called “cookies”. Cookies are small files (like a text file or graphic) that are placed in the memory of your computer or mobile device. They store certain information (e.g. your preferred language or site settings) which your browser may (depending on the lifespan of the cookie) retransmit to us upon your next visit to the Platform.

What cookies do we use?

We differentiate between two categories of cookies: (1) essential cookies, without which the functionality of the Platform would be reduced, and (2) optional cookies used for e.g. usage analysis and personalization purposes. The following tables contain a detailed description of the optional cookies we use:

Functional and Optional Cookies

Cookie Settings

Subject to your consent

We only use optional cookies if we have obtained your prior consent (Art. 6(1)(a) General Data Protection Regulation). Upon your first access to our Platform, a banner will appear, asking you to give us your consent to the setting of optional cookies. If your consent is given, we will place a cookie on your computer and the banner will not appear again as long as the cookie is active. After expiration of the cookie’s lifespan, or if you actively delete the cookie, the banner will reappear upon your next visit to our website and again ask for your consent.

 

How to prevent the setting of cookies

Of course, you may use our Platform without any cookies being set. In your browser, you can at any time configure or completely deactivate the use of cookies. This may, however, lead to a restriction of the functions or have adverse effects on the user-friendliness of our website. You may at any time object to the setting of optional cookies by using the respective objection option indicated in the table above.

 

Website Analysis with Google

Google will analyze your use of our website on our behalf. To this purpose, we use the cookies described in more detail in the above table. The information collected by Google in connection with your use of our website (e.g. the referring URL, our webpages visited by you, your browser type, your language settings, your operating system, your screen resolution) will be transmitted to a server of Google in the US, where it will be stored and analyzed. The respective results will then be made available to us in anonymized form. Your usage data will not be connected to your full IP address during this process. We have activated on our website the IP anonymizing function offered by Google, which will delete the last 8 bits (type IPv4) or the last 80 bits (type IPv6) of your IP address after each data transfer to Google. Moreover, by concluding specific agreements with Google we ensure that an adequate level of data protection is maintained with respect to the processing of personal data by Google in the US.

You may withdraw your consent to the use of web analysis at any time, either by downloading and installing the provided Google Browser Plugin or by administrating your consents in the above table, in which case an opt-out cookie will be placed. Both options will prevent the application of web analysis only as long as you use the browser on which you installed the plugin and do not delete the opt-out Cookie.

Further information on Google Analytics is available in the Google Analytics Terms of Use, the Privacy and Data Protection Guidelines of Google Analytics and in the Google Privacy Policy<.

 

External content provider on the Platform

We include third-party services and/or content on our Platform. When you use such third-party services or when third-party content is displayed, communication data are exchanged between your computer or mobile device and the respective provider for technical reasons.

The respective provider of the services or content may also process your personal data for own additional purposes. To the best of our knowledge, we have configured the services and content of providers known to process personal data for own purposes in such a way that either any communication for other purposes than to present their services or content on our Platform is blocked, or communication only takes place once you have actively opted to use the respective service. However, since we have no control over personal data collected and processed by third parties, we are not in a position to provide binding information regarding the scope and purpose of such processing of your personal data.

 

Information on side effects and quality complaints

This website is not intended or designed for communications regarding side effects, lack of therapeutic effect, medication errors, grey market products/counterfeit medicine, incorrect or off-label use, quality complaints and/or other issues regarding the safeness or quality of Bayer products. If you wish to report side effects or make a quality complaint, please contact your health care professional (e.g. physician or pharmacist), your local health authority, or use our Website for the report of undesirable side effects.

If you nevertheless report to us undesirable side effects or other issues regarding the safeness or quality of Bayer products, we will be legally bound to deal with your communication and may have to contact you for clarification purposes. Subsequently, we may have to notify the competent health authorities of the issues reported by you. In this context, your information will be forwarded in pseudonymized form, i.e. no information by which you may be directly identified will be passed on. We may also have to forward these pseudonymized notifications to our group companies and cooperation partners, to the extent these are likewise obliged to notify their respectively competent health authorities.

 

Transfer of data for commissioned processing

For the processing of your personal data, we will to some extent use specialized service contractors who act as our data processors. Such service contractors are carefully selected and regularly monitored by us. They will in this regard only process personal data in accordance with our instructions and based on an appropriate data processing agreement.

 

Processing of personal data outside the EU / the EEA

Your personal data will in part also be processed in countries outside the European Union (“EU”) or the European Economic Area (“EEA”) for which the European Commission has not issued a decision that the country would ensure an adequate level of data protection. In such cases, we will ensure that a sufficient level of protection is provided for your personal data, e.g. by making use of the Standard Contractual Clauses adopted by the European Commission (copy available on request), or we will ask for your explicit consent to such processing.

 

Retention period

We retain your data for the duration of your membership on the Platform. Upon receiving notice of your account deactivation, the data on the Platform will be deleted.

 

Information regarding your rights

The following rights are in general available to you according to applicable data privacy laws:

• Right of information about your personal data stored by us
• Right to request the correction, deletion or restricted processing of your personal data
• Right to object to a processing for reasons of our own legitimate interest, public interest, or profiling , unless we are able to proof that compelling, warranted reasons superseding your interests, rights and freedom exist, or that such processing is done for purposes of the assertion, exercise or defense of legal claims
• Right to data portability
• Right to file a complaint with a data protection authority
• You may at any time withdraw your consent to the processing of your personal data with future effect. If you wish to withdraw your consent, you may do so via Platform settings, or by sending a notice to the contact details below

If you wish to exercise your rights, please address your request to the contact indicated below (“Contact”).

 

Contact

For any questions you may have with respect to data privacy, or if you wish to exercise your rights, please

contact our company data protection officer at the following address:

Data Protection Officer of Bayer Middle East FZE:

Bayer Middle East FZE

Dubai Science Park, HQ Building

North Tower, 13-14th Floor

PO BOX 500829, Dubai, United Arab Emirates 

 

Amendment of Privacy Statement

From time to time, we may update this Privacy Statement. When we do, we will post it on the Platform and include the effective date of the update. Any amendments become effective upon publication on the Platform. We therefore recommend that you regularly visit the website to keep yourself informed on possible updates.

Last updated:30/09/2021