PRIVACY POLICY                                                                                         

Effective Date of this Privacy Policy

June 2016

Privacy at BESINS

Besins Healthcare (UK) Ltd and its affiliates (together “BESINS” or “we”) recognise the importance of your privacy and understand that the security of your Personal Information is important to you. We are committed to protecting the Personal Information you provide to us. This Privacy Policy outlines how we generally manage your Personal Information and protect your privacy.

What is “Personal Information” as used in this Privacy Policy?

“Personal Information” means information that identifies you or could be used to identify you, directly or indirectly, and which is submitted to and/or collected by BESINS websites.

What kind of “Personal Information” does BESINS collect?

Examples of Personal Information that we may collect include your name, your postal address, your email address, date of birth, your telephone number, and your online identifier. We do not collect through our websites any Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, data concerning health or data concerning your sex life or sexual orientation.

What is the scope of this Privacy Policy?

Unless otherwise specifically noted, this Privacy Policy does not apply to Personal Information collected from you offline, to BESINS websites that do not link to this Privacy Policy, or to third-party websites to which BESINS websites may link. Your use of BESINS websites is subject to this Privacy Policy and the Terms of Use.

We recommend that you read this Privacy Policy before using BESINS websites or submitting Personal Information to us.

How does BESINS collect Personal Information online?

We collect information in two ways:

  • Personal Information you submit: we collect Personal Information that you enter into data fields on BESINS websites. For example, you may submit your name, postal address, e-mail address, and/or other information in order to receive information about various subjects, register for BESINS programs, contact BESINS customer service, or respond to BESINS surveys. To protect your privacy, you should not provide us with any information that is not specifically requested.
  • Passive collection of unidentifiable information: BESINS websites may collect information about your visits to BESINS websites without you actively submitting such information. Unidentifiable information may be collected using various technologies, such as cookies (see our Cookies Policy), and web beacons. Web beacons (also referred to as GIF files, pixels or Internet tags) help us recognise a unique cookie on your browser. Your Internet browser automatically transmits to BESINS websites some of this unidentifiable information, such as the URL of the website you just visited and the browser version your computer is operating. Passive information collection technologies can make your use of BESINS websites easier by allowing us to provide better service, customise BESINS websites based on consumer preferences, compile statistics, analyse trends, and otherwise administer and improve BESINS websites. Certain features of BESINS websites may not work without use of passive information collection technologies. Information collected by these technologies cannot be used to identify you without additional identifiable information and we will not connect additional identifiable information with information collected through the use of such tracking technologies. With respect to limiting or disabling tracking technology please see below “What choices do I have about how BESINS collects and uses Personal Information about me?

For what purposes does BESINS collect, hold, use and disclose Personal Information?

We will use the Personal Information you provide through BESINS websites for the purpose of responding to your questions and providing you with the requested service or information. After you have entered Personal Information into a form or data field on a BESINS website, we may use certain identifying technologies to allow that BESINS website to “remember” your personal preferences, such as sections of that BESINS website that you visit frequently and, if you choose, your user ID. We will only use your Personal Information for other business purposes (such as to offer you the opportunity to receive notices regarding BESINS’ products or services, to invite you to participate in surveys about our products, or to notify you about special promotions) if you provided us with your prior opt-in for such purposes. We will never send you a commercial electronic message unless permitted.

Does BESINS consolidate Personal Information?

We may consolidate the Personal Information of customers who use BESINS websites. In addition, we may consolidate information in a non-identifiable form (aggregate/anonymous data) to help us better design BESINS websites and BESINS products, to enhance our research activities, and to facilitate other business functions.

What choices do I have about how BESINS collects and uses Personal Information about me?

You may always limit the amount and type of Personal Information that we receive about you by choosing not to enter any Personal Information into forms or data fields on BESINS websites. However, please note that if you choose not to provide the Personal Information requested of you to us, we may be unable to provide you with the products and services you require or contact you to perform the functions and activities described below.

Other parts of BESINS websites may ask whether you wish to opt into our contact lists for offers, promotions and additional services that may be of interest to you. You may also be provided with preference questions or preference boxes allowing you to indicate that you do not want BESINS websites to use tracking technologies, such as cookies, to “remember” your Personal Information, such as user IDs or mailing addresses, on return visits. However, BESINS websites that use tracking technologies to collect unidentifiable information do not generally provide you with the ability to opt out of the tracking technologies. Some Internet browsers allow you to limit or disable the use of tracking technologies that collect unidentifiable information. See our Cookies Policy for further guidance.

Who will have access to Personal Information about me?

Personal Information can be accessed by a restricted number of BESINS employees, by certain companies with which we may conduct joint programs, and by third parties with whom we contract to carry out business activities for or on behalf of us. We train our employees, consultants and subcontractors about the importance of privacy and how to handle and manage Personal Information and customer data appropriately and securely. Third parties who have contracted with us are instructed to process the Personal Information only on documented instructions from us, to use Personal Information for the agreed upon purpose only, not to sell Personal Information to other third parties, to make sure that their employees authorised to process the Personal Information have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality, and not to disclose it to other third parties except as may be required by law. Also, it is BESINS practice to seek your consent where required by applicable law if you are registering for a program which is conducted in conjunction with another company that may require access to your Personal Information. Personal Information collected from you may also be transferred to a third party in the event that the business of this site or a part of it and the customer data connected with it is sold, assigned or transferred, in which case we would require the buyer, assignee or transferee to treat Personal Information in accordance with this Privacy Policy. Finally, Personal Information may be disclosed to a third party if we are required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding.

How does BESINS protect the privacy of children?

We do not knowingly collect or use any Personal Information from children (we define “children” as minors younger than 18) on BESINS websites. We do not knowingly allow children to order our products, communicate with us, or use any of our online services. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below (see: How can I contact BESINS?), and we will work with you to address this issue.

How does BESINS secure Personal Information?

It is BESINS practice to secure each BESINS website that collects Personal Information, but BESINS urges you to exercise caution when transmitting Personal Information over the Internet. BESINS websites covered by this Privacy Policy will display a warning whenever you link to a website that is not controlled by BESINS. You should check the privacy policies of such third-party websites before submitting Personal Information.

Management and security of Personal Information

BESINS stores your Personal Information in hard copy documents and/or as electronic data in our software IT systems (and those of our service providers). BESINS IT servers, databases and cloud based data centres are located globally. We may therefore transfer your Personal Information to one of BESINS’ IT servers, databases and cloud based data centres outside your country of domicile. However, BESINS is committed to keeping your Personal Information secure and to ensuring effective levels of data protection, in accordance with this Privacy Policy and applicable law.

How long will BESINS store Personal Information?

In general, we will only store your Personal Information for as long as it is needed to fulfil the purposes for which it was collected, subject to applicable data retention periods imposed upon us by applicable law.

How may I access Personal Information held by BESINS?

You can, in most cases, access the Personal Information we hold about you. All requests for access to your Personal Information can be directed using one of the methods specified below (see: How can I contact BESINS?). Please note that in certain circumstances we are entitled to deny access. If access is denied, reasons for the denial of access will be given in writing.

How may I correct Personal Information, or delete it from current customer records?

With your support we will keep Personal Information accurate and up-to-date. You may request to remove, amend or correct your Personal Information at any time. You have also the right at any time to withdraw your consent to the use of your Personal Information in the future. Please notify us of your wishes by contacting us using one of the methods specified below (see: How can I contact BESINS?), especially if you believe that the information we hold about you requires changing or has become out-of-date.

What if you have a complaint?

If you have any concerns or complaints about the manner in which your Personal Information has been collected or handled by us, please contact us using one of the methods specified below (see: How can I contact BESINS?).

It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response, you may make a complaint with a relevant supervisory authority (see for the UK: https://www.gov.uk/data-protection/make-a-complaint)

How can I contact BESINS?

If you would like to have access to Personal Information we hold about you, if you have questions about the scope, use, amendment, or deletion of Personal Information that you have provided to BESINS, or if you would like to opt out of future communications from a BESINS business or a particular BESINS program, or if you are a parent and become aware that your child has provided us with information, or if you want to make a complaint or raise any concern, please contact us by clicking on the “Contact Us” link on the BESINS website you are visiting or by sending an e-mail to information@besins-healthcare.com. Alternatively, you may send a letter to the following address:

Besins Healthcare

28 Poland Street

W1F 8QN

United Kingdom

Your question, request, concern or complaint will be directed to the appropriate person who will consider and respond to your complaint within fourteen (14) days. In all communications to BESINS, please include the e-mail address used for registration (if applicable), the BESINS website address on which you provided any Personal Information about which you have questions or concerns, and a detailed explanation of your request. If you would like to delete, amend or correct your Personal Information and are contacting us by e-mail, please put “Deletion Request” or “Amendment/Correction Request”, as applicable, in the subject line of the e-mail. We will do our best to respond to all reasonable requests in a timely manner.

How will I know whether BESINS has updated this Privacy Policy?

If BESINS changes its privacy practices, an updated version of this Privacy Policy will reflect those changes and we will notify you of such changes by updating the effective date at the top of this Privacy Policy. Without prejudice to your rights under applicable law, BESINS reserves the right to amend this Privacy Policy from time to time to reflect technological advancements, legal and regulatory changes and good business practices.

BHUK/2016/309. Date of preparation July 2016