Data privacy | Opella

What is this document about.

Opella is a multinational group that includes Opella Healthcare with its affiliates and subsidiaries (collectively “Opella”, “we”, or “us”).

Your Personal Data (or Data) is any information that is about you, or is related to you and used to learn, evaluate, or decide something about you. Opella understands the importance of privacy and the protection of Personal Data and is committed to ensure protection and security of Data we process.

This Global Privacy Notice explains how and why we may process Personal Data of retail customers and users of our products, except for research subjects.

We provide detailed information on what Data is actually collected and used through specific privacy notices that we make available when your Personal Data is collected.

If you interact with us in different capacities (e.g., as a visitor to our websites or social media pages, or a participant in an event) or if certain jurisdictions apply to you, please refer to the other relevant Privacy Notices on Opella.com for additional information.

Who is responsible for using and protecting your Data.

Opella is composed of many companies around the world. (A full list is available at: https://www.opella.com/en/privacy-center/documents/ListOfOpellaAffiliates-en-GL).

Depending on the nature and the context of your interactions with us, different Opella companies may be responsible for processing your Personal Data, for different purposes.

As a general criterion, the Opella company you directly interact with as a retail customer or user of our product is normally responsible for processing your Personal Data in such context.

In all cases, we explicitly state which entities are responsible for specific uses of your Data within the privacy notice we make available to you when such Data is collected.

In some circumstances, you may not interact with us directly, but we may still collect and use your Data, for example when pharmacists, doctors, therapists or other healthcare professionals report to us about an adverse effect of our product involving you. In these situations, the Opella company responsible for the processing of your data is the one which obtained the authorization to sell the product in your country, and it is normally indicated on the packaging of the product.

What Data we collect about you and why.

Important remark: Depending on the country, the types of interactions permitted between consumer healthcare companies and retail customers or users of their products may be subject to strict regulations, particularly with respect to advertising, promotion and direct communications. We abide by the rules that apply in different markets, so some of the purposes listed below may not apply in your country

Pharmacovigilance and Product Quality Complaints

In this context, the Personal Data we may collect about you belong to the following categories:

Personal identification data, such as name and address, age, gender; 
Physical characteristics, such as weight, height;
Contact details, such as email addresses or phone numbers;
Social information, such as interactions, connections, or group membership;
Communication information, such as date, time, duration, and content of any message we may exchange with you;
Medical, health and impairment information, such as pre-existing conditions, allergies, prescriptions, product usage information, description of adverse events and reactions;

and such Data will be processed for the following purposes:

to ensure product quality and safety, for example by detecting, assessing, following up on, and preventing adverse events, or when responding to quality complaints regarding our products;
to fulfill our legal, regulatory, ethical and compliance obligations, for example by reporting adverse events to health authorities;
to establish, exercise or defend our legal rights, when, for example, we collect evidence, liaise with legal counsel, maintain records of legal proceedings, report on litigations and disputes.

Market research and promotion of our product

When allowed by the law, we may collect and use Data about retail customers and users of our products in the following categories:

Personal identification data, such as name and address, age, gender; 
Contact details, such as email addresses or phone numbers;
Social information, such as interactions, connections, or group membership;
Medical, health and impairment information, such as pre-existing conditions, allergies, prescriptions, product usage information, description of adverse events and reactions;

and such data will be processed for the following purposes:

to develop and improve our products and services, for example when we conduct market research surveys and analyze sales and feedback data.
to manage and nurture the relationship with you, for example by inviting you to participate in surveys or provide feedback;
to provide commercial and promotional information about our products and services, for example by sending direct marketing and promotional communications through various electronic channels. Learn more about this by reading the note on “Direct marketing” below;
to fulfill our legal, regulatory, ethical and compliance obligations, for example by handling your preferences concerning the use of your data;
to establish, exercise or defend our legal rights, when, for example, we collect evidence, liaise with legal counsel, maintain records of legal proceedings, report on litigations and disputes.

Whenever you visit one of our websites or social media pages, we can also collect some Data about you and use it for some of the purposes described in this section, for example to serve you advertisement that may be of interest for you, across multiple online platforms. For further details on this, you can read the Global Privacy Notice to the “Visitors of our websites and social media pages”, available on Opella.com.

Direct sales (eCommerce)

Our products are typically distributed and sold through a network of pharmacies, distributors and other retailers.

Even in the context of online sales, although our product name and brand are used in the marketplace, in most cases the seller is a third party, which is autonomously responsible for the use of your Data in the context of the sale of our products. The exact identity of the seller is made clear in the marketplace.

In some cases, however, Opella directly operates the online sale of its products and may collect Data about you belonging to the following categories:

Personal identification data, such as name, surname and title; 
Contact details, such as home address, email addresses, phone numbers;
Communication information, such as date, time, duration, and content of any message we may exchange with you;
Financial information, such as financial account data (credit card number, bank account), financial transaction data (purchases, sales, income, taxes, and other transactions);

and such Data may be processed to:

to handle financial and contractual matters, for example to process the sale and payment;
to provide and deliver products and services, for example to make sure the product is delivered to you;
to provide support, assistance and care, for example to handle customer inquiries or resolve issues;
to fulfill our legal, regulatory, ethical and compliance obligations, for example to comply with anti-fraud or privacy regulations;
to establish, exercise or defend our legal rights, when, for example, collecting evidence, liaising with legal counsel, maintaining records of legal proceedings, reporting on litigations and disputes.

On top of that, while you interact with the online marketplace platform, further data may be collected as described in the Global Privacy Notice to the “Users or our online services and applications”, available on Opella.com.

Legal ground

We process Personal Data for the purposes described above based on applicable legal grounds, which may include the necessity to provide requested services, compliance with legal obligations, legitimate business interests, or consent where required by law.

Data related to health: in certain jurisdictions, even personal data that is not directly related to health may still be considered as data concerning health, if it can be linked to an individual's interest in or use of medical products. This includes information that can infer health-related behaviors or preferences, even if it is not traditionally considered health data.

How we collect your Data.

Depending on the nature and scope of your relationship with us, we may collect your Personal Data from different sources and in a variety of circumstances and ways:

directly and knowingly from you,
though automated tool or tracking technologies
from other affiliates of Opella
from Partners or Service Providers
from Healthcare Professionals/Scientific Investigators

In addition, new Data about you may be inferred, derived, generated as part of the processing (for example certain degree of interest in our products, personality traits (based on engagement and content consumption patterns), purchase intent signals based on your interaction with our post or social pages).

If we obtain your Personal Data from more than one source, we may combine or link such Data and use it for purposes compatible with those for which it was originally collected.

Who can access your Data.

Only authorized recipients have access to your Personal Data to perform the activities described above. Such recipients may include:

employees and staff of Opella affiliates and subsidiaries;
our partners such as service providers, contractors, business partners or vendors acting upon our instructions;
regulatory bodies, public authorities, courts, and law enforcement bodies;
professional Advisors and Auditors;
supervisory & regulation bodies (payers, governmental agencies, ethics committees);
research partners or institutions.

Whenever required by the applicable law, we enter into contractual agreements with these recipients to ensure they provide adequate data protection measures, they commit not to use the Data for purposes other than those described in this Global Privacy Notice and cooperate with us to ensure that your rights can be effectively exercised.

Where is your Data processed.

We are part of a multinational group with employees, affiliates, partners and service providers located around the world. Consequently, your Data may be processed in and accessed from countries where different data protection laws apply.

When Personal Data is transferred to or accessed from other jurisdictions, we adopt one of the mechanisms provided by the law to ensure an equivalent level of protection of your Data in the destination country. This includes, for example, the adoption of the Standard Contractual Clauses.

How long we keep your Data.

Your Data will be kept for a period not exceeding the time necessary to achieve the purposes for which it was collected. The criteria for determining the retention period of the Personal Data consider the period of permitted processing (for all the relevant purposes), applicable regulations affecting the minimum or maximum retention period (if any), limitation of rights, and legal bases for processing.

How we protect your Data.

While we strive to protect your Personal Data, no Data transmission, use or storage can be guaranteed as 100% secure. To protect your Data, we adopt technical and organizational measures aimed at reasonably mitigating the risk that such Data is leaked, lost, or used for unauthorized purposes.

If a security incident occurs and affects your Personal Data, we will take reasonable actions to mitigate possible impacts on you. When the incident is likely to result in serious harm this may include a notification to you or to competent authorities.

Children Data.

We neither knowingly solicit Data from, nor target, children. If you’re a parent or guardian and you’re aware that your child has provided us with their Data, please contact us. We’ll take the necessary steps to delete such Data.

Your rights.

You have rights regarding your Personal Data which may include, for example:

have access to, and receive a copy of your Data;
obtain the rectification of your Data, should it be inaccurate, incomplete, or obsolete;
obtain the deletion of your Data in situations set forth by applicable data protection laws;
withdraw your consent to data processing at any time, without affecting the lawfulness of processing, where your Data has been collected and processed on the basis of your consent;
object to the processing of your Data, where it has been collected and processed on the basis of our legitimate interests;
request a limitation of data processing activities, in the situations set forth by applicable laws;
request that some of the Data you provided to us is brought to you, or to another company, in a commonly used, machine-readable format.

Your rights may vary depending on the privacy laws applicable to the specific use of your Data.

If you want to exercise any of your rights, please submit a request using this online form https://www.opella.com/en/privacy-center or use the other contact indicated in this or other privacy notices, as well as in the list of Opella affiliates available at: https://www.opella.com/en/privacy-center/documents/ListOfOpellaAffiliates-en-GL.

You are also entitled to lodge a complaint with your local Data Protection Authority.

Contact us.

If you have a question or any concerns regarding our use of your Data, visit https://www.opella.com/en/contact.

Where a Data Protection Officer or equivalent role is designated, you can also contact them. For further details consult the list of Opella affiliates available at: https://www.opella.com/en/privacy-center/documents/ListOfOpellaAffiliates-en-GL.

Changes to this Global Privacy Notice.

We may update this Global Privacy Notice periodically to reflect changes in the law or our practices. We encourage you to check this page periodically.

Opella Global Privacy Notice to retail customers and users of our products.