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 Notice is intended to describe common email tracking technologies, what information is collected through them, how we use them and why.
What are email tracking technologies, and what are they used for.
Email is still a relevant means of communication between organizations and their customers, employees, and business contracts. As such, organizations devote significant resources to increase the efficiency and effectiveness of their email communication campaigns. To this purpose, understanding which messages have been read, by whom, when, how many times, and (when applicable) who clicked on links embedded in such messages is very helpful to improve future communication and reduce the likelihood of sending messages that are not of interest for the recipient.
To obtain the information described above, organizations can rely on different email tracking technologies. The most common email tracking technologies are tracking pixels and tracking links.
Tracking pixels - Business senders usually do not store images inside email files themselves. Instead, they embed links pointing to where that image is hosted on a web server. When the recipient opens the email, the email app reads that link and automatically sends a request out to the server where the image is stored, asking it to fetch the image. In response to this call, the image in question is loaded and written to the user’s terminal memory for the email client to display. This is standard practice for efficiency: it keeps email sizes small, speeds up loading, and lets one hosted image serve multiple recipients without duplicating it in every email.
The request sent by an email app carries information that, if collected and analyzed, may indicate if a message was opened or not by a specific recipient and at what time.
A tracking pixel (also referred to as a web beacon or pixel tag) is a tiny and typically invisible, image whose only function is to trigger that outgoing request described above, so the sender can capture the information it carries and analyze it. The URL of the tracking pixel usually has unique identifiers or parameters associated with the recipient or the specific message in which the image appears.
Tracking links - Emails can contain links that recipients can click. These links may be configured to pass along information to the sender about who clicked the link (such as a recipient identifier), in addition to such as standard technical information exchanged during online communications including the IP address, date and time of access, device or browser details.
Tracking links, therefore, are links to web resources that are configured in a way that allows the sender to obtain additional information to track whether a certain recipient clicked on the link, when, how many times, etc.
What Data is collected by means of email tracking technologies, and why.
The information we collect by means of email tracking technologies belongs to the following categories:
- Engagement and behavioral information, such as whether and when the email was opened, the links clicked, the date and time of opening or interaction, the number of times an email was opened, whether the email was forwarded, and other engagement metrics.
- Device and equipment information, such as IP address, device type, email client and version, operating system, broad geographic location (e.g., country or area), and other technical information.
Depending on the type of email, Opella may use email tracking technologies for different purposes.
Transactional emails
A transactional email is sent to provide the recipient with important information about a requested service, their account, or their transactions. It is not a promotional message, but an informative or functional message, necessary for the contractual relationship or the requested service.
Transactional emails are typically generated and sent automatically in response to a specific event or action.
These may include, for example, welcome emails, account alerts, notifications related to events such as package shipments, order confirmations and purchase invoices, reminders, and password reset emails, responses to customer service requests, appointment or reservation reminders, payment notifications or breach notification emails related to the requested service.
When used in the context of transactional emails, the Data is primarily processed for:
- Deliverability and functionality: , To determine whether a message has been delivered opened, and rendered correctly across different email clients and devices.
- Compliance: To demonstrate compliance with our legal, regulatory, or contractual obligations relating to the delivery of information to the recipient.
Standardized email campaigns
These are coordinated series of email communications designed to achieve a specific purpose. During standardized email campaigns, each recipient receives the same message and the personalization is absent or minimal (e.g. limited to the salutation). The campaign may also serve marketing, informational, engagement, or other business purposes.
When used in the context of standardized email campaigns, email tracking technologies are mainly used to measure the performance and effectiveness of the campaign itself and improve future campaigns. For these campaigns, data is generally aggregated to obtain non-personal metrics such as how many recipients opened a certain message, clicked on the links within the message, measure campaign performance and improve future communications.
Personalized email campaigns
- These are coordinated series of communications email campaigns designed to achieve a specific purpose. During personalized email campaigns, the elements of individual emails are tailored, to varying degrees, to the characteristics, preferences, behavior, or circumstances of each recipient or defined group of recipients. The campaign may also serve marketing, informational, engagement, or other business purposes.
- In personalized email campaigns, tracking technologies may be used to tailor the content, frequency, and timing of future communications based on the recipient’s engagement with previous email campaigns. To this purpose, the Data collected is linked to other information Opella already holds about them.
Similarly to what happens with standardized campaigns, the Data is also aggregated and analyzed to measure the performance and effectiveness of the campaign itself and improve the effectiveness of future campaigns.
Your choices regarding tracking pixels.
Where required by applicable laws, we will obtain prior consent from the recipient before using tracking, and recipient will be allowed to withdraw such consent at any time. When email tracking technologies are used in support of the purposes for which a recipient has provided consent, we may rely on that consent for such use, in accordance with applicable law.
Who is responsible for using this Data.
Opella is composed of many companies around the world, the list of which is available here: https://www.opella.com/en/privacy-enter/documents/ListOfOpellaAffiliates-en-GL.
The Opella affiliate who, directly or through a service provider, sends an email that embeds email tracking technologies is responsible for the processing of Data collected through such technologies. The name of the Opella affiliate acting as the sender, is normally disclosed within the message itself.
Who can access the Data.
Data collected through email tracking pixels may be accessed by:
- employees and staff of Opella affiliates and subsidiaries, to allow for the processing of your data for the purposes described in the previous sections;
- our partners such as service providers, contractors, or vendors, acting upon our instructions to support the processing of your Data for the purposes described in the previous sections;
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 the Data processed.
We are part of a multinational group with employees, affiliates, partners and service providers located around the world. Consequently, the Data collect through email tracking technologies 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 Standard Contractual Clauses.
How long we keep the Data.
The Data collected through email tracking technologies will be kept for a period not exceeding the time necessary to achieve the purposes for which it was collected. As the main purpose for which we collect and use the Data is to constantly improve our understanding of the interests and preferences of the recipients of our promotional messages, the Data is normally retained for as long as we maintain a relationship with the concerned individual that involves sending such messages.
Where the Data collection and use is subject to recipient’s prior consent and the consent is withdrawn, the Data is then deleted or anonymized without undue delay.
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.
Your rights.
You have rights regarding your Personal Data which may include, for example to:
- access and/or receive a copy of your Data;
- rectify your Data, should it be inaccurate, incomplete, or obsolete;
- delete 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 be provided 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.
