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.
Opella has developed several Global Privacy Notices for specific categories of individuals (e.g., Employee seekers, Healthcare professionals, staff of our vendors, etc.) and for specific contexts of interaction (e.g., visit to a website, participation in an event, etc.) which are available here: https://www.opella.com/en/privacy-center/documents/global-notices.
If none of the above applies to you, this Global Privacy Notice explains how and why we may process Personal Data of other categories of peoples, including but not limited to:
- employees, owners, representatives or collaborators of our Business Partners;
- media contributors (journalists, influencers, etc.);
- employees, representatives or collaborators of supervisory authorities, regulators, external auditors, certification agencies, payers, governmental agencies;
- members of work councils or independent ethics committees
- financial analysts, investors.
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.
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 with which you have the most direct interaction in a given context 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.
What Data we collect about you and why.
The Personal Data we may collect about you belong to the following categories:
- Personal identification data, such as name, address, residency, date of birth, national ID, email address and telephone number;
- Contact details, such as home address, email addresses, phone numbers, and emergency contact information;
- Organizational affiliation data, such as company or organization, job title, role, function, department, BU or division;
- Communication information, such as email subject line and contents, video or phone call recordings, voice mail, IM contents, communication logs and meta-data (e.g., date, time, duration, location, addressees, sender, etc.);
Depending on the nature and scope of your relationship with us, we may process such Personal Data for one or more of the following purposes:
- to manage and nurture the relationship with you, for example by inviting you to provide feedback or to participate in surveys, or events;
- to handle financial and contractual matters concerning the relationship we have with you or with the organization you own, represent, work for or collaborate with;
- to provide support, assistance and care, for example to respond to any request or inquiry you may direct to us;
- to manage external relations, for example by providing you information about us, our products or our initiatives that may be relevant in the context of the relationship we have with you or with the organization you own, represent, work for or collaborate with;
- to fulfill our legal, regulatory, ethical and compliance obligations, when, for example, we need to abide to a law or fulfill a request from an authority or law enforcement agencies;
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.
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,
- from other affiliates of Opella,
- from the organization you own, represent, work for or collaborate with,
- from publicly available sources.
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.
We operate in a complex ecosystem of Opella affiliates, third-party service providers with their sub-contractors, commercial partners, scientific partners, customers, regulatory bodies, public authorities, and law enforcement agencies.
Provided that we are legally authorized to do so, your Personal Data may be shared or otherwise made available to various recipients inside and outside Opella in various circumstances.
Such recipients may include:
- 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 for to support the processing of your Data for the purposes described in the previous sections;
- professional advisors and auditors;
- supervisory & regulation bodies, public authorities, courts, and law enforcement bodies. This may happen, for example, in circumstances that include, but are not limited to fulfilling our reporting obligation; responding to requests from them; when it is necessary to establish, exercise, or defend legal claims; when you request us to do so if this does not constitute a violation of our or others' rights; when it is necessary to prevent physical harm or material financial losses to us or others.
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.
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.