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 your Personal Data when you visit one of our websites or social media pages, regardless of whether you also have other relationships with Opella (e.g. as an employee, healthcare professional, or business customer). 

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 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 who manages the website or social media page you visit is responsible for the processing of personal data in relation to such visit. Such information is generally available directly on the website or social media page. 

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 and surname; 
  • Contact details, such as addresses, email addresses, and phone numbers;  
  • Organizational affiliation data, such as company or organization, job title, role, function, functional responsibilities or domain areas;  
  • Device and equipment information, such as the IP address, device type, unique device identification number, browser type, operating system, broad geographic location (e.g., country or area), and other technical information; 
  • Preference and behavioral information, such as the contents accessed, the links clicked, dates and times of connection, reactions and scoring, personalized settings and choices, including but not limited to preferences about language, direct marketing, and cookies; 
  • Social information, such as group memberships and social media interactions and connections; 
  • Communication information, such as the content and other details (e.g., date, time, recipients) of relevant messages submitted through a website or social media feature, such as a "contact us" form or a messaging functionality within a social media platform. 
  • Images, such as profile pictures or photos uploaded by social media users. 


We may process such Personal Data for one or more of the following purposes:  

  • to manage and nurture the relationship with you, for example to handle interactions and requests, social media engagement and user-generated contents through our digital channels; 
  • to develop and improve our products and services, for example by displaying personalized content or by enhancing the experience of visitors through the use of analytics; 
  • to provide commercial and promotional information about our products and services, for example to serve digital advertisements that are relevant to the visitors across various online platforms; 
  • to develop and operate our digital platforms and tools, for example by facilitating access, or optimizing navigation automatically adapting the website layout to the device type or remembering preferences; 
  • to protect our staff, visitors, assets and information, for example by ensuring the security and protection of your and our data, as well as that of our digital channels and infrastructure; 
  • to fulfill our legal, regulatory, ethical and compliance obligations, for example (when applicable) to meet accessibility requirements, or allow for reporting and handling of issues related to our products; 
  • to establish, exercise or defend our legal rights, for example to handle and oversee disputes, claims, and litigations involving the organization. 


We process personal data collected through our websites and social media pages 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. 

When you visit one of our websites or social media pages, we normally obtain your Data: 

  • though automated tools or tracking technologies, for example when you interact with our websites and social media pages. For further details, consult the “Cookies and similar tracking technology” appendix to this Global Notice, or the cookie notices on our websites and on the social media platforms where our pages are hosted.  
  • directly and knowingly from you, for example when you fill-in “contact us” forms or you react or comment on our social media pages; 
  • from Partners or Service Providers, for example when you interact with us through a social media platform which is operated by a third party. See “Personal Data collected and processed by social media platform operators” below for more details; 


In addition, new Data about you may be inferred, derived or generated by us as part of the processing for the purposes described above, for example when we infer what information may be more relevant for you.  

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. 

Unsolicited Personal Data 
In some circumstances, you may voluntarily provide us with unsolicited Personal Data, for example when you use contact forms or share with us comments or messages through social media platforms. We ask for your collaboration to avoid sharing Personal Data that is unnecessary. Should this happen, we will take reasonable steps to ensure the unnecessary Data is not used and is deleted without delay.

Personal Data you provide about others. 
In some circumstances, you may provide us with Personal Data about others (for example, when you comment on our social media pages). Whenever you provide us with Personal Data about others, you must ensure that this does not violate those people's rights. If unsure, please refrain from communicating such Personal Data to us.

Personal Data collected and processed by social media platform operators  
Most of the Personal Data about visitors to our social media pages is collected by the social media platform operators (such as Facebook, Instagram, etc.), who also execute part of the processing of Personal Data for the purposes described above. When this happens, they usually act as a service provider based on an agreement that defines the parties' responsibilities for using such data. 
In a few cases, the social media platform operator and Opella share responsibility for the processing of Personal Data that is carried out for common interests. When this happens, details concerning shared responsibilities are usually included in the privacy notice that the platform operator makes available when the data is collected. 
Moreover, social media platform operators also collect and process Personal Data for their purposes and under their responsibility. Visitors to our social media pages are encouraged to read any privacy notice, policy, and notice made available by each social media platform operator. 

Chatbots 
A chatbot is a computer program simulating human conversation through voice commands, text chats, or both. When one of our websites incorporates a chatbot, further Data may be collected and processed. Nonetheless, the categories of Personal Data a chatbot may collect and the purposes why such information can be used remain those described above.  

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.  

Appendix  
COOKIES AND SIMILAR TRACKING TECHNOLOGIES

Cookies and similar tracking technologies are used within our websites, online services and applications (both web and mobile) for different purposes. This appendix to the Opella Global Privacy Notice to the visitors to our websites and social media pages provides you with details concerning the relevance of such tracking technologies in relation to the processing of Personal Data and your privacy. 

When you visit or interact with our websites, online services and applications, Opella (and/or authorized third parties) may store and/or access data using cookies. The specific types of technologies used may vary depending on the case, for this reason we invite you to refer to the specific information available in each website, online service and application. 

What are tracking technologies and how are they used. 

Cookies are small text files which are saved on your device when you visit a website, or use an application, whether web or mobile, to save some information on it.  

Although cookies are the most common and well-known technology used for this purpose, other technologies such as local shared objects, local storage (such as HTML5), web beacons/pixel tags, embedded scripts, ETags and other technologies may store and/or access information on a device. For the sake of brevity, we will use the term "cookie" to reference all these technologies, and we will refer to a single visit to a website or use of an application as a "session".  

Each cookie may serve a different purpose by collecting, storing, and making available other information about the device, the browser, the activities carried out during one or more session. Some of this information is used solely in the context of the ongoing session, other information is stored for a longer time and is used in future sessions.  

The information stored and processed by means of cookies is considered Personal Data when it is used to distinguish you from other users or visitors (e.g., recognize you directly or indirectly when you visit again a website) or evaluate, learn or decide something about you (e.g., whether to show you a content that we believe is of your interest based on preference settings or your observed behavior). To obtain these results, some cookies enable tracking visitors across websites and applications. 

Personal Data stored and processed by means of cookie belongs to the following categories: 

  • Device and equipment information, such as session ID, IP address, device type, unique device identification number, browser type, operating system, broad geographic location (e.g., country or area), and other technical information;  
  • Preferences and behavioral information, such as the contents accessed, the links clicked, dates and times of connection, reactions and scoring, personalized settings and choices, including but not limited to preferences about language, direct marketing, and cookies themselves. 

What are tracking technologies and how are they used. 

Cookies are small text files which are saved on your device when you visit a website, or use an application, whether web or mobile, to save some information on it.  

Although cookies are the most common and well-known technology used for this purpose, other technologies such as local shared objects, local storage (such as HTML5), web beacons/pixel tags, embedded scripts, ETags and other technologies may store and/or access information on a device. For the sake of brevity, we will use the term "cookie" to reference all these technologies, and we will refer to a single visit to a website or use of an application as a "session".  

Each cookie may serve a different purpose by collecting, storing, and making available other information about the device, the browser, the activities carried out during one or more session. Some of this information is used solely in the context of the ongoing session, other information is stored for a longer time and is used in future sessions.  

The information stored and processed by means of cookies is considered Personal Data when it is used to distinguish you from other users or visitors (e.g., recognize you directly or indirectly when you visit again a website) or evaluate, learn or decide something about you (e.g., whether to show you a content that we believe is of your interest based on preference settings or your observed behavior). To obtain these results, some cookies enable tracking visitors across websites and applications. 

Personal Data stored and processed by means of cookie belongs to the following categories: 

  • Device and equipment information, such as session ID, IP address, device type, unique device identification number, browser type, operating system, broad geographic location (e.g., country or area), and other technical information;  
  • Preferences and behavioral information, such as the contents accessed, the links clicked, dates and times of connection, reactions and scoring, personalized settings and choices, including but not limited to preferences about language, direct marketing, and cookies themselves. 

Cookies categories.

Cookies can be categorized in different ways.  

Depending on who uses them, cookies are classified as: 

  • first-party cookies, which are set by the website or application you’re visiting, and only used by such website or application; 
  • third-party cookies, which may be placed by third-party services that appear on the first party website or application and may be used by such third parties for their purposes too. 


Based on their duration, we can refer to: 

  • session cookies, which only last as long as your online session, and disappear from your device when you close your browser or mobile app; 
  • persistent cookies, which remain on your device after your session has been closed and last for a time which vary depending on the function of the cookie. Persistent cookies are used to remember information for future sessions.  
     

Another relevant classification concerns the purpose of the cookies: 

  • functional cookies, which enable the website to provide functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If these cookies are not allowed, some features or services may not function properly. 
  • performance cookies, which allow us to count visits and traffic sources so we can measure and improve the performance of our site. They measure how often you visit our website and how you use it. They help us to know which pages are the most and least popular and see how visitors move around the site. The information these cookies collect is not used to learn or decide anything about you, but to obtain aggregate and anonymous indicators . If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance; 
  • targeting cookies, which may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising. Subject to your prior consent, these cookies stored in your device by the third-parties listed below, allow us to count the number of displays of advertising content in our advertising spaces, identify these contents, the number of displays for each of them, the number of users who clicked on each content and where applicable, further actions carried out by the users on the sites linked to these advertising contents, to be able to calculate the sums due to the actors of the advertising distribution chain (communication agency, advertising management, site/distribution medium) and to establish statistics. Please note that when consenting to the use of targeting cookies, you also consent to the follow up of your navigation on other websites.  


Finally, in some jurisdiction it is relevant to distinguish between: 

  • strictly necessary cookies, a subset of functional cookies which are fundamental for the proper functioning of the website or platform as a whole, as well as for some of their key features. Relevant features or functions of the website or app will not work properly, when these cookies are blocked;   
  • optional cookies, the absence of which does not substantially jeopardize the experience of the visitor or user, although their presence might help.

Cookies preferences and permissions. 

The use of cookies may be subject to different types of permissions, depending on the laws applicable in both the country of the Opella entity who operates the website or platform, and on the countries of targeted visitors:

  • in some countries, we need prior consent before downloading any cookie to visitors’ devices, regardless to its function or category; 
  • in some other countries, prior consent is necessary only for optional cookies; 
  • in some other countries yet, prior consent is not required but we must inform visitors about the intended use of cookies and give them the opportunity to opt-out. 


Depending on the country, we comply with locally applicable rules by providing you notices and tools to manage your cookie preferences directly within our websites and applications.  

When necessary, we normally show you some basic information and prompt you to make a choice about cookies at your first visit or access. In this context you are normally offered the opportunity to access more detailed information about the cookies in use, their categorization and purpose, and manage your preferences in greater detail. 

Moreover, we normally make available features within the website or application to allow you managing your preference at any time and we periodically prompt you to review your preferences (usually once every one or two years). 

Limited to websites or applications accessed through a browser, the browser itself may also allow you to manage cookies. Depending on the browser you use, you may have one or more of the following options: 

  • block all cookies; 
  • selectively block only some cookies or categories of cookies, such as third-party or advertisement-related cookies, while allowing other categories; 
  • use private browsing features, by means of which the browser creates a temporary session that is isolated from user data;  
  • delete cookies, by means of which you can clean up any cookie from your device.


All the above may impact the correct functioning of websites and web applications or the availability of some content. Should you experience a malfunction you can adjust the settings accordingly. 

International transfer of Personal Data related to cookies.

Certain processing of data stored within cookies may involve the transfer of Personal Data between countries where the applicable data protection laws do not guarantee an equivalent level of protection. 

Any such transfers will be done in accordance with the applicable laws, and in particular with the requirements concerning the transmission of data to third countries. In some circumstances, we will rely upon an adequacy decision to lawfully transfer personal information. When this is not possible, we will normally rely on Standard Contractual Clauses to allow for personal data to be transferred across jurisdictional borders.  

Details on social media cookies

Social media cookies allow you to share content with social media platforms (e.g., Facebook, Instagram, LinkedIn, etc.).  

Usually, these technologies are useful for the third parties to create user profiles, monitoring online behavioral and present suitable advertisements. For more information on how they use your personal data, you are kindly referred to their respective privacy policies.  

Often social media cookies are used in association with: 

  • social media plug-ins: they are small pieces of software which create a link between your visit to our website or application and the social media platform of a third party. These technologies will let the third party to know that you have visited our website or application and may let them receive cookies placed on your device; 
  • Pixels (or other similar tracking technology, e.g. LinkedIn Insight Tags): they are small pieces of software which are used to allow social media platforms for ad tracking, conversion measurement, and retargeting. 

When used for targeted advertising or behavioral tracking, the social media platform operator and Opella share responsibility for the processing of Personal Data that is carried out for common interests. When this happens, details concerning shared responsibilities are usually included in the privacy notice that the platform operator makes available when the data is collected.  

In particular, regarding websites and social media pages in Europe, Opella entered into specific joint-controller privacy terms with: 

 

You can check them to understand which is the social media platform provider legal entity that shares responsibility with Opella on your Personal Data, understand how and on which legal ground it processes your Personal Data and how exercise your rights.