Data Privacy Statement
1. Handling of personal data
At Grünenthal Ltd., we believe transparency is the foundation of trustful collaboration. Below we’ll provide you with information on how we handle your personal data when you use our website. We handle your personal data because this is necessary to make certain functionalities of our website available and give you the best possible experience. Unless otherwise indicated, the legal basis for the handling of your personal data results from the fact that such handling is required to make available the functionalities of the Website requested by you (Art. 6(1)(b) General Data Protection Regulation).
1.1 Using our Website
1.1.1 Accessing our Website
When you visit our Website, your browser will transfer certain data to our web server. This is done for technical reasons so that we can make the information you request available. In particular, the following data are collected, briefly stored and used:
- IP address
- Date and time of access
- Time zone difference to Greenwich Mean Time (GMT)
- Content of request (specific site)
- Status of access/HTTP status code
- Transferred volume of data
- Website requesting access
- Browser, language settings, version of browser software operating system and surface
We will also store such data for a limited period of time so that we are able to initiate a tracking of personal data in the event of actual or attempted unauthorised access to our servers (Art. 6(1)(f) General Data Protection Regulation).
1.1.2 Setting of cookies
What are cookies?
Our website uses so-called “cookies”. Cookies are small text files that are stored in the memory of your terminal via your browser. They store certain information (for example your preferred language or site settings). Your browser may retransmit these to us when you revisit our website, depending on the lifespan of the cookie.
What cookies do we use?
We differentiate between two categories of cookies: (1) functional cookies which are necessary for the functionality of our website and (2) optional cookies. These are used for website analysis and marketing purposes. The following tables contain a detailed description of the optional cookies we use:
|Purpose and content||Lifespan|
|Website analysis with Google Analytics:
These cookies assign a randomly generated ID to your device. This enables us to recognise your device next time you visit. For details on website analysis please see the respective chapter below.
|WordPress login cookie:
These cookies assign a randomly generated ID to your device. This tracks user session whilst logged in.
|Duration of session|
|Cookie bar cookie:
These optional cookies assign a randomly generated ID to your device. This indicates user response to the cookie bar notifications. These cookies will not be placed unless the user agree to the popup message.
Subject to your consent
We only use optional cookies if we have obtained your prior consent (Art. 6(1)(a) General Data Protection Regulation). When you visit our website for the first time, a banner will appear asking you to give us your consent to the setting of optional cookies. If you consent, we will place a cookie on your computer and the banner will not appear again as long as the cookie is active. After expiration of the cookie’s lifespan, or if you actively delete the cookie, the banner will reappear the next time you visit our website and will again ask you for your consent.
How to prevent the setting of cookies
This may, however, lead to a restriction of the functions or have adverse effects on the user-friendliness of our Website.
1.1.3 Website Analysis
Google Tag Manager
This Website uses GTM (Google Tag Manager) to initiate and control the connection to Google Analytics. It is used most of all to minimise administrative effort and to analyse reporting problems.
On our Website we use Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (hereinafter “Google”). Google will analyse your use of our website on our behalf. To this purpose we use, among others, the cookies described in more detail in the above table. The information collected by Google in connection with your use of our website (for example the referring URL, our webpages visited by you, your browser type, your language settings, your operating system, your screen resolution) will be transmitted to a server of Google in the USA, where it will be stored and analysed. The respective results will then be made available to us in anonymised form. Your usage data will not be connected to your full IP address during this process. We have activated on our Website the IP anonymising function offered by Google, which will delete the last 8 digits (type IPv4) or the last 80 bits (type IPv6) of your IP address. Moreover, Google is certified under the EU-US Privacy Shield, which ensures that an adequate level of data protection is maintained with respect to the processing of data by Google in the US.
You may revoke your consent to the use of web analysis at any time, either by downloading and installing the provided Google Browser Plugin or by amending your browser cookie settings. Both options will prevent the application of web analysis only as long as you use the browser on which you installed the plugin and do not delete the opt-out cookie.
By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
Use of tracking pixels on the website
Tracking pixels are small images on websites that are used for log file recording and log file analysis for statistical evaluation. When visiting a website, the tracking pixels write information to the cookie file in the user’s browser.
1.1.4 Use of contact and registration forms
You can contact us directly by using the contact forms available on our website. In particular, you may provide us with the following information:
- Name, surname and title
- Address (Street, Postal Code, City)
- Employment information (position, speciality, professional ID number, practice name, NHS trust)
- Contact data (e.g. e-mail address, phone number)
We collect, process and use the information you provide via the registration and contact forms exclusively for the processing of your specific request.
1.1.5 External services or content on our Website
We include third-party services and/or content on our website. When you use such third-party services or when third-party content is displayed, communication data are exchanged between you and the respective provider for technical reasons.
The respective provider of the services or content may also process your data for their own additional purposes. To the best of our knowledge, we have configured the services and content of providers known to process data for own purposes in such a way that either any communication for other purposes than to present their services or content on our website is blocked, or communication only takes place once you have actively opted to use the respective service. However, since we have no control over data collected and processed by third parties, we are not in a position to provide binding information regarding the scope and purpose of such processing of your data.
For further information regarding the scope and purpose of such collection and processing of your data, please consult the privacy statements of the providers whose services and/or content we include and who are responsible for the protection of your data in this context.
1.1.6 Information on side effects and quality complaints
We understand you may wish to report side effects or make a quality complaint. You can do this as follows:
Reporting by Healthcare Professionals
Adverse events should be reported. Reporting forms and information can be found at www.mhra.gov.uk/yellowcard. Adverse events should also be reported to Grünenthal Ltd (telephone 0870 351 8960). Quality complaints and medical device adverse incidents should also be reported.
Reporting of side effects by patients/carers, members of the public
If you get any side effects, talk to your doctor pharmacist or nurse. This includes any possible side effects not listed in the package leaflet. You can also report side effects directly via the Yellow Card Scheme at www.mhra.gov.uk/yellowcard. By reporting side effects you can help provide more information on the safety of this medicine. Quality complaints and medical device adverse incidents should also be reported.
If you report side effects or other issues regarding the safeness or quality of our products directly to Grünenthal Ltd, we will be legally bound to deal with your communication and may have to contact you for clarification purposes. Subsequently, we may have to notify the health authorities. For patients and members of the public, your information will be forwarded in pseudonymised form, that means no information by which you may be directly identified will be passed on. We may also have to forward this information to our group companies and cooperation partners, to the extent these are likewise obliged to notify their respective health authorities.
1.2 Transfer of data for commissioned processing
We will to some extent use specialised service contractors for the processing of your data. We carefully select and regularly monitor such service contractors. They will only process personal data upon our instruction and strictly in accordance with our directives, based on respective data processor agreements.
1.3 Processing of data outside the EU/the EEA
Your data will partly be processed in countries outside the European Union (“EU”) or the European Economic Area (“EEA”). The respective countries may have a lower data protection level than European countries. In such cases, we will ensure that a sufficient level of protection is provided for your data, e.g. by concluding specific agreements with our contractual partners , or we will ask for your explicit consent to such processing.
2. Information regarding your rights
You have the following rights according to applicable data privacy laws:
- right of information about your personal data stored by us;
- right to request the correction, deletion (provided that we are not legally obliged to keep the data) or restricted processing of your personal data;
- right to object to a processing for reasons of our own legitimate interest, public interest or profiling, unless we are able to prove that compelling, warranted reasons overruling your interests, rights and freedom exist, or that such processing is done for purposes of the assertion, exercise or defence of legal claims;
- right to data portability;
- right to file a complaint with a data protection authority.
You may revoke your consent to the collection, processing and use of your personal data at any time with future effect. For further information please refer to the chapters above describing the processing of data based on your consent.
If you wish to exercise your rights, please address your request on the contact form on the website or to our company data protection officer whose contact details are given below.
3. Contact details
If you have any questions regarding our data privacy you can get in touch with our company data protection team at the following address: firstname.lastname@example.org
Requests and complaints
If, as the data subject, you do not agree with the way in which Grünenthal Ltd. or persons at Grünenthal Ltd. process your data and wish to inform the data protection officer directly, please use the following email address: email@example.com
You can only reach our data protection officer at this email address. The data protection officer is obliged to keep your identity confidential. Should it come to the conclusion that your identity could be inferred in the course of clarifying a complaint, the data protection officer will point this out to you in advance and, if necessary, ask you to release him from his obligation to secrecy.
Data Protection Supervisory Authority
You may address questions and complaints also to the UK’s independent data protection authority:
Information Commissioner’s Office
Wycliffe House, Water Lane
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
Alternatively the authority can be emailed through their website https://ico.org.uk/
4. Amendment of Privacy Statement
We may update our Data Privacy Statement from time to time and we will publish these updates on our website. They become effective upon publication so we recommend you regularly visit the site to keep yourself informed on possible amendments.
This Data Privacy Statement was last updated on 08/February/2019.