Social Media Data Privacy and Cookies Statement
On this page we provide information about how Boehringer Ingelheim International GmbH (hereafter "Boehringer Ingelheim", "we", "us") handles personal data in connection with social media channels such as Facebook, Instagram, LinkedIn, Messenger, Pinterest, Twitter, YouTube and Xing (“Social Media”) and when emails are sent to hello@boehringer-ingelheim.com or press@boehringer-ingelheim.com.
You can find more information about us in our imprint.
We provide information about our handling of personal data in connection with these channels (1. General Privacy Notice) and when and how adverse events are reported (2. Privacy Notice for Pharmacovigilance).
For the data processing done by the Social Media platform owner, please check the data privacy terms of the respective Social Media platform.
1. General Privacy Notice
This data privacy statement explains how we process which personal data of you for which purposes. In any event, collection and processing of personal data will only take place in accordance to the applicable laws (i.e. the General Data Protection Regulation, "GDPR").
1.1 Contact Options and Data Processing
Via Social Media you have the opportunity to get in contact with us. We are monitoring and processing your data, such as:
- any activity on our respective Social Media channel, such as (but not limited to) guest wall posts, comments, (negative) likes, etc.;
- any direct message to our respective Social Media account;
- any @mention or tagging of our respective Social Media account;
- any email sent to hello@boehringer-ingelheim.com;
- any message sent to us on Messenger platforms.
We process your data in order to provide you with the agreed or requested services on the respective Social Media channel.
The legal basis for these kinds of data processing is Article 6 (1) b) GDPR.
1.2 Log Data and Technical Cookies
When using the respective Social Media channel, certain data, including data sent by the browser (e.g., IP address, cookies, previous website, time and date, displayed contents) are temporarily stored by the respective Social Media platform owner. In general, we are not using additional cookies and are not creating additional Log data on our respective Social Media channel.
We use the data that the respective Social Media platform owner is providing to enable you to use our Social Media services. When subscribing to news from us for example on a messenger platform, we store the data necessary to do so, e.g. telephone number, account name or other profile data that you have set to “public” according to your messenger settings.
If necessary we use your data to review and assert our and/or third party rights in the event of especially violations of legal regulations, our Privacy Statement and the rights of third parties. The legal basis is Article 6 (1) f) GDPR.
Exeption: Facebook Pixel
Our website utilizes the Facebook Pixel, the conversion tracking pixel service of Facebook Inc. (“Facebook”). When you visit our website and take an action (e.g. downloading a document), the Facebook pixel is triggered and reports this action. This way we can use advertising features like audiences, conversions, targeting and optimization as well as Facebook Analytics data.
This means, when visiting Facebook or a third party website, you receive information customized to your interests (“Facebook Ads”). It is in our interest to provide you with information based on your interests so that our website and our provided information stays of interest for you.
We have no influence on the specific direct use or additional use of your data by Facebook. We inform you to the best of our knowledge:
Through the use of Facebook Custom Audiences Facebook receives information that you visited our website, or you clicked on one of our advertised posts. If you are registered at one of Facebook’s services, Facebook would be enabled to connect your visit to your account. Even if you are not registered or logged in at Facebook, it might be possible for Facebook to track your IP-address and/or additional identification data.
To deactivate Facebook Custom Audiences on our website please click here or if you are logged in to Facebook as a user click here. Please note that your opt-out is limited to the respective browser you are using and the visited domain of the website.
The legal basis for our use of your data is Art. 6 (1) f) GDPR.
For additional information to the data processing of Facebook please got to https://www.facebook.com/about/privacy.
1.3 Analytics
We make use of analytics tools to further inform and improve our Social Media activities. To do so, we make use of data provided from the respective Social Media platform. We build analytics reports with the help of the Social Media platform analytics tools or with tools from third parties, who are using the data provided by the respective Social Media platform owner.
1.4 How We Secure Your Personal Data
We are committed to keeping your personal information, as far as we have it and use it, secure. We are taking all reasonable technical and organizational measures to protect your data from loss, misuse or alteration.
1.5 Data Transfer to Third Parties
We may share personal information with third parties.
For the data transfer to third parties done by the Social Media platform, please see the terms of use, especially the privacy terms of the respective Social Media platform
1.5.1 Reporting Obligations to Regulatory Authorities and Enforcement of Rights
As a pharmaceutical company, we are subject to specific regulations. Some of these laws require us to send your reports to regulators or other authorities worldwide (including countries that may have a different level of data protection than the EU). We only provide authorities with personal data if we are legally obliged to do so.
In order to protect our rights or the rights of third parties, we may also disclose data to rights holders, consultants and authorities in accordance with legal provisions.
1.5.2 Service Provider
We engage service providers to process your personal data for the purposes described in this data protection information. These service providers process the data only on our behalf, in accordance with our instructions and under our control in accordance with this data privacy declaration and the privacy terms of the Social Media platform.
1.5.3 Boehringer Ingelheim Companies
As part of a global group of companies, we might involve other Boehringer Ingelheim companies that support us in data processing as needed. These group companies process the data exclusively for the purposes stated in this data protection declaration.
1.5.4 Data Transfer to Recipients Outside the EU
Some of our third party service provider and/or Boehringer companies might process personal data outside the EU. In these cases, we ensure an adequate level of data protection to comply with European law (usually through EU standard contractual clauses published by the European Commission).
1.6 Deletion
We process your personal data for as long as necessary for the purpose of the processing, which mainly is the provision of our services requested by you. This means for example that we send you newsletters for as long as you did not withdraw your subscription. Your personal data will be deleted in a timely manner after we consider the service requested by you as completed/ fulfilled.
We will retain personal information for as long as necessary for the particular business purpose or purposes for which it was collected. If you revoke your consent, delete user accounts or object to data processing, we will delete the data collected in a timely manner.
In some cases we are obliged to keep data to comply with statutory retention periods (e.g. in the context of pharmacovigilance). In such a case, we will ensure that your data will only be used to comply with the retention obligations and not for other purposes.
1.7 Your Rights
1.7.1 Information Request
Upon your request, we will inform you which personal data we store about you and for which purposes. In justified cases, you may also request the deletion, correction or limitation of the processing of your personal data.
If you have provided personal data based on a contract or consent, you have the right to receive this data in a common and machine-readable format.
If your personal data is transferred to a country outside the EU, which does not provide appropriate protection, you can request a copy of the contract that implements the appropriate protection of personal data.
1.7.2 Objection Right
You may also object to the processing of your personal data for the transfer to authorities outside the EU described above unless the interests of Boehringer Ingelheim prevail.
If we use your personal data based on balance of interests, you can object to the use of your data. In this case, we will no longer use your data unless our interests prevail or we are legally required to continue the usage.
You can object to the use of your data for direct marketing purposes, e.g. the receipt of mailings, at any time without further consideration
1.7.3 Right to Withdraw
Where you provided consent for the use of your personal data, you can withdraw your consent at any time with future effect.
1.8 Contact
If you have any questions about our use of personal data, this data protection statement or in case you would like to exercise your rights, you can contact our data protection officer directly:
Boehringer Ingelheim International GmbH
– Data Protection Officer –
Binger Straße 173
D-55216 Ingelheim am Rhein
Germany
In case of questions or concerns you can also contact the competent data protection authority (especially where you live or where we are established).
The competent data protection authority for Boehringer Ingelheim International GmbH is: Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Rheinland-Pfalz, Hintere Bleiche 34, 55116 Mainz, poststelle@datenschutz.rlp.de.
1.9 Changes to this Privacy Statement
To keep this privacy statement up to date, we may make changes to it from time to time. This is to ensure that you are always aware of how we use your personal data. Applicable laws and regulations might as well require changes and we want to comply with applicable rules.
Therefore, we would like to encourage you to review this privacy notice periodically to be informed of how we use your personal information.
Data privacy statement as of: January 29th 2019.
2. Privacy Notice for Pharmacovigilance
2.1 Purpose of the Data Collection
In case you report adverse events or other pharmacovigilance relevant information to a Boehringer Ingelheim product Boehringer Ingelheim Pharma GmbH & Co KG, Binger Straße 173, 55216 Ingelheim am Rhein, is managing all pharmacovigilance related matters on behalf of the Boehringer Ingelheim International GmbH in the global pharmacovigilance database. We will use and share this data solely for pharmacovigilance purposes.
Pharmacovigilance is the detection, assessment, understanding and prevention of adverse effects or any other medicine-related problem.
2.2 Handling of the Report and Sharing with Boehringer Ingelheim Companies and Authorities
The Boehringer Ingelheim group of companies is obliged to report pharmacovigilance relevant information to health authorities worldwide (including to countries that may have another level of data protection compared to the EU).
The legal basis for this is Art. 6 (1) c), and for transfers outside EU Art. 6 (1) f) and Art. 49 (1) e) GDPR.
The reports will contain details about the incident but only limited personal data:
- For patients, the report will only contain, age, date of birth, year of birth, gender and initials as provided, but never the patient's name.
- For the reporting individuals, the report will include the name, profession (e.g. physician, pharmacist), initials or address, email and phone number as provided. The contact information is required to be able to follow-up with the reporter to gain high quality and complete information on adverse events. If the reporter does not wish to provide his contact details to the Boehringer Ingelheim group or authorities, “Privacy” is to be entered in reporter's names field.
Where your data is shared with other Boehringer Ingelheim companies, business partners or service providers outside of the EU, we will provide an adequate protection of personal data.
2.3 Retention period
As reports about adverse events are important for public health reasons, reports are stored for a minimum of 10 years after withdrawal of the product in the last country where the respective product is marketed.
Privacy Notice of Pharmacovigilance as of: January 29th 2019.