Aservo® EquiHaler®

Data Protection/ Privacy Policy

1. General

Boehringer Ingelheim Animal Health UK Limited ("We" or “us”) are committed to protecting and respecting your privacy.

This Privacy Policy (together with our Terms of Use as set out at Equihaler Digital Leaflet and any other documents referred to in it) applies to your use of:

The Aservo^® Equihaler^® website (“Website” or “Site”).
Any of the services accessible through the Site.

In this Privacy Policy, the terms “personal data”, “processing”, “data controller” and “data processor” shall have the meaning ascribed to them in the General Data Protection Regulation ((EU) 2016/679).

This Privacy Policy sets out the basis on which any personal data We collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding personal data and how We will treat it. By providing us with information about you and/or by continuing to use our Website, you are accepting the practices described in this Privacy Policy.

This Privacy Policy applies to (including, but not limited to) the sharing by you of information; for example, information relating to a product, service, business or brand via our Site, to a third party or parties, including (but not limited to) a friend, acquaintance or contact.

Our Site is not intended for minors under 18 years of age. No one under the age of 18 may provide personal data to or through the Website. We do not knowingly collect personal data from minors under 18. If you are under 18, please do not create an account or send us any information about you.

The data controller is Boehringer Ingelheim Animal Health UK Limited, of Ellesfield Avenue, Bracknell, Berkshire RG12 8YS (Company Number 01961886).

2. Personal data we may collect from you

We may collect and process the following personal data about you:

Personal data you give us. You may give us information about you by filling in forms on our Site or registering on our Site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our Site, subscribe to receiving emails from us, subscribe to receive information from us, search for a product, participate in discussion boards or other social media functions on our Site, enter a competition, promotion or survey, and when you report a problem with our Site. The information you give us may include your name, address, e-mail address and phone number.

Personal data we collect about you. With regard to each of your visits to our Site We may automatically collect the following information:

Additional information, if you provide additional information (such as information regarding your professional standing) in order to access restricted information, then we will collect that information.
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
Information that you provide to us for the purpose of registering with us and allowing us to send you email notifications and/or promotional information.
Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Personal data we receive from other sources. We may receive information about you if you use any of the other websites We operate or the other services We provide. (In this case we will have informed you when We collected that data that it may be shared internally and combined with data collected on this Site.) We are also working closely with third parties (including, for example, business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers, search information providers) and may receive personal data about you from them. We may also collect personal data regarding you from someone you duly authorise to act on your behalf.

From time to time you may be able to visit the Website and deal with us anonymously or by pseudonym. However, please be aware that if you do not provide us with certain information that We require, We may not be able to provide you with particular services that you seek.

Personal Data collected for Adverse Event Reporting. We are 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 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 or her contact details to Boehringer Ingelheim or authorities, “Privacy” is entered in reporter's names field.

3. Cookies

We use cookies and other similar technologies such as pixel tags, embeddable scripts and local storage. Cookies are small text files that may be places on your computer or other device by websites when you visit them. Cookies enable us to recognise your device on a subsequent visit by that device to our Website and allow us to deliver a more personalised experience by providing information to us. Cookies are essential for some website functions and these functions will not work in the absence of those cookies. You can use the browser privacy functions to clear the cookies already on your device or to block cookies in the future by altering the browser privacy settings. However, please note that this may cause some of the functionality of the Website not to work correctly. If you continue to use our Website you accept the use of cookies. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

4. Uses made of the personal data

We use information held about you in the following ways:

Purposes for processing. We may process personal data regarding you for a number of purposes (including but not limited to): staff administration, advertising; marketing and public relations; accounts and records; consultancy and advisory services; research; trading/sharing in personal information; crime prevention; health administration and services; administration of membership records; information and databank administration; education and journalism; media collecting, monitoring, researching, and evaluating information from healthcare providers and patients on the adverse effects of medicines.

Personal data you give to us. We will use this information:

to provide you with the information, products and services that you request from us;
to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
to provide you, or permit selected third parties to provide you, with information about products and services we feel may interest you. Where we permit selected third parties to use personal data regarding you, we (or they) will contact you by electronic means only if you have consented to this;
to notify you about changes to our website;
to ensure that content from our Site is presented in the most effective manner for you and for your computer.

Personal data We collect about you. We will use this information:

to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our Site safe and secure;
to measure or understand the effectiveness of advertising We serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our Site about products or services that may interest you or them.

Personal data We receive from other sources. We may combine this information with information you give to us and information We collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive). This may include information from face to face interactions such as sales meetings, conferences, or from interactions We may have with you electronically, for example, through sending emails or making telephone calls to you.

5. Marketing

We will only send you marketing material if you consent.

When We send you marketing material, We may monitor whether or not you open and/or click on the material that We send you.

If you have consented to receive marketing material from us, you have the right at any time to ask us not to process personal data relating to you for marketing purposes. If you wish to exercise this right, please contact us.

6. Social Media and Digital Content Policy

We collect information from websites, including social networking sites such as Twitter and LinkedIn, concerning engagement, demographics and posts about us and our products. This data includes but is not limited to: click through rates, engagement behaviours and statistics, such as likes, shares, comments and demographic information, such as your age and gender. For posts that are directed at Boehringer Ingelheim owned channels (e.g. Twitter mentions, or posts to the LinkedIn page) the name of the individual posting is likely to be collected as we monitor for posts. However, this would not be used unless it was an Adverse Event, in which case it would be reported through official Adverse Events procedures.

We also collect data from reputable third-party social listening platforms. The data we obtain from such providers has been collected through publicly available digital content libraries and social media platforms, such as Twitter, news, blogs, and other public online data sources. Where our providers hold such data, this data may include data such as, but not limited to: regional location and personal hobbies and interests and any other information you make publicly available through the site, for example, your name and contact details. These platforms (in the case of Boehringer Ingelheim Limited are currently Twitter and LinkedIn) will have their own data and privacy policies concerning the data they collect and make publicly available. These can be consulted by any member of the public.

Uses made of this personal data. We may use your personal data obtained through the aforementioned sources for the following reasons:

We use your voluntary data provided through social media platforms, such as Twitter and LinkedIn, to enable us to respond to queries, complaints or comments that you have and to make sure that these are appropriately dealt with, for example when you comment on our social media channel, including published posts. If voluntary data you provide includes any special categories of personal data (such as information about your health, race or religion), you must make sure before you provide this that you are happy for us to use that voluntary data for the purposes set out in this Privacy Policy.
We also use collected data to help us monitor, analyse and improve our digital communications. We use this data to help us understand which content is most interesting and helpful for our users. This helps us to make sure that We are providing you with the best possible content.
We also use this data for marketing and advertising purposes. This can include sending you advertisements based around your digital behaviour and interests.
We use and combine the data that we hold about you in order to build up a picture of you and the types of content which might be of interest to you (your profile). We may use your profile to provide you with a more customised and tailored experience across social networks and the wider web, and to inform the advertising that is displayed to you. This makes sure that you see advertisements that are relevant and interesting to you.
We capture copies of social media posts to archive data that may be of historical or statistical value and to use this data in the future for internal purposes or to allow third parties access to this data for research and review purposes. For example, if We have shared content on LinkedIn concerning recruitment opportunities, and you comment on this post with your thoughts, We may archive this data if We believe it is useful for our records. Occasionally this may include copies of voluntary data that you have provided on public areas of the platform. We will only ever capture personal data that has already been made publicly available in this way and for these purposes. Where possible, when these copies are archived We anonymise or remove personal data.

7. Disclosure of personal data

We may disclose personal data to third parties in certain circumstances including (but not limited to) the following:

to fulfil the purposes for which you provided information regarding you;
our professional advisers, including lawyers, accountants, tax advisors and auditors;
regulatory or government bodies including to monitor the effect of medicines or medical devices and also to resolve complaints or disputes both internally and externally or to comply with any investigation of those bodies;
in the event that We sell or buy any business or assets, in which case We will disclose personal data regarding you to the prospective seller or buyer of such business or assets;
if We are under a duty to disclose or share personal data regarding you in order to comply with any legal or regulatory obligation or request, or in order to enforce or apply our terms of use or to protect the rights, property, or safety of Boehringer Ingelheim Animal Health UK Limited, our customers, or others;
third parties to whom We outsource services such as data hosting, analytics, marketing and Site development and maintenance;
to business partners, suppliers and sub-contractors for the performance of any services We may provide for you or any interactions We may have with you as part of your use of the website, including the running and hosting of the website; and/or
to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 and/or
for any other purposes that you would reasonably expect;

Before We disclose any personal data to a third party, We take steps to ensure that the third party will protect personal data regarding you in accordance with applicable privacy laws and in a manner consistent with this Privacy Policy. Third parties are required to restrict their use of this information to the purpose for which the information was provided.

We may transfer personal data regarding you to overseas recipients for business purposes and operational, support and continuity purposes, for example, when We use IT service providers or data storage services which are located overseas. Countries where these recipients are located may have data protection laws which differ to the data protection laws in your country of residence.

We will disclose personal data regarding you to third parties in order to :

enforce the Terms of Use (Equihaler Digital Leaflet), and other agreements or to investigate potential breaches; or
protect the rights, property or safety of Boehringer Ingelheim Animal Health UK Limited, our customers, or others. This includes exchanging data with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Portions of the Site may involve linking to or using web sites or services belonging to third parties. We have no control over third-party sites or services, and all use of third-party sites or services is at your own risk. We cannot accept responsibility for the privacy policies of any such sites. We are not responsible for content or availability by means of such sites or services. We do not endorse any products offered by third parties and We urge you to exercise caution in using third-party sites or services.

8. Where We store personal data

All information you provide to us is stored on our secure servers, or those secure servers of our third-party service providers. The safety and security of personal data regarding you also depends on you. Where We have given you (or where you have chosen) a password that enables you to access certain parts of the Sites, you are responsible for keeping this password confidential. We ask that you do not share a password with anyone.

Please ensure when sharing information via or from the Site (for example, on social networks or other forums), you do not submit any personal data that you do not want to be seen, collected or used by other users.

The security of personal data regarding you is a high priority. We take such steps as are reasonable to securely store personal data regarding you so that it is protected from unauthorised use or access, misuse, loss, modification or unauthorised disclosure. This includes both physical and electronic security measures. Examples include the use of passwords, locked storage cabinets and secured storage rooms. Other features include:

storing information on secured networks consistent with industry standards, which are only accessible by those employees who have special access rights to such systems;
using industry-standard encryption technologies when transferring or receiving personal data, such as SSL technology;
restrictions are placed on the electronic transfer of files; and
our IT networks undergo necessary vulnerability testing to continually identify and remediate potential opportunities for unauthorised data access.

We takes steps to destroy or de-identify personal data when the information is no longer required for any purpose for which it may be used or disclosed by us and We are no longer required by law to retain the information.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the provision of support services or for sending you information you have consented to via our website. By submitting personal data regarding you, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that personal data regarding you is treated securely and in accordance with this Privacy Policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect personal data regarding you, or procure that personal data regarding you is secured, We cannot guarantee the security of such data transmitted to our Site; any transmission is at your own risk. Once We have received personal data regarding you, We use strict procedures and security features to try to prevent unauthorised access.

9. Your Rights:

Data protection laws give you the right to access personal data held relating to you. To protect your privacy, we may take steps to verify your identity before taking any action in response to any request. Any access request may be subject to a small fee to meet our costs in providing you with details of the personal data that we hold relating to you.

We also want to make sure that any personal data relating to you that we hold is accurate and up to date. You may ask us to correct or remove any personal data you think is inaccurate.

You also have the right, in certain circumstances, to:

the erasure of personal data relating to you that We hold;
the restriction of processing of personal data relating to you that We hold; and
object to our processing of personal data relating to you that We hold.

If you would like to exercise any of these rights or if you have any questions about our processing of personal data relating to you, please contact us.

We will respect and provide you with all rights in relation to personal data relating to you that We hold, and to which you are entitled, under applicable law.

If you have a concern about the way We are collecting or using personal data relating to you, We request that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/.

10. Changes to our Privacy Policy

We review and amend this Privacy Policy from time to time. Any changes We may make to this Privacy Policy in the future will be posted on the Site and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Site.

11. Contact

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed FAO the Data Protection Officer by contacting us.

Last Reviewed: October 2019

Cookie Policy

Our websites use cookies to distinguish you from other users of our website.

A cookie is a small piece of data containing a unique reference which is written to any web-enabled user device (e.g. a computer). Cookies are not viruses - they are plain text items and are not compiled code - so they cannot be executed on, or affect the operation of, the web-enabled device. For more information on cookies go to https://ico.org.uk/your-data-matters/online/cookies/. Boehringer only uses cookies to provide and enhance our services to users.

Any computer, laptop, PDA, mobile, smart phone, tablet and/or other device running a web browser capable of connecting you to the website may be a web-enabled device.

Adobe Analytics (Omniture)

We also use cookies from Adobe Analytics, a web analytics service provided by Adobe Systems Software Ireland Limited ("Adobe"). Adobe Analytics uses cookies on behalf of Boehringer Ingelheim to analyze all traffic and usage patterns. The IP address collected by the cookies is made anonymous before it is geolocated. In addition, it is replaced by a generic IP address. Adobe will not associate your IP address with other information held by Adobe. You can prevent Adobe from collecting and using information (cookies and IP address) by using your options at http://www.adobe.com/privacy/opt-out.html As data can be transferred to the USA in exceptional cases, Adobe is self-certified itself to the EU-U.S. Privacy Shield.

The analyses help us to improve our services. The legal basis is Article 6 (1) f) GDPR.