Thank you for visiting www.guts4life.com.my/en. At Ferring, your privacy is important to us and we are committed to ensuring our data protection practices adhere to applicable European and local national data protection regulations.

This Privacy Notice will provide information as to how Ferring may collect, hold and process your personal data, and will describe the ways in which we will ensure your personal data is protected in accordance with the applicable regulations.

Guts4life (www.guts4life.com.my/en) is a website with information, support and inspiration for people concerned with Crohn’s disease and ulcerative colitis, conditions known as inflammatory bowel diseases (IBD).

This Privacy Notice applies only to this www.guts4life.com.my/en, therefore if you visit another website related to or recommended by Ferring, please consult the privacy notice on the respective website.

• What is personal data
• Who can be considered as a data subject
• How Ferring may use your personal data
• Cookies
• Retention of personal data
• Your rights
• How Ferring may share or transfer your personal data
• Links to other websites
• Security information
• Children
• Modifications
• How to contact us

What is personal data

Personal data means all information that relates to an identified or identifiable individual. This may include name, postal address, phone number, email address or any other information which may be used to identify you personally.

Who can be considered as a data subject

A data subject is any identified or identifiable individual about whom personal data is being processed. If you are not already a data subject of Ferring, there may be opportunities during your visit to this website whereby you provide personal data voluntarily, and therefore become a data subject. Ferring will only collect personal data from you during your visit to this website if and when you voluntarily provide it.

How Ferring may use your personal data

Ferring Sdn Bhd (“Ferring”), as the data user on behalf of affiliates of the Ferring Group will only process your personal data where there is a legal basis for doing so, and where it is necessary to carry out the purpose for which it was collected. The legal basis for processing your personal data will depend on the purpose for which the data was collected, as described below:

• Personal data may be processed if necessary for our legitimate interests in pursuing or fulfilling the following purposes:
  • to respond to you regarding an inquiry in the following categories: media; partnerships; development of business relationship; and any other general enquiries;
  • to process and respond to enquiries regarding data privacy and your privacy rights;
  • to process and assess reported cases for potential misconduct and/or violation of the Ferring Philosophy as well as other applicable Policies and SOPs;
  • to process and respond to a collaboration request; or
  • any other legitimate business purposes such as data analysis, audit, improving services and expanding our business activities.

  Ferring believes it necessary to process personal data for the purposes mentioned above based on legitimate interests to ensure that enquiries, requests, applications, and reports are timely processed in line with users’ expectations, policies and applicable laws, while at the same time adequately considering your rights. In addition, you can obtain more information about the legitimate interest balancing test that Ferring has performed.

• Personal data may be processed when necessary to comply with applicable laws and regulations such as:
  • to comply with laws within or outside your country of residence; or
  • to comply with a legal process or in response to a court order to produce certain personal data.
• Personal data may be collected and processed if necessary for vital interests and to comply with applicable safety obligations within the pharmaceutical sector such as:
  • to process a report regarding side effects, adverse drug reactions, adverse events or other safety information in relation to a Ferring drug/product. For information regarding the processing of special category data for this purpose please see the Pharmacovigilance Privacy Notice.
• Personal data may be collected and processed during our commercial and educational activities with you as a Healthcare Professional (HCP). Please refer to our Customer Relationship Management Privacy Notice regarding those activities.

Your personal data will only be used for the specific purpose for which is was collected and will not be used for any other purpose without notifying you in advance and/or obtaining the appropriate consent.

Cookies

When you visit this website, data about your use of the website may be collected using Google Analytics. This tracking technology uses cookies to collect aggregate data about website usage and activity, such as how many users visit the website and how often. This data may be shared with a third-party service provider in order to further improve our web services. No personal data can be accessed or collected via these cookies. The use of this type of technology shall comply with applicable data protection regulations and the current E-Privacy Regulation.

Retention of personal data

Ferring will follow the appropriate actions to ensure your personal data is retained only for the period required to fulfil the purposes outlined in this Privacy Notice. Ferring will only retain personal data for a longer period if required or permitted by law or by applicable regulations within the pharmaceutical industry.

Your rights

If and when we collect, hold and process your personal data, you will be afforded specific rights as a data subject. Ferring will give effect to these rights in accordance with the applicable European and local national data protection laws.

• Right to access and rectification: you have the right to request a copy of the information we hold about you, as well as the right to request the correction of the personal data we hold if it is inaccurate.
• Right to erasure and restriction of processing: you have the right to request the erasure of your personal data or for the restriction of processing your personal data. These rights are limited and will apply only in certain circumstances and where no exemptions apply.
• Right to data portability: you have the right to request a copy of the personal data we hold, as well as the right to request this data be transferred to another controller. This right is subject to certain conditions and may not apply, for example, if not permitted for reasons of public interest, or is not technically feasible.
• Right to object: you have the right to prevent processing likely to cause damage or distress; . If the data is processed for reasons of public interest, scientific or statistical purposes, you may still object and it will be our responsibility to demonstrate the legitimacy of processing the data.
• You have the right to withdraw your consent to the processing of personal data.
• You have the right to contact or lodge a complaint with your local data protection supervisory authority.

If you would like to submit a request in relation to a data subject right, please use the Data Subject Contact Form.

How Ferring may transfer or share your personal data

Your personal data may be transferred to other locations in which Ferring maintain facilities (including Ferring affiliates, contractors, partners or agents), where there are legitimate grounds for such a transfer, such as a valid business reason. Such locations may include countries outside the European Economic Area (EEA). Any such transfers will be safeguarded by internal international data transfer agreements, to ensure that your personal data is protected in accordance with the applicable European and national data protection laws.

Ferring may, in certain circumstances, share your personal data with third parties, such as vendors, contractors, partners or agents, if necessary to achieve the notified purposes, or if such third parties are assisting Ferring with the processing of the data. Ferring will only disclose personal data about you to a third party in the following circumstances:

• Relevant consent has been provided by you;
• where applicable, as a result of a request by you as a data subject;
• whereby there is a legal basis for the disclosure of the data and you have been provided with suitable notice of this;
• where we are required to do so under applicable laws or as a result of a court order; or
• where Ferring decides to sell, buy, merge or otherwise reorganize its business structure.

Ferring will never sell your information to a third party.

Links to other websites

This website may provide links to associated or external websites. Ferring is not responsible for the content, quality, data processing activities or data protection practices of any other website. If you visit another website, please consult the privacy notice and privacy settings of the respective website.

Security information

Ferring maintains a number of appropriate technical and organizational security measures to safeguard your personal data from unauthorized access, use, disclosure, accidental destruction or loss. For example, where appropriate, Ferring is committed to the encryption, anonymization or pseudonymization of personal data, and personal data will be stored securely in a designated system. Our internal policies and procedures are designed to prioritize and promote the protection of personal data.

While our data security measures are continually evaluated and updated, the security of data transferred via the internet from a computer or other device cannot be guaranteed and you are encouraged to take steps to protect yourself online and against unauthorized use of your passwords, and mobile devices, as well as installing the appropriate firewall, anti-virus and anti-spyware protections for your computer.

A non-exhaustive list of possible data incidents may include,

• a lost/stolen laptop;
• an external hacker;
• an email containing personal data sent in error;
• information lost in transit; or
• documents left in unsecured location

If you suspect any security compromise or detect vulnerabilities, it is essential to report these data incidents immediately by using the Data Subject Contact Form.

Children

Ferring is committed to protecting the privacy of children. Where personal data relates to a data subject who is under the age of 18 (or less if provided for by the applicable national law), consent shall be required from their legal representative. Ferring shall make all available and reasonable efforts to verify that the necessary consent has been obtained in such cases.

Modifications

Any changes to this Privacy Notice will be communicated at this location. We recommend you consult our Privacy Notice when revisiting our website to review any changes and to keep informed about our ongoing commitment to respecting the right to privacy and to providing the highest possible level of data protection.

Contact information

(i)If you wish to opt-out or if you have any questions or comments regarding this Privacy Notice, please contact Ferring Sdn Bhd at the following address or at “my_enquiries@ferring.com”

Ferring Sdn Bhd
21-6, Block B, Jaya One,
No, 72-A, Jln Profesor Diraja Ungku Aziz,
46200 Petaling Jaya, Selangor

(ii)In case you wish to:

• Report a data incident or suspected personal data breach;
• Submit a request to exercise your rights as a data subject; or
• Contact the Global Data Protection Officer with a general enquiry,