This Privacy Policy describes how LEO Pharma (“we” or “us”) processes your personal data when you register for one of our services on our website, use our website, or otherwise are in contact or interact with us. It concerns both the instance where LEO Pharma has obtained your personal data from you directly or from a third party.

This privacy notice ensures compliance with articles 12-14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

LEO Pharma nv sa, is the data controller for processing of the personal data we have received about you or that you have provided to us. You will find our contact information below.

If you have any questions about our processing of your personal data, you are always welcome to contact our Data Protection Officer. You can contact our Data Protection Officer in the following ways:

• By letter: LEO Pharma A/S, Industriparken 55, 2750 Denmark, c/o Data Protection Officer

Categories of personal data	Purposes	Legal basis	Legitimate interests	Retention
Information we may collect directly from you: Title and profession, full name, 1st line of surgery/hospital/pharmacy address and postcode, professional phone number, professional email address, details about your interaction with emails received from us, including i) whether you have opened such emails and at which time and date, ii) which links you’ve clicked on in the email, and iii) your IP-address. We use industry standard technologies including clear gifs to collect this data. Information we have collected from a third party: Unique Vendor ID, profession, title, full name, specialty and qualifications, and language.	i) To manage and improve your professional relationship with us, ii) to send you promotional content from LEO Pharma including educational information about disease and therapy areas, information about our products, information about events and services and/or iii) to process details about your interaction with emails received from us. This helps us share improved and more relevant content with you.	GDPR, art. 6(1)(f): Legitimate interests.	We process your personal data to promote and improve our services and products as well as to improve our handling of questions that you may have concerning our services and products. We use industry standard technologies, including artificial intelligence, to analyze your personal data to help us improve our professional relationship with you. We also process your personal data to ensure that your personal data is updated and correct.*	We store your personal data for 2 years after the latest contact or until the time where you may have objected to being registered by LEO Pharma for the mentioned purposes. We may keep your personal data longer if we have a legal basis for doing so.
When browsing our website, we may process the following personal data about you: Information about your computer and about your visits to and use of our website, including your IP address, browser type, geographical location, length of visit and number of page views. Such information will be collected via cookies.	When you use our website, cookies are used to collect personal data about your behavior for the purpose of optimizing our website and our services, generating statistics and for marketing. LEO Pharma may also use web analysis tools, such as Google Analytics provided by Google, and LEO Pharma and the provider of such third-party cookies act as joint data controllers. You can read more about this and locate a link to the privacy policies of such third-party providers in the cookie overview, which can be accessed through LEO Pharma’s Cookie Policy.	For profiling and tracking of your use of our website for marketing-related purposes will be based on your consent, GDPR art. 6(1)(a). and for other purposes GDPR art. 6(1)(f).	Pursuit of our legitimate interests in providing you with an interesting website that works optimally.	Personal data will be retained as long as necessary for providing you with the given service. The retention times for cookies depend on the type of cookie. You may read more about the retention times in the cookie overview in our Cookie Policy.
When a safety event is reported we may process the following personal data about you: Information on adverse events or other experiences Patient age and/or sex, date of birth, patient initial Results of tests and procedures relevant to the investigation of the patient. If applicable, date and reported cause of death. Information on the primary source(s) which allow the relevant affiliate or partner of LEO to request additional information as needed. Relevant medical history and concurrent conditions. The name of the medicinal product(s) and the active substance(s). Concomitant medicinal products, and past-medical drug therapy for the patient. If you are a reporter of adverse events/other experiences, we will only process the following personal data: Name, contact information, place of work and profession.	As a pharmaceutical company, LEO Pharma is under legal obligations to conduct pharmacovigilance by collecting information related to the safety of our products. We record and process the information to meet our pharmacovigilance obligations. These obligations allow marketing authorization holders and public authorities to learn from experiences to minimize the risks for patients.	Complying with a legal obligation to collect and report information related to pharmacovigilance and safety of our products GDPR art. 6(1)(c) and art. 9(2)(i).		Records and reports will be retained for a minimum of 10 years after the marketing authorization has ceased to exist pursuant to art. 12(2) in the EU Commission’s Implementing Regulation (EU) No 520/2012 on the performance of pharmacovigilance activities.

*At any time, you may object to our processing of your personal data, see section “8. Your Rights” below.

• Other LEO Pharma entities, including our ultimate holding company and its subsidiaries. A full overview over LEO Pharma entities can be found here: leo-pharma.com.

• We may share your personal data with IQVIA to ensure that our registered information is up to date and correct. You can read more about IQVIA and how they process personal data here (see “Privacy” near the bottom of the page): www.iqvia.com.

We may share your personal data with LEO Pharma entities located outside the European Economic Area (“EEA”).

An overview of all LEO Pharma entities is available at leo-pharma.com. Where your personal data is transferred outside the EEA, a data transfer agreement has been put in place. You may request a copy of such agreement by reaching out to our Data Protection Officer (see section 2 above).

We receive information about you from you from IQVIA, and/or publicly available sources. You can read more about IQVIA and how they process personal data here (see “Privacy” near the bottom of the page): www.iqvia.com.

Where our processing of your personal data is based on consent, you have the right to withdraw your consent at any time. You can do this by contacting us via the contact details disclosed in section 1 of this privacy policy.

If you choose to withdraw your consent, this will only apply from the time of such withdrawal. Consequently, it will not affect the lawfulness of our processing of your personal data up to the time of withdrawal.

You have several rights in relation to our processing of information about you pursuant to the General Data Protection Regulation. If you want to use your rights, please contact us.

You are entitled to gain access into the information that we are processing about you, as well as several additional information.

In certain instances, you have the right to delete information about you before the time of our ordinary general deletion.

In certain instances, you have the right to limited the processing of your personal information. If you are entitled to limited processing, in future, we may only process the information - except for storage - with your consent or for the purpose of determining, enforcing or defending legal claims, or for protecting a person or important social interests.

You may, in certain cases, have the right to object to our or legitimate processing of your personal information. You can also object to processing your information for direct marketing.

You may file a complaint about our processing of your personal data with the The Belgian Data Protection Authority (APD, Autorité de protection des données in French or GBA, Gegevensbeschermingsautoriteit in Dutch)

PRIVACY POLICY