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Privacy Policy

Our commitment to privacy

The Santen Eyecare Education (“SEE”) Portal available at www.seesanten.com  (the “SEE Portal”, “website” or “service”) is operated by Santen UK Limited (Santen UK Limited, Address: Salisbury Hall, St Albans, AL2 1BU, UK, email: en*********@sa****.com, URL: https://www.santen.uk/) (“Santen”, “we”, “our”).

The SEE Portal is managed, maintained and technically supported by Outlook Creative (https://outlookcreative.uk/), a UK-based service provider, acting for and on behalf of Santen as data processor.   

The SEE Portal is intended for Healthcare Professionals only (“you”, “your” or “users”); the SEE Portal is a medical education online platform dedicated to support your professional development about ophthalmology and tailored to your learning preferences, giving you access to articles, videos on demand and details of upcoming events, as well as information and materials on Santen products and services, as further described below.

At Santen, we recognize the importance of, and are fully committed to protecting the privacy of personal data related to all individuals with whom we interact. This Policy is designed to assist you in making informed decisions when using our website or interacting with us.

You are recommended to read carefully this Policy before disclosing any personal data and/or filling in any electronic form posted on this website. By visiting our website or by providing us your personal data, you agree and consent to the collection, use and disclosure of your personal information as outlined in this Policy.

Scope of this policy

This Policy is specifically intended for healthcare professionals interested in using the SEE Portal to access medical education resources relevant to eye disease.

Personal data we collect

When you use the SEE Portal, we may collect and process the following personal data:

(a) Personal Data directly provided by you and processed by Santen and its data processor, Outlook Creative, on the SEE Portal:

  • Identification information and business contact details such as name, professional registration number, OneKey ID, business address, business email address and business phone number;
  • Professional data, such as your professional registration number, place of work, job role and specialisation;
  • User credentials, such as your OneKey user id and OneKey verification status;
  • Additional data you provide when you subscribe to SEE portal such as your communication preferences, language preference, areas of interest, your seminar, congress, webinar and similar registrations (including whether you accept or decline an invitation), other information you may add in the platform (such as personal notes, messages, answers you provide to registration questions, and your feedback/star review on the content we provide); activities/engagement with Santen (such as meetings with Santen representatives, attendance at meetings sponsored by Santen); and samples and promotional items provided;
  • Other information such as communications and queries you make to Santen.

(b) Personal Data collected and processed by IQVIA/OneKey Web Authentication Service:

  • Identification information and contact details such as name, title, date of birth, email address and phone number;
  • Professional data, such as your profession, professional registration number, your organization/institution you are belonging to and your business address;
  • User credentials, such as your username and password;

(c) Personal Data collected automatically Personal data related to you may be also collected automatically by your use of our website or whenever you choose to disclose it by updating your User Profile information, completing our Contact us online form or whenever you choose to send us directly an email at the designated email addresses.

Such data, indirectly collected, include but is not limited to the following:

  • Digital usage data generated automatically from your use of our SEE portal or from the delivery/use of services and/or content from the SEE portal, such as login user credentials, time and date of login, IP address, your browser type and version, time zone setting, content request, status of access/Http status code, transferred volume of data, website requesting access, time period of user’s staying on a single page, the internal path analysis and/or other parameters regarding the user’s operating system and computer environment, browser plug-in types and versions, operating system and platform and other data transmitted via Cookies, web beacons (also known as “tracking pixels”, which are typically used, for example, to count the number of visitors to the website, to monitor how users navigate the website and to count content views), embedded scripts, location-identifying technologies, device recognition technologies, and other tracking technologies (“Tracking Technologies”). This data is collected and used in most cases in an aggregated and not immediately identifiable manner, such as for security management purposes, to ascertain responsibility in case of possible crimes against the site (e.g. cyberattacks, DDoS attacks) or upon public authorities’ request. Subject to the user’s consent, this data can be collected at an identifiable user/customer level to personalize the user’s experience, as further explained in our Cookies Policy.
  • User activity tracking data: In addition, we will collect certain types of activity tracking data, which includes data that reveals how you interact with the SEE portal and applications as well as with our electronic communications (e.g. via email, SMS, or other digital apps) and advertisements; such data will be linked to your educational – professional preferences such as what presentations, course modules and other content in the platform that you open and finish, as well as the amount of time you spend actively working on a presentations, course modules, seminars or the like, group and other invitations that we send you. We collect this data to gain insights on which kinds of activity and content are most frequently accessed and used by our users; such data collection enables Santen to review and evaluate the performance of the digital media we make available and the relevance of the content we provide to our users and allows us to adjust our sending habits and our digital communication campaigns to best suit the needs of the intended recipient and/or audience as well as to optimize the relevant content leading to a tailored user/customer experience. Santen may collect such data in an aggregated and not immediately identifiable manner, or at an identifiable user/customer level, subject to the user’s/customer’s consent.

Purpose of processing personal data

Santen will collect, store and otherwise process your personal data to provide the SEE Portal services to you or for purposes permitted by applicable laws, including the UK Data Protection Act 2018 (DPA 2018), as amended and in force, and on the terms set forth in this Policy. By registering for and using the SEE Portal you give your express permission to Santen to process your personal data for the purpose of delivering the SEE Portal services to you and for other compatible purposes as further described below:

  • For the establishment, management and organization of tailor-made high-quality eye disease medical education in accordance with the specific educational needs of each particular healthcare professional/ user.
  • To manage our relationship, interactions and communications with you: for example, to respond to your questions and comments or inquiries, to invite you to events, webinars and other learning modules organized or sponsored by Santen and/or third parties.
  • To managing your preferences: for example, providing you with recommendations on training modules and events on your areas of interest.
  • Marketing communications: to provide you with information relating to Santen product and services and inform you about other promotional activities in accordance with applicable laws. Such uses might include event management, provision of information and services that you have requested (such as information on Santen products), reports of healthcare professional visits and tailoring the seminar invitations we send you based on your interests. Please also note that we may use the personal information for the SEE Portal to send you from time-to-time email and other messages, e.g., in order to inform you of new group messages, new features, to remind you of seminar sign-ups and similar.
  • Business relationship with Santen: Santen may also use your personal information for the development, tracking and profiling of scientific and medical activities and initiatives in which you are involved with Santen’s Medical Department. These may include clinical trials, medical education, scientific advisory boards and exchange of scientific information.
  • For collaboration and research purposes: for example, to enable Santen to make more informed and objective decisions when identifying, engaging with health care professionals and key opinion leaders and managing the collaboration relationship with health care professionals.
  • Website functions: We will use your data to monitor the proper functioning of the platform, how it is used and for the purposes of developing it to ensure that content from our website is presented in the most effective manner for you and for your device.
  • Inviting you to participate in (online) surveys to obtain customer insights on our products and services and to identify Santen’s market position in the healthcare sector in the area of Ophthalmology.
  • To optimize our marketing campaigns and provide our users and customers a user experience, tailored to their needs and preferences.

Santen will process personal data for further purposes, where lawful to do so (such as for scientific or market research as well as for archiving or statistical purposes) or when legally obliged to do so (such as to comply with our safety reporting obligations). We retain your personal information as long as it is necessary for the aforementioned purposes or as required by applicable laws. When such requirements no longer exist, your personal information will be deleted or rendered completely anonymous.

Legal basis of processing

Santen processes personal data based on one or more of the following conditions:

  • Where the processing is necessary to provide you with the requested services offered through the SEE portal;
  • Where you have provided your consent, for example to handle and respond to a communication or a query you have submitted to Santen via the Contact Us form or for the deployment of optional cookies such as functional or performance/analytics cookies or to send you email push notifications or other email news and updates at your request; in such cases, your consent can be withdrawn at any time and without giving any reason;
  • Where the processing is necessary to ensure Santen’s compliance with a legal obligation e.g. for example when you report an adverse event to us;
  • Where the processing is in Santen’s legitimate interest, for example where such processing is strictly necessary for the technical operation of the website or for the maintenance of our current or future business relationship with you.

Redirect to other web sites

From the SEE Portal, you can connect through special links to other websites of third parties to access content that has been created or endorsed by Santen. Santen assumes no responsibility regarding the processing activities of personal data or any activity by or content on third-party sites to which our website provides links. We encourage you to read and be aware of the privacy policy, and all other policies, of each site you visit. Remember, the statements in this Policy apply solely to information collected by Santen.

Disclosure of personal data

Personal data are not disseminated to unspecified recipients. Santen discloses your personal data to third party recipients on a need-to-know basis where this is reasonably permitted to pursue its legitimate business aims and as required by applicable law (i.e disclosure of your personal data to IT and web hosting service providers).

For more information on Santen’s privacy practices, how we handle your personal data and the measures we take in order to disclose it lawfully and safely internally and externally with our affiliates, service providers and partners, please read our Santen Privacy Policy available on our corporate website here https://www.santen.uk/data-privacy.

Automated decision making

Santen may combine any personal data you provide or any other information and insights automatically collected via the SEE Portal or via other digital media and online resources as well as information provided to us by third parties, to create a profile of our customers and business partners, to enable Santen to better manage our customer or business relationship with you; in particular, to facilitate Santen’s decision making with respect to the various medical and/or scientific engagements and collaborations with the healthcare community; to optimize our digital media medical or scientific activities and to better understand the relevance of the content provided to our users/customers and partners; to allow Santen to offer our users/customers an experience tailored to their needs and preferences.  

Santen will not make any automated decisions about you that would affect your legal rights or similarly affect you as an individual or negatively affect your business or customer relationship with Santen.

You can always raise any concerns you may have in relation to our decision-making and processing at any time by contacting us at pr**********@sa****.com.

Santen Email News & Updates

Subject to your express permission, Santen UK Limited and its affiliates (collectively “Santen”) would like to process and further use any personal information you provide directly to Santen during your user registration to the SEE portal, which forms part of your user profile (user account), including any identified preferences, as well as any information relevant to your use of the SEE portal, indirectly collected via Cookies and other tracking technologies, to send you electronic (email) communications on medical education, product information and other promotional activities relating to Ophthalmology and/or Santen, tailored to your areas of interest and expertise and your SEE portal online user activity, to offer your further learning, scientific and/or promotional opportunities as well as to enhance your customer profile and ongoing business relationship with Santen.

Providing your consent to such processing and further use of your personal information and related user activity is completely optional and does not have any effect on your registration and/or use of the SEE portal services. If you choose to provide your consent for the aforementioned purposes, you will still be able to withdraw it at any given time, without providing any reasons, by simply visiting your profile and opting out of communications

Your data protection rights

Under applicable laws and subject to any legal restrictions, you may have the right to request us to:

  • Provide you with further details on the processing of your personal information;
  • Provide you access to your personal data that we hold about you;
  • Update any inaccuracies in the personal information we hold that is demonstrated to be inaccurate or incomplete;
  • Delete any personal information that we no longer have a lawful basis to use;
  • Transmit your personal data you have provided to Santen to another controller where technically feasible (data portability);
  • Stop a particular processing when you withdraw your consent, at any time and free of charge;
  • Object to any processing based on the legitimate interests or public interest to process information, unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights. and
  • Restrict certain aspects of the processing of your information.

All data protection related requests should be addressed to Santen EMEA Privacy Office at pr**********@sa****.com.

If we do not handle your request in a timely manner, or if you are not satisfied with our response to any exercise of these rights, you are entitled to lodge a complaint with the competent supervisory authority of your place of residence or work. Further information and contact details of the competent European supervisory authorities can be found here.

Further information and contact details of the UK competent supervisory authority (ICO) can be found at https://ico.org.uk/ .

Policy updating

Santen reserves the right to amend this Policy from time to time to reflect technological advancements, legal and regulatory changes, and Santen’s business practices, subject to applicable laws. If Santen changes its privacy practices, an updated version of this Policy will reflect those changes by posting any revisions on with the respective update of the effective date listed on the bottom of this Policy. We therefore encourage you to periodically visit this page to stay informed of how we are using your personal data.

Contact information

If you have any questions in relation to this Policy, or you want to obtain more information about Santen’s privacy practices, please contact our Santen EMEA Privacy Office by email at pr**********@sa****.com.

Last updated: 21 August 2024

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