Privacy Policy
Edited on 15 Nov 2024
Luzsana Biotechnology Europe AG (“Luzsana”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal information. Please read this Privacy Notice carefully as it contains important information on how and why Luzsana collects and processes your personal information through your use of this website.
Luzsana is the Controller of the personal data and has committed to comply with all applicable data protection legislations, including but not limited to, the General Data Protection Regulation EU 2016/679 (GDPR) and Swiss Federal Act on Data Protection (FADP).
This Privacy Notice aims to make sure that you understand what personal information is collected about you, how your personal information is used and how it is kept safe. The terms and definitions contained in this Notice shall be read and interpreted in the light of the provisions of the applicable data protection legislations.
THE USE OF OUR WEBSITE IMPLIES YOUR FULL AND UNRESERVED ACCEPTANCE OF THIS NOTICE, AS WELL AS OUR TERMS OF SERVICE. YOU ACKNOLEWDGE HAVING READ THE INFORMATION BELOW AND AUTHORIZE LUZSANA TO PROCESS, IN ACCORDANCE WITH THIS NOTICE, YOUR PERSONAL INFORMATION THAT YOU PROVIDE ON OUR WEBSITE.
1. What personal data do we collect?
We may collect and use your personal information in a variety of contexts, including when you participate in Luzsana research, take our drugs or therapies, or visit our websites or offices. Depending on your relationship or interactions with Luzsana, Luzsana may have collected and processed any of the following categories of personal information about you:
Categories | Examples | Incipients Information |
---|---|---|
Identification information | First name, last name, initials, gender, age or date of birth, government-issued identification (e.g. identity card, driver’s license, passport or tax ID number), photographs, videos, sound recordings, language, or Luzsana-issued access cards and IT credentials. |
• Luzsana Biotechnology Europe AG; • Luzsana service providers; • Luzsana technology and security providers; • Luzsana business partners and collaborators; • Administrative, regulatory or judiciary authorities; • Advisors; and • Other third parties. |
Contact details | Postal and/or email address, or phone number | • Luzsana Biotechnology Europe AG; • Luzsana service providers; • Luzsana technology and security providers; • Luzsana business partners and collaborators; • Administrative, regulatory or judiciary authorities; • Advisors; and • Other third parties. |
Commercial information | Records of Luzsana’s products or services prescribed, purchased, obtained or considered, payment information (amount invoiced and/or paid, bank details, payment method, billing address), or history of our relationship | • Luzsana Biotechnology Europe AG; • Luzsana service providers; • Luzsana technology and security providers; • Luzsana business partners and collaborators; • Administrative, regulatory or judiciary authorities; • Advisors; and • Other third parties. |
Professional information | Job title, employment status, educational information, professional qualifications and licenses, or work experience and professional networks, affiliates, programs and activities | • Luzsana Biotechnology Europe AG; • Luzsana service providers; • Luzsana technology and security providers; • Luzsana business partners and collaborators; • Administrative, regulatory or judiciary authorities; • Advisors; and • Other third parties. |
Health, biometric and genetic information | Information about your medical conditions, treatments and any adverse events you may experience while taking our drugs or therapies | • Luzsana Biotechnology Europe AG; • Luzsana service providers; • Luzsana technology and security providers; • Luzsana business partners and collaborators; • Administrative, regulatory or judiciary authorities; • Advisors; and • Other third parties. |
Geolocation | Geolocation information obtained from your device’s GPS, Bluetooth, IP address, or other location services/technology | • Luzsana Biotechnology Europe AG; • Luzsana service providers; • Luzsana technology and security providers; • Luzsana business partners and collaborators; • Administrative, regulatory or judiciary authorities; • Advisors; and • Other third parties. |
Information related to your exchanges with Luzsana | Date and subject of your requests or exchanges with Luzsana’s services | • Luzsana Biotechnology Europe AG; • Luzsana service providers; • Luzsana technology and security providers; • Luzsana business partners and collaborators; • Administrative, regulatory or judiciary authorities; • Advisors; and • Other third parties. |
Others | Other information needed for our relationship or interactions with you or as required by laws, our service providers or collaborators, such as the information you provide in connection with contracts and queries you make to us. | • Luzsana Biotechnology Europe AG; • Luzsana service providers; • Luzsana technology and security providers; • Luzsana business partners and collaborators; • Administrative, regulatory or judiciary authorities; • Advisors; and • Other third parties. |
2. Why do we use your personal data?
The reason why we collected your information decides how we process it. Depending on your relationship and/or interactions with Luzsana, as well as, applicable legislations and our own procedures & requirements, Luzsana may process your personal information for the following reasons:
Purpose | Examples | Legal ground |
---|---|---|
Managing your contact requests | • To contact you • To answer your questions |
Legitimate interest of Luzsana to manage its contact requests |
Managing the personal and contractual relationship with you | • To develop or manage our relationship or interactions with you or your employer or affiliated organization • To comply with our contractual and payment obligations • To process your privacy and other requests or complaints |
Depending on your relationship with Luzsana: • to take steps prior to entering into an agreement or • performance of the relevant agreement or • comply with legal and regulatory obligations to which Luzsana is subject |
Improving the products, services and programs of Luzsana | • To determine eligibility for, facilitate supply, administration and management of, to track progress and outcomes regarding certain products, services and programs • To manage Luzsana’s research and development, collaboration and market research efforts |
Legitimate interest of Luzsana to improve its products, services and programs |
Sending communication that might interest you | • To send you transactional, administrative and marketing communications regarding Luzsana business and medical activities (including products, services, programs and events of Luzsana). You can opt-out of these communications by the methods described in the YOUR RIGHTS Section of this policy. | Legitimate interest of Luzsana to develop its business activities (with your consent, if required by applicable law) |
Providing educational and awareness information | • To provide you educational information, including providing information about certain health conditions and disease states, our products, programs and services | Legitimate interest of Luzsana to enhance the education and awareness about health conditions and disease states |
Managing Luzsana’ events or programs | • To register you • To manage the event or program depending on the participants • To send you communications about the event or program • If applicable, to record Luzsana’ events or programs |
Legitimate interest of Luzsana to develop its business activities (with your consent, if required by applicable law) |
Improving the websites and their services, as well as your user experience on the websites | • To evaluate and improve the websites and their services e.g. to track the popularity of certain pages of the websites, the success of our email notifications, traffic levels on the websites and other usage data • To take steps designed to protect and enhance the security of the websites |
Legitimate interest of Luzsana to improve the Sites and their services, as well as your user experience on the Sites |
Pre-litigation or litigation management | • To take action against any identified breach • To manage any dispute or litigation |
Legitimate interest of Luzsana in defending its rights and interests |
Compliance with legal and regulatory obligations | • To comply with legal and regulatory obligations (e.g., in connection with regulatory submissions or complying with regulatory obligations relating to drug development, safety and transparency reporting, and for monitoring, investigating and enforcing compliance with our policies and legal and regulatory requirements) • To process your requests to exercise your rights |
Legal and regulatory obligations to which Luzsana is subject |
Others | • For other everyday business purposes such as payment processing and accounting, product development, safeguarding Luzsana property, contract management, archiving, website administration, fulfilment, analytics, fraud prevention and corporate governance, the potential sale or merger of some or all of the company, reporting and legal compliance. | Legitimate interest of Luzsana or legal and regulatory obligations to which Luzsana is subject |
3. How do we collect your data?
You directly provide Luzsana with most of the data we collect. We collect data and process data when you:
- Register online or place an order for any of our products or services.
- Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.
- Use or view our website via your browser’s cookies. (For more information on cookies and other data collection technologies, please read the Cookies Policy applicable to the website you are accessing.)
4. How long will we keep your personal information?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of meeting any legal, accounting or reporting requirements.
5. Data sharing
We may transfer your personal data to our associated entities and service providers to the extent necessary in order to achieve the purpose we collected the data for. We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not sell, trade, or rent your personal data to third parties.
Some of our associated entities and service providers may be located outside Switzerland, the European Economic Area (EEA) and/or other country where Luzsana’s subsidiary(ies) is located. In this case, your personal data may be transferred outside of those regions and Luzsana will take steps to ensure personal data is kept secure and treated in accordance with this privacy notice. In the absence of an adequacy decision, we will implement appropriate safeguards, including where relevant by entering into appropriate standard contractual clauses with the receiving party outside of Switzerland, the EEA and/or other country where Luzsana’s subsidiary(ies) is located.
6. How do we protect your data?
Luzsana has in place appropriate security measures to ensure the security and integrity of your personal information and treats your personal data in a confidential manner. We limit access to your personal information to those individuals who have a business need to access it to protect your personal information from unauthorized access and disclosure.
We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
7. Automated decision-making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making unless we have a justification for doing so and we have notified you.
8. Your rights
Under certain laws such as GDPR and FADP (including those implementing regulations and national standards), you may have the following rights with respect to your personal information to:
Be informed | You have the right to know how your Personal Information is collected and used. |
Request access | You may ask to receive a copy of your Personal Information in a commonly used format. You have the right to know whether we process Personal Information about you, and if we do so, to access certain data we hold about you and certain information about how we use it and who we share it with. |
Request correction | You are entitled to ask us to rectify, by completing or correcting, all or certain information held about you which appears incomplete or inaccurate. |
Request erasure | You have the right to ask us to delete or remove your Personal Information where there are no longer legitimate grounds to continue to process it. |
Request restriction of processing | You have the right to ask that the use of your Personal Information is restricted, or even “frozen”, to leave you the possibility to exercise other rights. Your Personal Information shall not be used anymore but must be kept by us during this period. |
Request data portability | You may ask that your Personal Information is transferred to another data controller. |
Object to processing | You have the right to object to the processing where we are relying on legitimate interest as legal basis. |
Withdraw consent | When you have given your consent for the processing of your Personal Information (e.g.: email alerts), you can withdraw it at any time without justification as long as the processing is covered by GDPR and other applicable laws and regulations. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purposes you originally agreed to, unless we have another legitimate basis for doing so in law. |
9. Exercising your rights
If you have any question or request about the Privacy Notice, the ways in which Luzsana collects and uses your personal information described above, your choices and rights regarding such processing, or wish to exercise your rights under applicable data protection laws, you may do so by contacting us as follows:
– By sending an email to [email protected]
If we do not fulfil your request, you will be provided with the reason(s) for such decision.
In the case you consider the processing of your personal data infringes the GDPR or the FADP, you have the right to lodge a complaint with the data protection supervisory authority in the Member State of your habitual residence, place of work or place of the alleged infringement.
11. Pharmacovigilance, Enquiries and Product Quality Complaints Privacy
If the information you provide involves the safety information of Luzsana’s medicine products, we will collect the patient’s personal information, including but not limited to: the patient’s name, gender, date of birth/age, physiological signs, contact information, medical history, family history, medication information, allergy history, medical records, data related to adverse events, and the basic information of the reporter, including name, contact number, work address, and email address, for the purpose of verifying the validity of the data and processing the safety information report. Please note: According to PIPL and GDPR, past medical history, family history, medication information, allergy history, medical records, and adverse reaction event data are sensitive personal information, and we need this information for follow-up of relevant safety information to ensure that Luzsana meets the regulatory requirements of drug regulations.
If the information you provide involves a safety inquiry about medicine products of Luzsana, we will record and use the name, phone number, identity information, email address, address, workplace, professional title, medication information provided by you for the follow-up provision of medical knowledge and medication guidelines.
Luzsana will strictly follow the requirements of domestic and foreign regulators and laws and regulations to properly store and use the collected personal safety data. We will comply with all applicable laws, regulations, and industry best practices in the cross-border transfer of personal safety information, and we will always comply with the strictest requirements if the rules differ from jurisdiction to jurisdiction.
We are committed to taking appropriate technical and management measures to protect your personal information from unauthorized access, or any disclosure, alteration or loss. We promise to take appropriate measures to protect your personal information, so that the processing of your sensitive personal information will not have a significant adverse impact on your personal rights and interests. We will keep your personal information for the shortest period necessary in accordance with the requirements of laws and regulations.
You have the right to be informed about, have access to, to rectify and restrict the processing of your personal safety information, and you can contact us at any time at the hotline 86-400-8283900/86-800-8283900 to request an inquiry, to request a copy, correction, deletion of the personal information we hold about you, or to withdraw your consent to the processing of certain types of personal information. If the request results in Luzsana or its affiliates violating its obligations under applicable laws, regulations or codes of practice, then your request may not be fully met, but you can still request us to
prohibit further use of your personal information. Luzsana has appointed a data protection officer to be responsible for supervising Luzsana’s compliance with relevant laws and regulations on personal information protection, and if you have any questions about Luzsana’s collection and processing of your personal information and your personal rights and interests, you can also send the request to [email protected] to obtain the Luzsana’s Data Protection Officer support.
12. Third party website and hyperlinks
This website may provide links to other websites as a service to our website’s visitors. These are websites we believe may have helpful information. However, Luzsana does not endorse and is not responsible for the content and the privacy notices of third-party websites. Similarly, Luzsana does not have any control over information you may choose to provide to those websites.
13. Changes to this Notice
Luzsana reserves the right to modify this Privacy Notices at any time. Then, we ask you to check this Notice regularly to ensure you are aware of the most recent version. We will notify you if we make any material changes to this Notice, which we may do by posting a message on our websites.
14. Contacts
Luzsana Biotechnology Europe AG, Barfusserplatz 3, 4051 Basel, Switzerland.
You may contact us at any time if you have questions or concerns about this Privacy Policy or our practices. Please send an email to [email protected].
If you have any questions of this privacy notice, or how your personal information is being processed, you can contact our Data Protection Officer. If you are still not happy after communication with our Data Protection Officer, you have the right to lodge a complaint with the corresponding data protection supervisory authority in your country of residence. You can find the contact details at:https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
DPO & DPR Contact details:
Luzsana Biotechnology Europe AG, acting as
Controller
Barfusserplatz
3, 4051 Basel, Switzerland
EU Data Protection Representative
140b Rue de
Rennes – 75006 Paris (FRANCE)
+33 9 70 70 20 09
UK Data Protection Representative
Belmont Building, Belmont Road – Uxbridge,
UB8 1HE (UNITED KINGDOM)
+44 56 0375 0073
Data Protection Officer
+32 32 2 896 55 53
For EU Data Protection Authorities https://edpb.europa.eu/about-edpb/about-edpb/members_en
For UK Supervisory Authority (“ICO”) Tel:
+55 (0)3 03 12 31 11 3
Website: https://ico.org.uk/global/privacy-notice/your-right-to-complain/
For CH Supervisory Authority (‘FDPIC’) Tel:
+58 462 43 95
Website: https://www.edoeb.admin.ch/en
Jiangsu Hengrui Pharmaceuticals Co., Ltd.,
acting as Controller
No. 7 Kunlunshan Road, Economic and
Technological Development Zone, Lianyungang, Jiangsu, China
EU Data Protection Representative
140b Rue de
Rennes – 75006 Paris (FRANCE)
+33 9 70 70 20 09
UK Data Protection Representative
Belmont Building, Belmont Road – Uxbridge,
UB8 1HE (UNITED KINGDOM)
+44 56 0375 0073
CH Data Protection Representative
Luzsana Biotechnology Europe AG
Flex Office, Barfüsserplatz 3,4051, Basel
(Switzerland)
Phone number: +41 79 240 60 71
Mail: contactus@luzsana.com
Data Protection Officer
+32 32 2 896 55 53
For EU Data Protection Authorities https://edpb.europa.eu/about-edpb/about-edpb/members_en
For UK Supervisory Authority (“ICO”) Tel:
+55 (0)3 03 12 31 11 3
Website: https://ico.org.uk/global/privacy-notice/your-right-to-complain/
For CH Supervisory Authority (‘FDPIC’) Tel:
+58 462 43 95
Website: https://www.edoeb.admin.ch/en
For CN Personal information protection supervision
authority – Cyberspace Administration of China (CAC) Tel: +86 12377
Website https://www.cac.gov.cn/index.htm