Version 1.0 Effective Date: May 27, 2020
SANOFI-AVENTIS (THAILAND) LTD. and its affiliates in Thailand (each and collectively as “SANOFI”, “we” or “us”) fully understand the importance of privacy and the protection of personal data in the digital era and are committed to ensure an adequate level of data protection for all persons with whom SANOFI has dealings in accordance with the Personal Data Protection Act, B.E. 2562 of Thailand, its implementing rules and regulations and other applicable laws protecting the privacy of your Personal Data. This includes, notably:
This Privacy & Data Protection Policy (“Policy”) describes SANOFI’s practices to ensure an adequate protection of personal data, i.e. any information relating to an identified or identifiable natural person, for all data processing carried out in the framework of its business and activities (“Personal Data”).
The objective of this Policy is to help you understand:
This Policy is intended to apply to all processing activities SANOFI conducts towards the persons it deals with in its professional business activities through all communication channels, both online and offline, whether face-to-face, or via any other means used in communications for any activities, unless otherwise defined in another specific privacy policy.
Specific privacy and data protection information notices (“Privacy Notice”) and/or consent forms will, if necessary, be communicated to you regarding specific situations where SANOFI may process your Personal Data. These Privacy Notices shall describe in more detail how your Personal Data will be processed in relation with the processing in question. Should you refuse to provide your Personal Data, or your consent to SANOFI to collect, use, transfer, disclose or process your Personal Data, SANOFI may not be able to communicate with you or to respond to any of your requests.
Our activities are generally not aimed at any person without legal capacity to conduct a legal act on his own, e.g. minors, persons deemed incompetent, or quasi-incompetent. If you do not have appropriate legal capacity to provide your consent for SANOFI to process your Personal Data, you must inform us in order to allow us to proceed in compliance with the applicable law. In case you are a minor and have consented us to process your Personal Data, you must indicate that your holder of parental responsibility over you has consented to doing so.
This Policy may be modified by SANOFI, from time to time, in particular to adapt its terms to evolutions or changes of applicable legislations and/or to SANOFI’s practices. We invite you to check this Policy periodically.
We will familiarize our employees and other personnel with this Policy and ensure their compliance. To this end, we will try to provide adequate education to our employees and other members of us.
Each Privacy Notice shall set out for what reasons (i.e. purposes) your Personal Data is processed and what Personal Data is collected and processed. In general, SANOFI collects your Personal Data for the following purposes:
Depending on the data processing at stake, SANOFI will generally process your Personal Data on either one of the following legal basis:
SANOFI may, on a case-by-case basis, rely on other legal grounds, such as the protection of your vital interests, in accordance with applicable data protection law, or as set forth in the applicable Privacy Notice.
SANOFI may collect your Personal Data from different sources:
While in some instances we may collect Personal Data about children with the consent of his/her parent or guardian for the provision of our services such as clinical activities or for patient support programs, we do not otherwise knowingly solicit Personal Data from, or market to, children. If a parent or guardian becomes aware that his or her child has provided us with personal information, he or she should contact us as described in the “How to Contact Us” section below. We will take steps to delete such information from our database in accordance with applicable legal requirements.
For the purposes described above, SANOFI may need to share your Personal Data with the following authorized third-parties:
SANOFI may need to share your Personal Data with other third-parties, in which case you will be duly informed through the applicable Privacy Notice.
In any case, SANOFI will require that such third-parties:
SANOFI is a multinational organization with affiliates, partners and subcontractors located in many countries around the world. For that reason, SANOFI may need to transfer (via access, visualization, storage..) your Personal Data in other jurisdictions outside Thailand, or in countries which may not be regarded as providing the same level of protection as specified under the laws of Thailand.
Safeguards for international transfers of Personal Data: In cases where SANOFI needs to transfer Personal Data outside Thailand, it shall ensure that adequate safeguards, as required under applicable data protection legislation, will be implemented.
In this respect and in particular, for intra-group transfers of Personal Data implemented for clinical studies and pharmacovigilance purposes, SANOFI has implemented and shall apply its “Binding Corporate Rules” validated by the EU Data Protection Authorities.
We have implemented a variety of technological and organizational procedures and measures to ensure the integrity and confidentiality of your Personal Data from unauthorized access, use and disclosure. These measures shall take into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.
For instance, we store your Personal Data on servers that have various types of technical and physical access controls, which may include, for instance, if appropriate, encryption. We may also aggregate, pseudonymize or anonymize Personal Data to ensure that no personally identifiable information is communicated to third parties.
SANOFI will retain your Personal Data only for the period necessary to fulfill the purposes outlined in this Policy.
As an exception, SANOFI may be required to retain your Personal Data for longer periods as required or permitted by law, or as necessary to protect its rights and interests. In such a case, you will be informed of the intended retention period in the applicable Privacy Notice.
You can exercise your rights as provided by the applicable data protection laws of Thailand.
To that end, SANOFI informs you that you are entitled:
If you would like to exercise any of these rights, please contact us as described in the “How to Contact Us” section below and we will take necessary steps to respond as soon as possible within 30 days after our receipt of your request.
SANOFI welcomes any questions or comments you may have regarding this Policy or its implementation. Any such questions or comments should be submitted using the contact information below.
You can send any request pertaining to your rights and SANOFI’s use of your Personal Data to our Data Privacy Officer during office hours Monday to Friday (except public holidays) from 8.30 a.m. to 5.30 p.m. at:
SANOFI
SANOFI’s Data Privacy Officer
Please be aware that once SANOFI receives your request, it may take up to thirty (30) days to respond to your request.
