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Privacy & Data Protection Policy

Version 1.0 Effective Date: May 27, 2020

Our commitment

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:

patients and their relatives or close ones,
participants in clinical trials,
healthcare professionals,
users of our products and services, including websites and apps users,
representatives of our contractors and business partners,
representatives of the scientific community etc.
job applicants.

What you will find in this document

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:

THE PURPOSES: for what reasons and purposes SANOFI processes your Personal Data
ON WHAT GROUND: on what basis does SANOFI process your Personal Data
WHERE FROM: from what sources does SANOFI collect your Personal Data
WHO: who are the authorized parties that SANOFI may disclose your Personal Data to
WHERE: where SANOFI and its authorized parties may process your Personal Data
HOW SECURE: what SANOFI does to protect your Personal Data
HOW LONG: SANOFI’s approach to defining the term of retention of your Personal Data
YOUR RIGHTS: what your rights are and how you can exercise them
HOW TO CONTACT US: where and how you can reach us if you wish to exercise your rights or if you have a question

What processing activities does this Policy cover?

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.

Validity and evolution of this Policy

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.

Familiarization and raising awareness

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.

THE PURPOSED: SANOFI will always collect your Personal Data for explicit and legitimate purposes

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:

to carry out our business operations; carry out marketing and sales; respond to your requests; to keep track of our interactions and meetings, such as when you contact us for information and support;
to comply with legal or regulatory obligations that apply to SANOFI; monitor safety; manage adverse events; carry out prevention and investigatory activities; carry out administrative formalities, registration, declarations or audits;
to provide patient support, healthcare support services, patient engagement and prescription information; manage claims, including insurance claims;
to conduct research and development; carry out clinical studies, registries and trials; manage and validate the recruitment and participation of individuals to studies, trials and other operations; analyze demographic data; offer special programs, activities, trials, events or promotions via our services ; carry out market or consumer studies;
to provide you access to online services, application and platforms; manage your online accounts;
to allow us to identify or authenticate you; provide or verify your credentials including via passwords, password hints, security information and questions, government-issued ID, healthcare professional number, driver’s license data, and passport data.
to improve and develop our products and services; identify usage trends and develop new products and services; understand how you and your device interacts with our services; track and respond to safety concerns; determine the effectiveness of our promotional campaigns, conduct surveys;
to personalize your experience when using our services; ensure that our services are presented in the way that best suits you; understand your professional and personal interests in our content, products and services or other content and adapt our content to your needs and preferences; present you products and offers tailored to you;
to allow us to communicate with you; respond to your requests or inquiries ; provide support for products and services ; provide you with important information, administrative information, required notices, and promotional materials; send you news and information about our products, our services, our brands, our operation; organize and manage professional events and congresses, including your participation to such events;
to process payments we may need to issue in a specific situation; verify your financial data; facilitate further payments;
to offer donations and sponsorships;
to respond to legal requests from administrative or judicial authorities, in accordance with applicable laws; comply with a subpoena, required registration, or legal process;
to protect our rights and interests; protect the health, safety, and security of SANOFI personnel and premises; carry out internal audits, asset management, system and other business controls; manage business administration (finance and accounting, fraud monitoring and prevention); maintain the security of our services and operations ; protect our rights, privacy, safety or property, to allow us to pursue available remedies or limit the damages that we may incur as necessary; to protect ourselves against possible fraudulent actions.

ON WHAT GROUND? SANOFI will always process your Personal Data lawfully

Depending on the data processing at stake, SANOFI will generally process your Personal Data on either one of the following legal basis:

your prior consent: where you have clearly expressed your approval of SANOFI’s processing of your Personal Data. In practice, this will generally mean that SANOFI will ask you to sign a document, or to fill-in an online “opt-in” form, or to follow any relevant procedure to allow you to be fully informed and then either clearly accept or refuse the data processing envisaged.
a contractual relationship between you and SANOFI: in such case, the processing of your Personal Data is generally necessary to the execution or the performance of the contract; this means that if you do not wish SANOFI to process your Personal Data in that context, SANOFI may or will be obliged to refuse to enter into such contract with you or will not be able to provide the products or services covered in this contract, or to fulfill obligations with you under this contract.
legal obligations applicable to SANOFI’s activities; for instance, SANOFI is required to implement pharmacovigilance procedures to monitor adverse effects of marketed products, which generally involves the collection and retention of Personal Data.
the “legitimate interest” of SANOFI in the sense of applicable data protection law. In such a case, SANOFI shall consider your fundamental rights and interests in determining whether the processing is legitimate and lawful.
the establishment and defences of legal claims.

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.

WHERE FROM: Where does the Personal Data come from? SANOFI will always collect Personal Data from trusted sources

SANOFI may collect your Personal Data from different sources:

Data that you communicate to us through various media, both online and offline, whether face-to-face, or via any other means used in communications for any activities, through registrations, applications surveys, or direct and indirect interactions with SANOFI. For example, data you provide to register to scientific events sponsored by SANOFI, to submit an online application, to send us a request for information, etc.
Data that we collect automatically, for instance when following your interactions with our websites, platforms, applications and services through certain technologies, such as cookies.
Data that we collect in accordance with applicable law from public sources available, including data that is published by you in all supports.
Data that we obtain legally from third parties, for example, when we may need to confirm contact or financial information or to verify licensure of healthcare professionals. In such case, we generally receive such Personal Data from third-parties that are authorized to do so in the framework of their own privacy and data protection policies or in accordance with the law. As applicable, we will inform you in the Privacy Notice of the identity of those third-parties and will invite you to refer to their privacy and data protection policies to inquire on the origin of such Personal Data and the condition of their collection.

About children Personal Data

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.

WHO has access to Personal Data: SANOFI will share your Personal Data only with authorized parties

For the purposes described above, SANOFI may need to share your Personal Data with the following authorized third-parties:

Sanofi and its affiliates
our partners (healthcare professionals and organizations, distributors, other members of the healthcare and pharmaceutical industry)
selected suppliers, service providers or vendors acting upon our instructions for website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, etc.
legal or administrative authorities, as required by applicable laws including laws outside your country of residence
potential acquirers and other stakeholders in the event of a merger, legal restructuring operation such as, acquisition, joint venture, assignment, spin-off or divestitures.
sponsors of sweepstakes, contests and similar promotions

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:

undertake to comply with data protection laws and the principles of this Policy;
will only process the Personal Data for the purposes described in this Policy; and
implement appropriate technical and organizational security measures designed to protect the integrity and confidentiality of your Personal Data.

WHERE Personal Data may be transferred: SANOFI will ensure that transfers of your Personal Data outside Thailand are safeguarded

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.

HOW SECURE: SANOFI will implement security measures to protect your Personal Data

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.

HOW LONG: we will retain your Personal Data for no longer than necessary

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.

YOUR RIGHTS: SANOFI will ensure that you can exercise your rights pertaining to your Personal Data

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:

to have access: You may have the right to access or request a copy of your Personal Data we are collecting, using and disclosing about you.
to request a rectification: You may have the right to have incomplete, inaccurate, misleading, or not up-to-date Personal Data that we collect, use and disclose about you rectified.
to obtain data portability: You may have the right to obtain your Personal Data we hold about you, in a structured, electronic format, and to send or transfer such data to another data controller, where this is (a) Personal Data which you have provided to us, and (b) if we are processing such data on the basis of your consent or to perform a contract with you.
to object to the processing of your Personal Data: You may have the right to object to certain collection, use and disclosure of your Personal Data, such as objecting to direct marketing. Where your Personal Data has been collected and processed on the basis of legitimate interests of SANOFI, in which case you will need to justify your request by explaining to us your particular situation.
to restrict the use of your Personal Data: You may have the right to restrict the use of your Personal Data in certain circumstances.
to withdraw consent: For the purposes you have consented to our collecting, using and disclosing of your Personal Data, you have the right to withdraw your consent at any time. The withdrawal of consent will not affect the lawfulness of the collection, use and disclosure of your Personal Data based on your consent before it was withdrawn.
to delete your Personal Data: You may have the right to request that we delete, destroy, or make unidentifiable, the Personal Data that we collect, use and disclose about you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise, or defend legal claims.
to lodge a complaint: You may have the right to lodge a complaint to the competent authority where you believe our collection, use and disclosure of your Personal Data is unlawful or non-compliant with applicable laws.

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.

HOW TO CONTACT US

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

Address: 87/2 CRC Tower 24^th Floor, All Seasons Place, Wireless Road, Lumpini, Pathumwan, Bangkok 10330 Thailand
Phone number: +66 2 264 9999
Email address: THMM_Privacy.Officer@sanofi.com

SANOFI’s Data Privacy Officer

Address: 87/2 CRC Tower 24th Floor, All Seasons Place, Wireless Road, Lumpini, Pathumwan, Bangkok 10330 Thailand
Phone number: +66 2 264 9999
Email address: THMM_Privacy.Officer@sanofi.com

Please be aware that once SANOFI receives your request, it may take up to thirty (30) days to respond to your request.