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Date of Preparation: December 2020
Collection and Processing of Your Personal Data
GW Pharma (International) B.V. will be a data controller for information collected on this form. In addition, if you are based in a country where GW Pharma (International) B.V has a local affiliate, that local affiliate will also be a data controller for the information collected on this form. The GW Pharma (International) B.V local affiliates are GW Pharma (France) SARL, GW Pharma (Germany) GmbH, GW Pharma Italy S.R.L. and GW Pharma Spain, S.L. (collectively "GW").
Collectively GW have the same purposes for collecting your data as outlined in this notice and both companies will require your consent for education and marketing information and communications.
Personal data that we collect about you and why
In addition to collecting your personal data directly from you, we may also collect personal data about you from a variety of sources including from publicly available sources, online and other databases and websites, and other documents or forms that you provide in order to participate in GW-sponsored or supported initiatives, such as GW sponsored medical education, research and development activities, or in other contexts.
GW may collect and use some or all of the following categories of personal data about you:
- personal details such as your name, gender and contact details;
- professional details such as your place of practice, job title, the medical field in which you are active, your professional qualifications and scientific activities (such as previous clinical trial experience, and participation in past or pending research studies with GW and other companies), publication of academic or scientific research and articles, and membership in associations and boards; and
- details of interactions with us, such as what kind of meetings we have held, topics discussed, your knowledge of and questions you have had on our business and products, what kind of material we have displayed to you and any feedback that you have provided, as well as your opinions and routines on prescribing, routines regarding your patients and diagnosis,
We process this information in our customer databases for the purpose of providing educational information and communications, and managing our relationship with you, including planning potential collaboration, contact, and helping ensure that we provide you with information that is relevant given your expertise, interests and preferences. The legal basis for this processing is our legitimate interest in maintaining a relationship with you and to provide you with the information you have requested.
Sharing your personal data
GW may share your personal data with others, from time to time, in connection with the purpose described in this notice. In particular, we may make your personal data available to:
- other companies within the GW Pharmaceuticals group;
- third party companies with whom we may partner in connection with proposed or actual GW projects such as commercialisation, medical communication, market research, creative agency and market access;
- third party companies that supply goods or services to GW such as legal counsel, auditors and IT service suppliers;
- other third parties pursuant to a court order, to protect the interests of GW, or where otherwise required by law or legal process; and
- actual or prospective purchasers of GW businesses in the event of a sale, merger or acquisition.
Sharing your personal data as described above may involve transferring it to countries, including countries outside of the EU/EEA, whose data protection and privacy laws may not be equivalent to, or as protective as, those which exist in your country of residence. However, in accordance with applicable law, GW implements measures such as standard data protection clauses to ensure that any transferred personal data remains protected and secure.
Securing and retaining your personal data
GW will take appropriate technical and organisational security measures to protect your personal data consistent with applicable privacy and data security laws. When GW retains a third-party service provider, that provider will be carefully selected and required to use appropriate measures to protect the confidentiality and security of personal data.
GW retains your personal data only for as long as we continue to have a relationship with you, unless a longer retention period is required or permitted by law.
You may contact GW to request access to personal data that we process about you and that we correct inaccurate data and complete any incomplete data. In accordance with the conditions and requirements of applicable law, you may object to our processing your personal data and request that we erase personal data about you, restrict processing of such data, and transmit your personal data to you or another data controller.
Should you wish to exercise these rights or if you have any questions regarding this notice, please let GW know by contacting us at firstname.lastname@example.org. You may lodge a complaint with your local Data Protection Authority (“DPA”) if you consider that our processing of your personal data infringes applicable law. A listing of each EU country’s DPA may be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm