Healthcare Professional Privacy Notice

Effective Date: 9 April 2018

AbbVie Limited (”AbbVie”, “we” or “our”) is an Irish biopharma company which develops and markets pharmaceutical products and delivers patient oriented solutions.  AbbVie is part of a global group, focused on developing leading treatments and innovations worldwide.  At AbbVie, we take great care in processing personal data in compliance with applicable laws. We only collect and use the information necessary to achieve the purposes described below.  The data controller is AbbVie (company registration number 510846) having its registered office at 70 Sir John Rogerson’s Quay, Dublin 2, and its principal place of business is at, 14 Riverwalk, Citywest Business Campus, Dublin 24, D24 XN32, Ireland.

Personal data that we collect about you and why

Sources

We may collect personal data about you from a variety of sources, including directly from you and from publicly available sources such as the Irish Medical Directory, CVs and resumes, online and other databases and websites, from third party providers such as IQVIA (which is a provider of a worldwide healthcare professionals database), and other documents or forms that you provide in order to participate in AbbVie-sponsored or supported initiatives, such as AbbVie-sponsored clinical research and development activities, seminars regarding product information and AbbVie services, educational events, and clinical information and updates or in other contexts..

Types of personal data

AbbVie may collect and use some or all of the following categories of personal data for the purpose described below:

• 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 AbbVie and other companies), publication of academic or scientific research and articles, and membership in associations and boards;
• financial details such as payment-related information, transfers of value which may include contributions to costs of educational events (such as registration fees, travel and accommodation expenses) and fees for services including consultancy services; 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, and similar information.

Processing purposes

We process this information for the following purposes:

• managing our relationship with you, including planning, organising, reviewing potential collaboration, analysis and/or contact with you;
• 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 professional relationship with you;
• complying with applicable laws and regulations (e.g., in connection with pharmacovigilance); and/or
• publicly disclosing certain transfers of value made to you and healthcare organisations under the Irish Pharmaceutical Healthcare Association (“IPHA”) Code of Practice for the Pharmaceutical Industry.

The legal basis for this processing are our legitimate interest in maintaining and optimising a professional relationship or connection with you, performance of a contract with you or involving you, compliance with a legal obligation and, where relevant, your consent. You are not required by law or by a contract to provide your personal data to AbbVie.  However, in order to maintain our relationship with you, AbbVie needs to process your personal data.

Sharing your personal data

AbbVie 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 AbbVie group and companies with whom we may partner in connection with proposed or actual AbbVie projects;
• our trusted third party service providers that supply goods or services to AbbVie such as legal counsel, auditors and IT service suppliers;
• our trusted third party service providers who supply services on behalf of AbbVie (ie, nurse support services);
• other third parties pursuant to a court order, to protect the interests of AbbVie, or where otherwise required by law, legal process or industry guidelines;
• actual or prospective purchasers of AbbVie businesses in the event of a sale, merger or acquisition; and
• in respect of transfers of value data, the IPHA Central Platform on www.transferofvalue.ie (as updated from time to time).

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 that exist in your country of residence.  To ensure an adequate level of data protection is provided, AbbVie has entered into an Inter-affiliate Data Transfer Agreement with AbbVie Inc. and it affiliates. The AbbVie Inter-affiliate Data Transfer Agreement incorporates the EU model contract for data transfers to controllers, which covers all personal data transfers between AbbVie affiliates worldwide to ensure an adequate level of protection for any transferred data. A copy of this agreement can be obtained by sending an email to privacyoffice@abbvie.com.

Where AbbVie uses service providers that have access to personal data, it requires such service providers to protect your data and to process your personal data in accordance with our written instructions and this data protection notice and for no other purpose.

Securing and retaining your personal data

AbbVie will take appropriate technical and organisational security measures to protect your personal data consistent with applicable privacy and data security laws.  When AbbVie retains a third-party service provider, that provider will be carefully selected and required to use appropriate measures in accordance with applicable law to protect the confidentiality and security of personal data.

AbbVie retains your personal data in a manner consistent with our retention policy and only for as long as we continue to have a relationship with you, unless a longer retention period is required or permitted by law.

Your rights

You may contact AbbVie to request access to personal data that we process about you and that we correct inaccurate data and complete any incomplete data.  Please contact us if any of the details you have provided change.  In accordance with the conditions and requirements of applicable law, you may object to our processing of your personal data, restrict the processing of such data and request that we erase personal data about you.   We may need to discuss the basis of your request as there may be circumstances where we are legally entitled to continue processing your personal data or refuse your request.

In limited circumstances, you may have the right to receive some personal data in structured, commonly used, machine-readable format and / or request that we transmit that data to a third party where this is technically feasible.  Please note that this right only applies to personal data that you have provided to us.

In cases where we are relying on your consent to process your personal data, you have the right to change your mind and withdraw your consent.  However, this may affect our ability to continue to provide the relevant services to you.

Should you wish to exercise any of these rights or if you have any questions regarding this notice or prefer that AbbVie not contact you again, please let AbbVie know by contacting us at privacyoffice@abbvie.com or write to us at Mainzer Straße 81, 65189 Wiesbaden, Germany (attention: EU DPO). If AbbVie is not able to fulfil your request, you will be provided with reasons for such decision. In addition, you are entitled to lodge a complaint with your local data protection authority.

If you have also consented to direct marketing but no longer want to receive any direct marketing via email, SMS/MMS, fax, and/or telephone, you will also need to withdraw your consent as explained in the message you received.

To learn more about AbbVie’s privacy practices, please refer to our general online privacy notice at www.abbvie.ie/privacy/home.html

Changes to This Healthcare Professional Privacy Notice

We reserve the right to change this notice at any time (for example, to comply with changes in laws or regulations, our practices, procedures and organisational structures, requirements imposed or recommended by supervisory authorities or otherwise).  Changes to this notice shall be applicable on the effective date of implementation.  Please refer to our website for the latest version of this notice.  We will also communicate any changes to you, where we are required to do so.

Governing Law and Jurisdiction

This notice is governed by the laws of Ireland and subject to the exclusive jurisdiction of the Irish courts.

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