Last updated and effective: March, 2021
Zealand Pharma A/S, and its affiliate, Zealand Pharma US, Inc., (collectively, “Zealand”, or “we”, “us” or “our”) are aware of and respect user’s concerns regarding privacy when visiting our sites.
DISCLAIMER: The content appearing on Zealand Websites or web-based resources is presented exclusively for informational purposes. You understand and agree that Zealand does not use this site to provide medical advice, financial advice, or legal advice. You will not rely on any statements made on this site as though it were professional advice. The site may provide selected information concerning diseases and their treatment. Such information is not intended or provided as medical advice. Such information is not a substitute for the advice of a trained healthcare professional. If you have or suspect having any health problems or conditions, you should consult your general practitioner or other qualified health provider.
1. WHAT DATA DO WE COLLECT AND HOW DO WE COLLECT IT?
(a) Information You Provide:
You can generally visit our Website without revealing any personally identifiable information about yourself. However, certain areas of our Websites and online resources allow you to register, subscribe to online services or newsletters, take surveys or otherwise provide your information to us. We may collect information that either directly identifies you or could reasonably be used in combination with other publicly available information to identify you (“Personal Information”), including your name, contact information, email address, communication preferences, business information, including employment history, education history, qualifications, occupation and areas of specialization, and other information in combination with such identifiers. We may use and disclose the information you provide to send you requested information or other information we think may be of interest to you (including marketing communications), respond to your inquiry, improve our Website, verify your relationship with us, and take other actions that may be necessary to respond to your request or fulfill the terms of a contract we have with you. We also use this information within Zealand to improve our products and communications, or to develop new products, services, and communication strategies.
We generally avoid collecting sensitive personal information, such as health data (“Sensitive Personal Information”), through our Websites. In some cases, however, we may need to collect such Sensitive Personal Information to facilitate providing services to you, such as certain patient support service offerings. Where required to comply with all applicable data protection and privacy laws, we will obtain your explicit consent to collect Sensitive Personal Information about you through our Websites.
In addition, we may collect information about you from publicly available sources, third parties, and directly from you through your interactions with us. We may combine the personally identifiable information you share with us through our Website with other information we collect from or about you, both online and offline. We may also combine this personally identifiable information with records provided by third parties. We use this consolidated information to help us better design Zealand products, to communicate information to you, to enhance our marketing and research activities, and to facilitate other business functions.
If you choose to participate in our questionnaires and surveys and other interactive Services, we will collect the information, including health-related information and other sensitive personal information that you share to help us better understand how Zealand products are used in coping with the diseases for which they are marketed. The information you provide through interactive Services may be combined (subject to all applicable laws) with the personal information provided elsewhere in or through the Services. We may combine your and others’ personal information to create summary data that we will use for our business purposes, such as research to improve our products and analyses that may help us better market our products.
You may provide information to be published or displayed (“Posted”) on public areas of the Websites or Services (collectively, “User Contributions”). Your User Contributions are Posted and made available publicly at your own risk. Zealand does not control the actions of third parties with access to your User Contributions.
(b) Information We Collect Automatically:
We also automatically collect other basic information about you which does not directly identify you but which may correspond with you, your browser, or a particular device. This may include your internet protocol address, your internet service provider, information about cookies in your browser, geographic location, and your software and hardware attributes (e.g., browser and device type). We also automatically collect information about how you interact with our Website, including the duration of your visit, the actions you take, the pages you view, the time spent on our site, the top search terms used, and the most effective ad traffic campaign drivers. We use and disclose the information we automatically collect to learn more about how our Website and online resources are used and to otherwise improve and administer the site. We also use and disclose this information to enable us to deliver information and advertisements tailored to your interests and preferences, based on your use of the site. Please see the section titled “Cookies,” below, for more details.
2. HOW DO WE USE YOUR PERSONAL INFORMATION?
By providing your Personal Information, you agree that, where it is permitted by local law, we may use your Personal Information:
- to communicate with you, including by mail, telephone, facsimile, e-mail, mobile alerts and SMS text messaging;
- to notify you of our new products and services and to provide you with product news and updates, promotional materials or newsletters, tips, or other helpful information;
- to seek your views on our products and services;
- to monitor our regulatory compliance;
- to respond to your requests;
- to improve the content or personalize our communications;
- to create a profile about you to match you with education/awareness programs, collaboration opportunities or obtain services from you;
- to consider your application for employment;
- for our own administrative and quality assurance purposes, such as to perform data analysis to identify usage trends, determine the effectiveness of our promotional campaigns and general operation of the Website;
- to improve our level of service; and
- for other purposes that may be detailed on this Website.
When we collect your Personal Information, we will take reasonable steps to advise you of what Personal Information we are collecting, the purposes for which we are collecting the Personal Information and will use such Personal Information only for stated primary or related secondary purposes.
If you contact us regarding a product experience, we may use the Personal Information you provide to generate complaints or adverse event reports.
We may use your Personal Information for marketing-related activities, including to communicate with you about our products, services, and company and to invite your participation in engagement opportunities (e.g., surveys). You can unsubscribe from marketing communications by clicking the “Unsubscribe” link included in each message.
3. HOW DO WE SHARE YOUR PERSONAL INFORMATION WITH OTHERS?
Your privacy is very important to us. We may disclose your Personal Information and the data generated by cookies (discussed below) to certain third parties listed below, including third parties who provide us with various business services. We will not sell your Personal Information. We will not otherwise disclose your Personal Information without your consent, except where such disclosure is reasonably necessary for normal business operations and such disclosure is in accordance with all applicable data protection and privacy laws.
(a) Affiliates and Third Parties
(b) Legal Reasons
In certain circumstances, we may be asked to release your Personal Information in response to a court order, subpoena, search warrant, law or regulation. We plan to cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the Personal Information that they may receive. We also reserve the right to cooperate with law enforcement authorities in investigating and prosecuting users who violate our rules or engage in behavior that is illegal or harmful to individuals or the Personal Information we are responsible for. In addition, we may use or disclose your Personal Information as we deem necessary or appropriate: (1) under applicable law, including laws outside your country of residence; (2) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (3) to comply with subpoenas and other legal processes; (4) to pursue available remedies or limit damages we may sustain; (5) to protect our operations or those of any of our affiliates; (6) to protect the rights, privacy, safety or property of Zealand, our affiliates, you and others; and (7) to enforce our terms and conditions.
(c) Regulators and physicians
If you contact us regarding your experience in using one of our products, we may use the Personal Information you provide as necessary to submit complaint or adverse event reports to local and international health or pharmaceutical regulators, and as otherwise required by law. We also may use the Personal Information to contact the prescribing physician to follow up regarding an unexpected event involving use of our product.
(d) Corporate Changes
We may disclose your Personal Information to a third party relating to a corporate reorganization, merger, sale, joint venture, assignment, co-promotional arrangement, transfer or other disposition of all or any portion of our business, assets or stock, including regarding any bankruptcy or similar proceedings.
(e) Data Collection Technologies
In addition to collecting your IP address, we may also use certain Data Collection Technologies on our Websites such as:
A cookie is a small piece of software that is inserted onto your computer browser or other web accessing device directories that permits our Website to recognize that you have been here before. This process is automatic and it is stored on your computer. If you do not want cookies to be stored on your computer, you can configure your browser not to accept cookies. Check in your browser’s help menu for instructions about how to deactivate cookies. You can also find instructions on how to manage cookies on the web, as well as information on how cookies work.
For such web use statistics, third-party cookies are used by Zealand. With such tools Website owners can improve their Websites. As a third party (for instance, Google) provides third-party cookies, these are not created by Zealand.
Zealand’s Website uses third-party cookies that are common on Websites. A cookie from Zealand cannot access information on the user’s computer, and it cannot spread computer viruses or any other harmful software. Cookies can identify an IP address but otherwise do not allow us to identify any individual user. If you do not wish to receive Cookies or wish to manage when you accept Cookies in general, you may set your browser to reject Cookies or to alert you when a Cookie is placed on your computer. Although you are not required to accept our Cookies, if you set your browser to reject Cookies, you may not be able to use all the features and functionality of the Website.
- Measure how often a visitor has been on the site and when the visitor’s first and last visit took place.
- Measure how much time a visitor spends on our Websites.
Zealand also uses data from:
- “Analytics” that employ cookies that provide information to us on how long a user spends on the Website and which browser the user has used. This cookie is deleted after 2 years. This time period is set out by Google.
- “Search” that provides similar data to Google Analytics, but this cookie is deleted as soon as the user closes the search session.
- YouTube. YouTube provides us with information on how long a video that is uploaded is viewed by a user and other details about the user’s general geographic location. It expires after 9 months.
ii. Internet tags. Occasionally, we may use Internet tags (also known as Web beacons, action tags, single-pixel GIFs, clear GIFs, invisible GIFs and 1-by-1 GIFs) on our Websites. Cookies and Internet tags are placed on different pages throughout our Websites. We also use them to measure responses to our Websites. We may deploy Cookies and Internet tags through our analytical service partners.
iii. Social Plugins. The Website may also use social plugins (e.g., the Facebook “Like” button) to enable you to easily share information with others. When you visit our Website, the operator of the social plugin may be able to place a Cookie on your computer, enabling that operator to recognize individuals who have previously visited our Website. For further details about the information shared via a social media plugin, you should refer to that social media Website’s privacy statement.
iv. Advertisers. We do not permit advertisers to display their advertisements on our Website.
v. Do not track (DNT). We do not respond to DNT signals offered by some browsers.
4. IS MY INFORMATION SENT TO OTHER COUNTRIES?
As a global company, Zealand conducts business in many countries. Permitted transfers of Personal Information to third parties or affiliates may include the transfer of data from one country to another, including countries where the laws provide different protection than your country. In such cases, we will ensure appropriate measures are taken to ensure adequate data protection in accordance with applicable laws.
If you have a general question about privacy or have a query related to the General Data Protection Regulation (GDPR), please use the general contact e-mail address and it will be forwarded to person responsible for review.
The entity responsible for the processing of your personal information is:
Zealand Pharma A/S
Tel: +45 88 77 36 00
The contact details with regards to data privacy are as follows: DataPrivacy@zealandpharma.com
5. WHAT ARE MY PRIVACY CHOICES & RIGHTS?
You have rights and choices regarding Zealand’s processing of your Personal Information:
- Opt-in. When you access any interactive tool or service on the Website that collects Personal Information, you will be asked to affirmatively choose (“opt-in”) to provide the requested Personal Information. You may always choose not to provide the requested Personal Information.
- Manage email. You may elect to receive email updates about developments regarding Zealand. If you decide, at any later time, that you no longer wish to receive these emails, you may unsubscribe to any such contact list by using the “Unsubscribe” links within the electronic communication channel, or by sending an email entitled “Unsubscribe” to DataPrivacy@zealandpharma.com.
- Manage cookies. Most web browsers allow control of cookies through the browser settings. You can set your browser to notify you when you receive a cookie, which will enable you to decide if you want to accept it or not. However, if you do not accept a cookie, certain elements of the Website may not function correctly or completely.
- Access/review/update Personal Information. If you become aware that Personal Information we maintain about you is inaccurate, incomplete, misleading, irrelevant or out of date, or if you would like to access, update or review your information, you may contact us using the contact information below. We will attempt to provide the requested information or make requested changes to the extent allowable by applicable privacy or other laws. In any event, we will respond to you as soon as reasonably possible, to advise you of the outcome of your request.
- Transparency about sharing. We will advise you of the organizations (or types of organizations) to which we may normally disclose Personal Information, and we will provide you with contact information in the event you would like access to your Personal Information we hold about you or need to update your Personal Information or preferences.
- Remove Personal Information. You may request the removal or discontinuation of processing regarding previously provided Personal Information at any time using the contact information below. Please be aware that we may not comply with your request to amend or remove information that was provided to Zealand by a healthcare professional or a consumer regarding an adverse drug event.
Please note that some of the above rights are limited by applicable law and we have the right to collect, process and hold your Personal Information to perform our legal obligations (for example: data regarding an adverse drug event). We may require you to provide additional information necessary to confirm your identity before we comply with any request made by you.
You may always lodge a complaint with a data protection supervisory authority, e.g. The Danish Data Protection Agency, https://www.datatilsynet.dk/databeskyttelse/klage-til-datatilsynet
You can take steps to exercise your rights by contacting DataPrivacy@zealandpharma.com.
6. HOW DO YOU PROTECT MY PERSONAL INFORMATION?
We have implemented reasonable safeguards designed to prevent loss, misuse and unauthorized access, disclosure or modification of Personal Information provided or collected through the Websites. Unfortunately, no system or online transmission of data can be guaranteed to be 100% secure and you should always take appropriate security measures to protect your Personal Information, including ensuring that you have up-to-date antivirus software.
7. HOW DO YOU STORE MY PERSONAL INFORMATION? HOW LONG WILL YOU RETAIN MY PERSONAL INFORMATION?
We provide products and services around the world. Accordingly, we store and process Personal Information on Zealand’s servers, and the servers of third parties we hire to provide our services, worldwide. These servers may be located outside the country from which you interacted with Zealand. We retain your Personal Information for no longer than is necessary for the purposes for which it has been collected and in accordance with applicable laws and regulation.
8. LINKS TO OTHER SITES
9. OUR CHILDREN’S NOTICE
We recognize the importance of protecting the privacy of children. Our Websites are neither intended for children nor are they designed to attract child users. Our Websites, their content and our services are intended for users over the age of eighteen (18). We do not knowingly collect any personally identifiable information from children under age eighteen (18). When a user discloses Personal Information on the Websites, the user is representing to us that he or she is at least eighteen (18) years of age. If we learn a user under the age of eighteen (18) has volunteered personally identifiable information on our Websites, we will delete such information from our active databases.
10. YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.
California Supplemental Privacy Notice
Definition of Personal Information Under CCPA
California law defines ‘Personal Information’ to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the categories of personal information identified below if such information identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.
Most companies need to collect and share consumers’ Personal Information for everyday business purposes, marketing, and maintenance of the safety, security, and integrity of their Websites and other assets, to comply with legal and regulatory obligations, among other reasons. This supplemental notice provides the information required under the CCPA and applies to both Zealand’s online and offline activities.
The types of Personal Information we collect and disclose depends on your relationship with Zealand. Not all of the categories listed below may apply to you. If the nature of your relationship with Zealand changes, additional categories of Personal Information may also apply. In some cases, an additional data privacy notice may apply and will be provided to you.
CCPA Notice On Collection of Your Personal Information
Pursuant to the CCPA, we provide the following details regarding the categories of Personal Information about California residents (excluding business to business data) that may collect or disclose:
- Identifiers, such as name and government-issued identifier (e.g., Social Security number);
- Personal information, as defined in the California safeguards law, such as contact and financial information;
- Characteristics of protected classifications under California or federal law, such as age, gender, medical conditions, and marital status;
- Commercial information, such as transaction information and purchase history;
- Biometric information, such as fingerprints and voiceprints;
- Internet or network activity information, such as browsing history and interactions with our Websites;
- Geolocation data, such as device location;
- Audio, electronic, visual and similar information, such as call and video recordings;
- Professional or employment-related information, such as work history and prior employer;
- Education information subject to the federal Family Educational Rights and Privacy Act, such as student records and directory information; and
- Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
We collect this Personal Information directly from California residents themselves, as well as from joint marketing partners, public databases, providers of demographic data, publications, professional organizations, social media platforms, people with whom you are connected on social media platforms, caregivers, companies and other third parties that help us screen and onboard individuals for hiring purposes, and other third parties.
We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, for our employment purposes, and to otherwise accomplish our business purposes and objectives. Our business purposes and objectives include, for example, developing, improving, repairing, and maintaining our products and services; personalizing, advertising, and marketing our products and services; conducting research, analytics, and data analysis; maintaining our facilities and infrastructure; undertaking quality and safety assurance measures; conducting risk and security controls and monitoring; detecting and preventing fraud; performing identity verification; performing accounting, audit, and other internal functions, such as internal investigations; complying with law, legal process, and internal policies; maintaining records; and exercising and defending legal claims.
- We may share your Personal Information with your consent or as you direct. For example, we may share data with your doctor as part of programs in which you agree to participate.
- We may share your Personal Information with our affiliated companies, product co-promotion and co-marketing partners, which may only use your Personal Information for the purposes as we have agreed to.
- We may share your Personal Information with companies that provide services to us like health insurance companies or payroll companies. These companies are bound by law or contract to protect your Personal Information and only use your Personal Information the way we tell them to.
- We may also disclose your Personal Information where needed to sell or transfer business assets, to investigate legal issues, enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed support external auditing, compliance and corporate governance functions.
- We may also disclose your Personal Information if required by law, such as in response to a subpoena, or to comply with requirements of law enforcement agencies and courts in the United States and other countries where we operate.
- Please note that we may also disclose data about you that is called “de-identified” or “aggregated” data. This type of information does not identify who you are so it is not personally identifiable. For example, we may publish reports that contain aggregate and statistical data about our customers. These reports do not contain any data that would let somebody contact, locate, or identify you.
Your Rights Under CCPA
California residents have certain rights with respect to Zealand’s use and disclosure of personal information about California consumers:
- Right of Access | Right to Notice. If you are a California resident, you have the right to request that Zealand disclose to you the categories of personal information we have collected about you, the categories of sources from which the Personal Information is collected, the business purpose or commercial purpose for collecting or selling Personal Information, the categories of third parties with whom we share Personal Information, the categories of Personal Information we have disclosed about you for a business purpose. You also have the right to request that we provide you with a copy of the specific pieces of Personal Information we have collected about you in the preceding 12 months.
- Right to Deletion. If you are a California resident, you have the right to request that Zealand delete the Personal Information we collect from you. However, in certain situations we are not required to delete your Personal Information, such as when the information is necessary in order to complete the transaction for which the personal information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our Websites or other online services, or to otherwise use your Personal Information internally in a lawful manner that is compatible with the context in which you provided the information
- Right Not to Be Subject to Discrimination. Zealand shall not discriminate against a consumer because the consumer exercised any of the consumer’s California rights described above.
To exercise any of the rights described above, you can:
- Call us at 88 77 36 00; or
- Email us at email@example.com
When we receive your request, we will tell you within 10 calendar days that we received your request, and within 45 business days (and after we verify your request, as set forth below), we will respond to your request. If you ask Zealand to delete your Personal Information, we will either respond that we will do so, or we will let you know that we will not due to a specified reason. For example, there may be a law that we have to follow that won’t permit us to delete your Personal Information.
A verifiable consumer request is one made by any individual who is:
- the consumer who is the subject of the request,
- a consumer on behalf of the consumer’s minor child, or
- by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer.
If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of the consumer when submitting a Request to Know or Delete.
In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive PI to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. PI collected from an individual to determine whether a request is a verifiable consumer request may not be used or disclosed for any other purpose except as required by law.
We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
California Children’s Privacy
Zealand Websites and applications are not intended to attract children, and we do not knowingly collect any Personal Information of anyone under the age of 16. If you believe your child is using our Website, please contact us so we can investigate and delete any inappropriate data. We do not sell your PI and do not have actual knowledge that we have sold personal information of minors under age 16. Call us at 88 77 36 00 or email us at firstname.lastname@example.org.
11. NOTICE TO EUROPEAN USERS
Legal bases for processing. The legal bases for our processing of your personal information are described in the table below.
To provide the Services
Where we have a contract governing this processing purpose, the processing is necessary to perform that contract, or necessary to take steps that you have requested prior to entering into the contract.
In other cases, these processing activities are necessary to protect your, or another person’s, vital interests.
To perform and administer clinical trials, research and product-improvement activities
Where we have a contract governing this processing purpose, the processing is necessary is perform that contract, or necessary to take steps that you have requested prior to entering into the contract.
Where we process sensitive personal data in connection with this processing purpose, the processing is necessary for scientific or historical research purposes or statistical purposes.
In all other cases, these processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To operate our Websites and mobile apps;
To communicate with you;
To create anonymous data for analytics;
For compliance, fraud prevention and safety
These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with regulatory monitoring and reporting obligations;
To comply with law
Processing is necessary to comply with our legal obligations.
Use for new purposes
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 satisfying any legal, accounting, or reporting requirements and in accordance with applicable laws and regulations.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information.
You can submit these requests by email to DataPrivacy@zealandpharma.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfer
If we export your personal data from the European Economic Area (“EEA”) to a country outside of it and are required to apply additional safeguards to that personal data under European data protection legislation, we will do so. Such safeguards may include applying the European Commission model contracts for the transfer of personal data to third countries described here*. Please contact us for further information about any such transfers or the specific safeguards applied.