Privacy Notice

Vigilance, medical information and product complaints

Respecting your Right to Privacy and Retaining your Trust is Important to Seefunge

Seefunge is committed to be a trusted steward of your personal information (please see the “personal information” section below for an explanation of what is considered your personal information). We collect and use this personal information to meet your expectations when you engage with us and continue to improve our business. Today, we rely on personal information to incorporate state-of-the-art technology into our products and services, improve quality and safety, and align with the interests of the healthcare community, our consumers, and other stakeholders.

Our Commitment to You:

We are committed to being transparent about our management of your personal information and we take all necessary steps to ensure our practices, procedures and activities comply with any applicable requirements, including all applicable privacy laws, and with this Privacy Notice.

What this Privacy Notice Covers

This Privacy Notice describes how Seefunge Pharmaceutical Technology Co., Ltd.  and its affiliates and subsidiaries (collectively, “Seefunge”) use and disclose the personal information collected from reporters, enquirers and patients and describes your rights pertaining to how we use your personal information. 

 

TABLE OF CONTENTS

What is Personal Information?
What Personal Information Do We Collect and How do We Use It?
Who Is the Controller of Your Personal Information?
When and to Whom Do We Disclose Your Personal Information?
For How Long Do We Keep Your Personal Information?
When and How Do We Transfer Your Personal Information Between Countries?
Your Privacy Rights
How Do We Protect Your Personal Information?
Children's Personal information
California Privacy Policy
Links to Third-party Websites
Changes to This Privacy Notice
Contact details of Seefunge as Controller

 

What is Personal Information?

Personal information is any information relating to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

What Personal Information Do We Collect and How do We Use It?

Purpose and Categories of Personal Information We collect and use your personal information for various purposes, as described below:	Legal Basis The lawful grounds on which we may collect, process, and/or disclose your personal information.	Our Legitimate Interests What is the important benefit or requirement to process personal information?
Tracking and Monitoring Adverse Events and Pharmacovigilance.	Some specified parts of our websites may collect personal information  related to  adverse events or other activities related to  pharmacovigilance. This personal information is very important for public health reasons and will  be used for the detection, assessment, understanding, and prevention of adverse events or other medical concerns	We collect and process your personal information  to comply with our legal obligations including in certain cases being required to report the gathered information to regulatory authorities.
Follow-up contact (the patient or patient’s doctor or other reporter). (Patient identification data or demographic information, information on the case/adverse event, reporter name and contact details)	Name, contact details, and affiliations/profession of the reporting individual.  Patient identification data, such as the number or identification code contained in the adverse event report form, or demographic information (e.g. initials, age, year or date of birth, gender, race), Data on the state of health: prescribed therapies, test results, the nature of the adverse event, personal or family history, illness or accompanying events, risk factors, and information on how the treatment was conducted. In addition, if it is necessary to assess the adverse event, we may also collect and process: Information about the person's origin and kinship, Data on the work performed, Information on the use/consumption of tobacco products, alcohol, drug, Information on lifestyle, habits and life behaviors, including, for example, addictions, physical activity undertaken (intensity, frequency, duration), diet and eating habits. We may collect other additional personal information related to health and medical history of the individual experiencing an adverse event if required to evaluate, classify and assess the vigilance case.	Our legitimate interest (Efficient and direct communication with the reporter) Compliance with a legal obligation to which Seefunge is subject.
Comply with legal pharmacovigilance obligations imposed on Seefunge by European and local safety vigilance laws and regulations, ensure compliance with high standards of quality and safety of health care and medicinal products, devices or products in accordance with applicable data protection laws.	Patient identification data, data on case and analysis performed, health data.	Compliance with a legal obligation to which Seefunge is subject
Respond to your inquiries ()	Name, contact details, and affiliations/profession, health data related to the medical inquiry	Our legitimate interest (inform and educate on our products and  related medical conditions)  Explicit consent
Report data to regulatory authorities	Personal Information provided in the inquiry	Compliance with a legal obligation or industry codes to which Seefunge is subject.
Report data to regulatory authorities and comply with legal obligations and Management of product complaints, follow up on such requests and to maintain the information in a product complaints database for reference	Name, contact details and affiliation/profession of the individual reporting the complaint.  Regarding the individual affected by the product complaint we may collect: Patient identification data, such as the number or identification code contained in the adverse event report form, or demographic information (e.g. initials, age, year or date of birth, gender, race), Data on the state of health: prescribed therapies, test results, the nature of the adverse event, personal or family history, illness or accompanying events, risk factors, and information on how the treatment was conducted. In addition, if it is necessary to assess the product complaint, we may also collect and process: Information about the person's origin and kinship, Data on the work performed, Information on the use/consumption of tobacco products, alcohol, drug, Information on lifestyle, habits and life behaviors, including, for example, addictions, physical activity undertaken (intensity, frequency, duration), diet and eating habits. We may collect other  additional personal information related to health and medical history of the individual affected by the product complaint if such information is relevant to evaluate, classify and assess the product complaint.	Compliance with a legal obligation to which Seefunge is subject. Our legitimate interest.(More efficient management of these complaints) and Exercise and defense of legal claims).
Reasons of public interest in the area of public health	Health data.	Reasons of public interest in the area of public health

 

Who Is The Controller Of Your Personal Information

Identity of the Controller 

Seefunge Pharmaceutical Technology Co., Ltd. is responsible for the processing of your personal information as it decides why and how it is processed, thereby acting as the “Controller”. 

 

When and to Whom Do We Disclose Your Personal Information?

The personal information we collect from and about you may be disclosed to third parties for the purposes described in this Privacy Notice:

1. to the subsidiaries and affiliates within the Seefunge group of companies,
2. to third-parties that provide services to us, such as those that fulfill requests for personal information, answer calls, administer programs or projects, assist in research and development, deliver advertisements or other communications or host databases or servers,
3. to business partners who offer products or services jointly with Seefunge,
4. to permit a third-party business partner to deliver marketing communications or products that may be of interest to you, subject to any choices you have expressed or applicable consent requirements
5. to identify you to any person to whom you send messages through the Services,
6. to any person you direct us to contact,
7. by you, on message boards, chat, profile pages, blogs, and other services to which you post personal information and materials. Because any personal information you post may become public, we urge you to be careful when deciding to disclose any personal information on or through the Services,
8. as required by law, such as to law enforcement, to health authorities to report possible adverse events, during government inspections or audits, as ordered or directed by courts or other governmental agencies, or in order to comply with a subpoena or other legal process,
9. when we believe in good faith that disclosure is necessary to protect legal rights or the security or integrity of our operations or the Services, protect your safety or the safety of others, investigate fraud, a breach of contract, or a violation of law, respond to a government request, or allow us to pursue available remedies or limit the damages that we may sustain, and
10. to third parties, advisors, and other entities to the extent reasonably necessary for development of or to proceed with the negotiation or completion of a corporate or commercial transaction, including a reorganization, merger, acquisition, joint venture, sale or other disposition of all or a portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

 

For How Long We Keep Your Personal Information?

Unless indicated otherwise in this Privacy Notice, the criteria we use to decide how long we retain personal information include: (i) whether we need your personal information to perform a contract to which you are subject, to respond to your questions or provide to you with the required service or support, (ii) whether there is a legal obligation to which we are subject, or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations). 

We delete personal information when it is no longer necessary to retain it for the purposes described in this Privacy Notice, or when required to do so by applicable law. 

Personal data retained as part of a medical information inquiry are archived 30 days after receipt and deleted 365 days after receipt. 

 

When and How Do We Transfer Your Personal Information Between Countries?

Due to the global nature of our business, your personal information may be transferred to or accessed by Seefunge subsidiaries or affiliates or Seefunge’s third-parties around the world. Of course, when we do so, we comply with applicable laws on the transfer of personal information between countries.

For example, when we transfer personal information from the European Economic Area (EEA), the United Kingdom (UK), and Switzerland to Seefunge-affiliated companies in other countries or Seefunge third-parties in other countries which may have different standards of data protection to the EEA, UK and Switzerland, such transfers are governed by Contractual Clauses, where appropriate, or other legally recognized measures that adequately protect the personal information. 

 

Your Privacy Rights

You may have the following rights in relation to your personal information, in accordance with the applicable data protection laws:

1. To withdraw your consent at any time, if we are processing your personal information on the basis of consent as opposed to other valid legal grounds for processing,
2. To access and/or update the personal information that Seefunge holds about you,
3. To request that Seefunge rectify or erase your personal information,
4. To request that Seefunge restrict the way it processes your personal information,
5. To object to the way Seefunge processes your personal information,
6. Where you request us to do so, to transfer your personal information either back to you or to another individual or entity, and
7. The right to express your point of view in the event of any individual decision having a significant impact on you being made by automated means about you and to request that such automated decision be reviewed by a human.

If you wish to exercise one of these rights, please email us at info@seefunge.com. You also have the right to lodge a complaint with a data protection authority in your country of residence.

We will require appropriate evidence of your identity or to be provided with additional relevant personal information based on your relationship with us before we are able to act on your request in circumstances where the personal information we have in our systems is insufficient detail to identify you or reply to your request. 

If you would like, you can enable someone else to exercise your rights under this Privacy Notice on your behalf. We would call this person your Personal Representative. If your Personal Representative sends us a request to exercise your rights under this Privacy Notice, we may ask them to provide evidence that you gave them permission to make the request on your behalf. In that scenario, we may also seek to verify your identity directly and/or ask you to confirm the Personal Representative’s ability to act on your behalf.

 

How Do We Protect Your Personal Information?

We have appropriate technical and organizational measures designed to provide an adequate level of security and confidentiality for your personal information. 

These measures take into account:

(i) State of the art technology, (ii) The costs of implementation of such technical and organizational measures, (iii) the nature of the personal information, and (iv) the risks involved in the processing of that personal information.

The purpose of these measures is to protect your personal information against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing. 

Moreover, when handling your personal information, we:

(i) Only collect and process personal information which is adequate, relevant and not excessive, as required to meet the above purposes, and

(ii) Ensure that your personal information remains up to date and accurate.

For the latter, we may request you to confirm the details of the personal information we retain about you. You are also invited to inform us whenever there is a change in your personal circumstances so we can ensure your personal information is kept up-to-date.

 

Children's Personal information

We are committed to protecting the privacy of children and that is why we do not knowingly collect personal information from children under the age of 18 , unless permitted to do so by applicable law. If we learn that we have collected personal information directly from children through our Sites without being permitted to do so by applicable law, we will delete this information. 

 

California Privacy Policy

Individuals who are natural persons and residents of  the state of California, United States (collectively, “California Residents”) may learn  more about how we handle their personal information or about their privacy rights by please clicking here.

 

Links to Third-party Websites

This Privacy Notice applies only to the Sites that display or refer to this Privacy Notice. The Sites may contain links to third-party websites that are not under our control. We are not responsible for the collection, use, or disclosure of your personal information by such websites. We encourage you to review the privacy policies of all third-party websites to learn about how those third parties collect, use, and disclose your personal information. 

 

Changes to This Privacy Notice

We may update this Privacy Notice from time to time by posting a new Privacy Notice on our Sites. When we update this Privacy Notice, we will indicate when it was most recently updated by changing the “last updated” date. Unless otherwise indicated, updates to this Privacy Notice are effective immediately upon posting. If we make a material change to our Privacy Notice, we may take reasonable steps to notify you, for example, by posting a banner or pop-up notice on our Sites.

 

Contact details of Seefunge as Controller

If you have any questions about our Privacy Notice, please contact us via email at info@seefunge.com.

 

November 15, 2024