Privacy Policy | GAIN Connect

GALDERMA INDIA PRIVATE LIMITED PRIVACY NOTICE

SCOPE OF THIS NOTICE

Please read this Privacy Notice (“Notice”) carefully to understand our policies and practices regarding your Personal Data (hereafter referred to as“Personal Data”) and how we treat it. This Notice applies to individuals who interact with Galderma services as set out below(“you” or “your”). This Notice explains how your Personal Data is collected, used, and disclosed by Galderma India Private Limited  (“Galderma”, “We”, "Us”, or “our”) in its capacity as a Data Fiduciary under the Digital Personal Data Protection Act, 2023 (“DPDPA”). It also tells you how you can access and update your Personal Data and make certain choices about how your Personal Data are used. "Galderma” and “Galderma Group” refer to Galderma India Private Limited, and its affiliates, where applicable.

This Notice covers both our online and offline data collection activities, including Personal Data that We collect through our various channels such as websites, third-party social networks and through our vigilance activities.

If you do not wish to provide necessary Personal Data to Us (We will indicate to you when this is the case, for example, by making this information clear in our registration forms), We may not be able to provide you with our goods and/or services. This Notice can change from time to time (see Section 9 – Changes to this Notice).

This Notice provides important information in the following areas:

SOURCES OF PERSONAL DATA
PERSONAL DATA THAT WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
COOKIES/SIMILAR TECHNOLOGIES  & GOOGLE FONTS
USES MADE OF YOUR PERSONAL DATA
DISCLOSURE OF YOUR PERSONAL DATA
RETENTION OF YOUR PERSONAL DATA
DISCLOSURE, STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA
ACCESS TO YOUR PERSONAL DATA
YOUR RIGHTS
CHANGES TO THIS NOTICE
CONTACT US

1. SOURCES OF PERSONAL DATA

This Notice applies to Personal Data that We collect from or about you, through the methods described below (see Section 2), from the following sources:

Galderma websites. Websites operated by or for Galderma, including sites that We operate under our own domains/URLs and mini-sites that We run on third-party social networks such as Facebook ("Websites").

E-mail, text and other electronic messages.Interactions with electronic communications between you and Galderma.
IQVIA OneKey Web Authentication. The GAIN Portal uses IQVIA’s OneKey authentication service to ensure that everyone who accesses the site is an authorised healthcare professional in their relevant jurisdiction. Use of IQVIA’s OneKey Web Authentication service (www.owa-secure.com) is subject to the OneKey Web Authentication Terms of Use available here: https://www.owa-secure.com/sso/login?_flowId=cgu-webflow provided by IQVIA (www.iqvia.com). The verification of username and password is done directly on IQVIA’s servers. We have no possibility to read your username or password. For the “OneKey” service that we are using, only a random string of characters is passed, which serves to record repeat visits to our website. The character string does not allow any conclusions to be drawn about you as a user. No personal data will be passed on to us.
E-mail, text and other electronic messages. Interactions with electronic communications between you and Galderma.
Data We create. In the course of our interactions with you, We may create Personal Data about you (e.g. records of your interactions with our Websites).
Data from other sources. Third-party social networks (e.g. such as Facebook, Google), market research (if feedback not provided on an anonymous basis), events, public sources and data received when We acquire other companies; where Personal Data is collected from third parties or public sources, We will provide you with this Notice where required in accordance with the DPDPA.

2. PERSONAL DATA THAT WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

Depending on how you interact with Galderma (online, offline, over the phone, etc.), We collect various types of information from you, as described below.

Personal contact information. This includes any information you provide to Us that would allow Us to contact you, such as your name, postal address, e-mail address, phone number or fax number.
Professional information. This includes any information you provide to Us relating to your profession and/or qualifications, but also information found in your curriculum vitae, information about your current and past interactions with Galderma and about your participation in events, conferences and scientific studies, and other personal information that you may provide about yourself and your professional activities.
Information from computer/mobile device. This includes any information about the computer system or other technological device that you use to access one of our Websites, such as the Internet protocol (IP) address used to connect your computer or device to the internet, operating system type, and web browser type and version. If you access a Galderma Website via a mobile device such as a smartphone, the collected information will also include, where permitted, your phone’s unique device ID, advertising ID, geo-location, and other similar mobile device data where permitted under applicable law.
Websites/communication usage information. As you navigate through and interact with our Websites or newsletters, We use automatic data collection technologies to collect certain information about your actions. This includes information such as which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages. This information is captured using automated technologies such as cookies and web beacons, and is also collected through the use of third-party tracking for analytics and advertising purposesin accordance with applicable law.
Consumer-generated content. This includes any content that you create and then share with Us on third-party social networks or by uploading it to one of our Websites, including the use of third-party social network apps such as Twitter. Examples include photos, videos, personal stories, or other similar media or content. Where permitted, We collect and publish consumer-generated content in connection with a variety of activities, including contests and other promotions, website community features, consumer engagement, and third-party social networking.
Third-party social network information. This includes any information that you share publicly on a third-party social network or information that is part of your profile on a third-party social network (such as Twitter) and that you allow the third-party social network to share with Us. Examples include your basic account information (e.g. name, email address, gender, birthday, current city, profile picture, user ID, list of friends, etc.) and any other additional information or activities that you permit the third-party social network to share. We receive your third-party social network profile information (or parts of it) every time you download or interact with a Galderma web application on a third-party social network such as Twitter, or every time you use a social networking feature that is integrated within a Galderma site (such as Facebook Connect) or every time you interact with Us through a third-party social network. This Notice does not apply to the third-party social networks. To learn more about how your information from a third-party social network is obtained by Galderma, or to opt-out of sharing such social network information, please visit the website of the relevant third-party social network.

3. COOKIES/SIMILAR TECHNOLOGIES & GOOGLE FONTS

Cookies/Similar Technologies. Please see our Cookie Policy to learn how you can manage your cookie settings and for detailed information on the cookies We use and the purposes for which We use them.

We also use Google Fonts, which is a web font service provided by Google that enables the optimisation of our Websites providing the correct fonts. We host Google Fonts locally without ever having to connect to a Google Server and thus collect IP addresses.

4. USES MADE OF YOUR PERSONAL DATA

The following paragraphs describe the various purposes for which We collect and use your Personal Data, and the different types of Personal Data that are collected for each purpose. Please note that not all of the uses below will be relevant to every individual.

What We use your Personal Data for	Our reasons
Patient/Consumer service. We use your Personal Data for consumer service purposes, including responding to your enquiries. We collect information about how our Websites are used to be able to provide you with certain content and improve it based on the feedback We receive.  Responding to your inquires typically requires the use of certain personal contact information and information regarding the reason for your inquiry (e.g. responding to any questions or concerns you may have concerning your use of the products, order status, technical issue, product question/complaint, general question, etc.).	Improving and developing new products and services Optimising service efficiency Fulfilling contractual obligations
Marketing efforts. We process your Personal Data to undertake and improve our marketing efforts in relation to the products and the Website.	Improve marketing activities
Optimisation of products and services We process your Personal Data to optimise the products and services. We will also share your personal data with Galderma India Private Limited or its affiliate companies (“Galderma”) who are the manufacturer of the products and for analysing the statistics as per business need.	Legitimate business purposes, including product and service optimisation Internal analytics and statistical analysis
Contacting you and conducting advertising on third-party social networks. We use your Personal Data when you interact with third-party social networking features, such as “Like” functions, to serve you with advertisements and engage with you on third-party social networks. You can learn more about how these features work, the profile data that We obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third party social networks.	Working out which of the products and services may interest you and telling you about them Defining types of consumers for new products or services
Legal reasons or merger/acquisition. In the event that Galderma or its assets are acquired by, or merged with, another company including through bankruptcy, We will share your Personal Data with any of our legal successors. We will also use your personal data to comply with our legal obligations (e.g., tax law and product safety obligations). We will disclose your Personal Data to third parties (i) when required by applicable law; (ii) to establish or respond to legal proceedings; (iii) in response to a request from a competent law enforcement agency; (iv) to protect our rights, privacy, safety or property, or the public; or (v) to enforce the terms of any agreement or the terms of our Website.	Compliance with legal obligations Protect our assets and staff
For Website usage analytics We may also collect and process information about your visit to our Website, such as the pages you visit, the website you came from and the searches you perform. We may use such information to help improve the contents of the site and to compile aggregate statistics about people using our site for our internal usage statistics and market research purposes. In doing this, We may install "cookies" that collect the domain name of the user, your internet service provider, your operating system, and the date and time of access.	Improve the efficacy of our Website
Internal records We process your Personal Data to maintain our internal records.	Compliance with legal obligations Defence of legal claims

In case We want to use your Personal Data for purposes unrelated to those described in this Notice, We will first notify you and, where required, offer you a choice as to whether or not We may use your Personal Data in this manner.

5. DISCLOSURE OF YOUR PERSONAL DATA

In addition to the Galderma entity mentioned in the ‘Contact Us’ section (see Section 10), We share your Personal Data with the following types of organisations:

Other Galderma subsidiaries and affiliates within India/Galderma its subsidiaries and affiliates worldwide. Galderma/Galderma and its subsidiary companies may share your Personal Data amongst and between each other for the purposes set forth in this Notice.

Service providers. These are external companies that We use to help Us run our business (e.g. website operation, support services, website development, data analysis, CRC, etc.). Service providers, and their selected staff, are only allowed to access and use your Personal Data on our behalf for the specific tasks that they have been requested to carry out, based on our instructions, and are required to keep your Personal Data confidential and secure.

Third-party recipients using Personal Data for legal reasons or due to merger/acquisition. We will disclose your Personal Data to third parties for legal reasons or in the context of an acquisition or a merger and will require such third parties to use and protect your Personal Data consistent with this Notice. We may also share your Personal Data with third parties that were formerly wholly or partly included in the Galderma family of companies to whom We provide services during a transition period following separation (see Section 4 for details).

6. RETENTION OF YOUR PERSONAL DATA

Galderma takes every reasonable step to ensure that your Personal Data are only processed for the minimum period necessary for the purposes set out in this Notice. We may retain your Personal Data for a longer period in the event of a complaint or if We reasonably believe there is a prospect of litigation in respect of our relationship with you. In case your information is no longer required for any purpose of lawful processing, then We will ensure it is disposed of in a secure manner.

In some circumstances, We may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case We may use this information indefinitely without further notice to you.

7. DISCLOSURE, STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA

We use appropriate measures (described below) to keep your Personal Data confidential and secure. Please note, however, that these protections do not apply to information you choose to share in public areas such as third-party social networks.

People who can access your Personal Data. Your Personal Data will be processed by our authorised staff or agents, on a need to know basis, depending on the specific purposes for which your Personal Data have been collected.

Measures taken in operating environments. We store your Personal Data in operating environments that use reasonable security measures to prevent unauthorised access. We follow reasonable standards to protect Personal Data. The transmission of information via the internet is, unfortunately, not completely secure and although We will do our best to protect your Personal Data, We cannot guarantee the security of the data during transmission through our Websites.

Transfer of your Personal Data. The storage as well as the processing of your Personal Data as described above may require that your Personal Data are ultimately transferred/transmitted to, and/or stored at, a destination outside of your country of residence. This may happen if any of our servers are from time to time located in a country other than the one you are based in, or one of our service providers is located in a country other than the one you are based in. Where Personal Data is transferred outside India, we will ensure that reasonable security safeguards are applied and that the transfer complies with the requirements of the DPDPA and any government notifications issued under it.

8. YOUR RIGHTS

You may have the following rights:

(a) To withdraw consent at any time, where applicable, and

(b) To access and/or update the Personal Data that Galderma holds about you,

(c) To request that Galderma rectify or erase your Personal Data,

(d) To nominate an individual to act on your behalf in the event of your death or incapacity.

(e) Any other rights available to you under law

When We send you marketing and promotional content through email, We make best efforts to provide you with the ability to opt-out of such communications by using the opt-out instructions provided in such emails.

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 Data We have in our systems is insufficient to identify you or reply to your request. If you are submitting a request on behalf of someone else, it may be necessary that We verify your authority to submit such a request. You may therefore be asked to provide signed confirmation that you are permitted by the data subject or by law to submit such request.

9. CHANGES TO THIS NOTICE

If We change the way We handle your Personal Data, We will update this Notice. We reserve the right to make changes to our practices and this Notice at any time, please check back frequently to see any updates or changes to our Notice.

10. CONTACT US

To exercise your privacy rights, please submit a relevant request using our Data Subject Request Webform.

To ask questions or make comments on this Notice and our privacy practices or to make a complaint about our compliance with applicable privacy laws, please contact our Data Privacy Office via email at: https://www.galderma.com/in/contact-us or in writing to Galderma India Private Limited, 33rd floor, Commerz III, International Business Park, Oberoi Garden City, Opp. Western Express Highway, Goregaon East, Mumbai-400063, Maharashtra, India

You may also contact our Grievance Officer, whose contact details are the following: [IN_PVmailbox@galderma.com  ]

We will acknowledge and investigate any complaint about the way We manage Personal Data (including a complaint that We have breached your rights under applicable privacy laws).

Last Updated 20 December 2024