Privacy Policy

1. WHO WE ARE AND HOW YOU CAN CONTACT US

UCB” or “we” means UCB Pharma Limited, a limited liability company with its registered office at 208 Bath Road, Slough, Berkshire, SL1 3WE.

As the controller, i.e. the legal entity that decides on the why and how information relating to you (“personal data”) is collected and processed in the context of this www.mypatchandme.co.uk patient support program (the “Programme”) website (the “Website”). We respect your right to privacy. We will only process your personal data as described in this www.mypatchandme.co.uk Privacy Policy (the “Policy”) and in accordance with the relevant data protection legislation, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation or “GDPR”).

At UCB we have a data protection officer (DPO), who can be contacted by any of the following means for any privacy-related questions, including regarding how we collect, store and use your personal data:

  • E-mail:                dataprivacyuk@ucb.com ; or
  • Regular mail:     UCB Pharma LtdTo the attention of the data protection officer208 Bath RoadSlough, Berkshire SL1 3WE, United Kingdom

 

2. THE REASON BEHIND THIS PRIVACY POLICY

The Policy governs the collection, use and retention by UCB of personal data relating to your use of the Website. This Policy applies to all Website users.

The Policy consists of five main components and informs you about:

  1. Who we are and how you can contact us;
  2. The reason behind this Policy;
  3. The purposes for which we process your personal data and the related legal basis under the GDPR;
  4. What your rights are in relation to the personal data we hold about you and how you can exercise them; and
  5. Further details on how we process (including share) your personal data.

This Policy may be updated periodically to reflect changes in our personal data processing practices. In that case we will post a prominent notice on the Website to inform you of any significant changes.

 

3. THE PURPOSES FOR WHICH WE PROCESS YOUR PERSONAL DATA AND APPLICABLE LEGAL BASIS

The table below indicates per purpose the categories of personal data we collect and process about you, the source from which we obtained such information, on what legal basis, how long we retain it and who we share your personal data with.

MyPatchandMe Website Users

1. In order to make the Website and its content available to you, UCB:

Collects the following personal data about you:
  1. Electronic identification data (*)
  2. Information collected through cookies (*)
Failure to provide the personal data with an (*) may result in (some features of) the Website not being accessible
Receives this personal data from: You, through the device(s) you use to access the Website
Retains (**) your personal data for: See our Cookie Policy
Shares your personal data with: UCB subsidiaries/affiliates and third party processors (as detailed in Section 5.A)
Relies on the following GDPR legal basis:

(i) Processing necessary for performance of a contract with you (including regarding the use of necessary cookies),

(ii) For other cookies see further below for the applicable legal basis and our Cookie Policy for more information

2. In order to enable:

  1. Application monitoring (e.g. checking whether the Website and optional services are up and running);
  2. Content monitoring (e.g. checking whether the services offered in the framework of the Programme are used and, if so, which services in the Programme are used); and
  3. The support and improvement of Website functionality (including making it more intuitive) and our service offering and to better understand usage patterns

We use cookies (combined with other information as outlined below) that allow us to evaluate - on an aggregate level - use made of our Website and how users (including yourself) access different features of our Website. In that context, UCB:

Collects the following personal data about you:
  1. Electronic identification data (*)
  2. Information collected through cookies (*)
  3. The data collected in Sections 6 – 11 of this table, together with aggregated feedback if you have responded to online surveys about the Programme.

Personal data about your usage and the proper functioning of the Website during such use will be aggregated into summary reports (statistics).

Failure to provide the personal data with an (*) may result in (some features of) the Website not being accessible
Receives this personal data from:

You, through the device(s) you use to access the Website

Our third party service providers (through the use of cookies)

Retains (**) your personal data for:

See our Cookie Policy

For any other information listed above, a maximum duration of 2 years

Shares your personal data with: UCB subsidiaries/affiliates and third party processors (as detailed in Section 5.A)
Relies on the following GDPR legal basis: For those cookies that require your consent, processing based on your consent (see Cookie Policy for more information). Otherwise, processing necessary for the purpose of the legitimate interests pursued by UCB to manage the Website and services and verify its proper functioning in light of its use and to improve the Website, Programme and associated services. To this end, UCB strives to maintain a fair balance between its need to process your personal data and the preservation of your rights and freedoms, including the protection of your privacy. For more information or if you have any questions regarding how we assess this balance, please contact us through any one of the channels set out under Section 1 - “Who we are and how you can contact us”

3. In order to maintain Website security (including the detection and prevention of malicious activities or invalid traffic on the Website), UCB:

Collects the following personal data about you:
  1. Electronic identification data (*)
  2. Information collected through logfiles (*)
Failure to provide the personal data with an (*) may result in (some features of) the Website not being accessible
Receives this personal data from: You, through the device(s) you use to access the Website
Retains (**) your personal data for: See our Cookie Policy
Shares your personal data with: UCB subsidiaries/affiliates and third party processors (as detailed in Section 5.A)
Relies on the following GDPR legal basis: For those cookies that require your consent, processing based on your consent (see Cookie Policy for more information). Otherwise, processing necessary for the purpose of the legitimate interests pursued by UCB to protect its IT infrastructure and maintain the security of its business assets. To this end, UCB strives to maintain a fair balance between its need to process your personal data and the preservation of your rights and freedoms, including the protection of your privacy. For more information or if you have any questions regarding how we assess this balance, please contact us through any one of the channels set out under Section 1 - “Who we are and how you can contact us”

4. In order to enable UCB to comply with its legal (including but not limited to pharmacovigilance) obligations, UCB:

Collects the following personal data about you:
  1. In relation to pharmacovigilance obligations: patient’s details as well as health data, including information regarding adverse event (seriousness, date and unique identification number)(*)
  2. Any other legally required information (*)
Failure to provide the personal data with an (*) may prevent UCB from complying with its obligations in accordance with applicable laws
Receives this personal data from: You
Retains (**) your personal data for: For as long as is legally required
Shares your personal data with:

(i) Relevant regulatory and government agencies

(ii) UCB subsidiaries/ affiliated companies and third party processors (as detailed in Section 5.A)
Relies on the following GDPR legal basis: Compliance with our legal obligations. 

5. In order to enable UCB to respond to your online queries submitted via the UCBCares email address, UCB:

Collects the following personal data about you:
  1. E-mail address
  2. Any other personal data you include in the email (*)
Failure to provide, where required, the personal data with an (*) may prevent UCB from adequately responding to your query or request
Receives this personal data from: You
Retains (**) your personal data for:

A maximum duration of two years

Shares your personal data with:

UCB subsidiaries/ affiliated companies and third party processors (as detailed in Section 5.A)

Relies on the following GDPR legal basis:
  1. Processing necessary for performance of a contract with you
  2. Processing based on your consent for any health-related data you provide
  3. Compliance with our legal obligations for any adverse event information you provide.
6. In order to enable you to register for and participate in the Programme and create a log-in, authenticate and manage your profile, settings, preferences and consents via our Website, UCB:
Collects the following personal data about you:
  1. Credentials for login:
  • email address (*)
  • password (*)
  1. Personal details:
  • first name (*)
  • last name (*)
  • electronic consent via tick box (*)
  • date of electronic consent via tick box (*)
  1. Health data:
  • Whether you have been on Neupro for less than 3 months or more than 3 months (*)

Failure to provide the personal data with an (*) will result in (some features of) the patient support services not being accessible

Receives this personal data from: You
Retains (**) your personal data for: A maximum duration of 2 years
Shares your personal data with: UCB subsidiaries/ affiliated companies and third party processors (as detailed in Section 5.A)
Relies on the following GDPR legal basis:
  1. Processing necessary for performance of a contract with you
  2. Processing based on your consent for any health-related data you provide

7. In order to enable you to sign up to receive daily SMS patch application reminders UCB:

Collects the following personal data about you:
  1. Mobile phone number (*)
  2. Activation (opt-in) to receive patch application reminder via SMS (*)
  3. Preferred time for receipt of SMS messages morning (8am), midday (11am) or evening (5pm) (*)

Failure to provide the personal data with an (*)will result in the patch application reminders not being sent

Receives this personal data from: You
Retains (**) your personal data for: A maximum duration of 2 years
Shares your personal data with: UCB subsidiaries/ affiliated companies and third party processors (as detailed in Section 5.A)
Relies on the following GDPR legal basis:

Processing based on your consent

8. In order to enable you to sign up to receive weekly SMS motivational messages, UCB:

Collects the following personal data about you:
  1. Mobile phone number (*)
  2. Activation (opt-in) to receive motivational messages via SMS (*)
  3. Preferred day of the week for receipt of SMS messages Monday - Sunday (*)

Failure to provide the personal data with an (*) will result in the weekly motivational messages not being sent

Receives this personal data from: You
Retains (**) your personal data for: A maximum duration of 2 years
Shares your personal data with: UCB subsidiaries/ affiliated companies and third party processors (as detailed in Section 5.A)
Relies on the following GDPR legal basis: Processing based on your consent

9. In order to enable you to sign up to receive relevant email communications about the Programme, UCB:

Collects the following personal data about you:
  1. Email address (*)
  2. Electronic consent to receive email communication via tick box (*)
  3. Date of electronic consent via tick box (*)

Failure to provide the personal data with an (*) will result in emails highlighting relevant Programme  information not being sent

Receives this personal data from: You
Retains (**) your personal data for: A maximum duration of 2 years
Shares your personal data with: UCB subsidiaries/ affiliated companies and third party processors (as detailed in Section 5.A)
Relies on the following GDPR legal basis: Processing based on your consent

10. In order to enable you to sign up to receive Taking Care and Taking Control magazines by post, UCB:

Collects the following personal data about you:
  1. Your first name and surname
  2. Postal address details:
    • House number and Street (*)
    • City (*)
    • Postcode  (*)
    • Country (*)
  3. Activation (opt-in) to receive Taking Care and Taking Control magazines by post(*)

Failure to provide the personal data with an (*)will result in Taking Care and Taking Control magazines not being sent

Receives this personal data from: You
Retains (**) your personal data for: A maximum duration of 2 years
Shares your personal data with: UCB subsidiaries/ affiliated companies and third party processors (as detailed in Section 5.A)
Relies on the following GDPR legal basis: Processing necessary for performance of a contract with you

11. In order to enable you to sign up to receive email invitations and reminder pop-ups to participate in online surveys to provide feedback on the Programme and how it could be improved in the future in month 1, 3 & 6 of the six month service delivery, UCB:

Collects the following personal data about you:
  1. Email address (*)
  2. Activation (opt-in) to receive email invitations and reminder pop-ups to participate in online surveys in month 1, 3 & 6 of the six month patient support service delivery (*)

Failure to provide the personal data with an (*) will result in email invitations and reminder pop-ups to participate in online surveys in month 1, 3 & 6 of the six month patient support service delivery not being sent

Receives this personal data from: You
Retains (**) your personal data for: A maximum duration of 2 years
Shares your personal data with: UCB subsidiaries
Relies on the following GDPR legal basis: Processing based on your consent

 

(**) We will retain your personal data in accordance with the retention periods set out in the table above. These retention periods, included in our data retention policy, are dictated by:

  • Applicable statutory/legal requirements;
  • Industry guidelines, and
  • For those data categories for which no express statutory or legal requirements apply, certain other determining factors such as the need to prove or enforce a transaction or contract, enforce our policies, etc.

We will delete your personal data once the above mentioned retention periods will have expired or if you object to or withdraw your consent to our processing of your personal data (to the extent such processing is based on your consent), except where we need to hold on to such data for the establishment, exercise or defense of legal claims, for the protection of the rights of another natural or legal person, for compliance with a European or European Member State legal obligation which requires such further processing or where we need to prove or enforce a transaction or contract or enforce our policies.

 

4. YOUR RIGHTS AND HOW YOU CAN EXERCISE THEM

4.A. Your rights

Right to access

You have the right to obtain confirmation from us as to whether or not we process personal data concerning you, and if so, the right (as far as this does not adversely affects the rights and freedoms of others) to obtain a copy of your personal data from us. For more information, please check Section 4.B “How to exercise your rights”.

Right to rectification

You have the right to ask us to rectify without undue delay any inaccurate personal data concerning you. You can also ask us to complete incomplete personal data regarding you by providing us with a supplementary statement containing such additional information. For more information, please check Section 4.B “How to exercise your rights”.

Right to erasure

You have the right to ask us to erase without undue delay personal data concerning you, where one of the following grounds applies:

  • Your personal data are no longer necessary in relation to the purposes for which they were processed;
  • You have withdrawn your consent - for those processing activities based on your consent – and we have no other legal ground for such processing;
  • You object to the processing of your personal data (for more information on the right to object, see further below) and there are no overriding legitimate grounds for such processing;
  • Your personal data have been unlawfully processed;
  • Your personal data must be erased for compliance with a European or European Member State legal obligation to which UCB is subject;

Please note that your right to erasure will not apply to the extent that processing is necessary for:

  • exercising the right of freedom of expression and information;
  • compliance with a European or European Member State Law to which UCB is subject;
  • reasons of public interest in the area of public health in accordance with article 9(2)(h) and (i) GDPR as well as article 9(3) GDPR;
  • archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with the relevant provisions of the GDPR;
  • the establishment, exercise or defense of legal claims.

For more information, please check Section 4.B “How to exercise your rights”.

Right to restriction on processing

You have the right to obtain from UCB restriction of processing by UCB of your personal data where one of the following applies:

  • You contest - in good faith - the accuracy of personal data regarding you and held by us, in that case the restriction of processing will apply for a period enabling us to verify the accuracy of your personal data;
  • The processing is unlawful and you oppose the erasure of your personal data and request restriction of their use instead;
  • We no longer need your personal data, but you require them for the establishment, exercise or defense of legal claims;
  • You have objected to the processing of your personal data by UCB in accordance with the relevant GDPR provision, in that case the restriction of processing will apply for a period enabling us to verify if our legitimate grounds override yours.

Please note that notwithstanding the above, we are still allowed to continue storing your personal data (throughout the period of restriction) or to process your personal data for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

If you have requested restriction of processing, we will inform you before the restriction of processing is lifted. For more information, please check Section 4.B “How to exercise your rights”.

Right to data portability

You have the right (insofar this does not adversely affects the rights and freedoms of others) to receive the personal data concerning you, that you have provided to UCB, in a structured, commonly used and machine-readable format and to transmit those data to another controller, without hindrance from UCB, where the processing is:

  • based on your consent or on a contract; and
  • carried out by automated means

For more information, please check Section 4.B “How to exercise your rights”.

Right to objection to processing

You have the right to object at any time, on grounds relating to your specific situation, to the processing of your personal data by UCB which is based on UCB’s pursuit of its legitimate interests as a controller. In that case UCB will no longer process your personal data, unless:

  • UCB demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms; or
  • For the establishment, exercise or defense of legal claims.

You have the right to object at any time to the processing of your personal data for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing. For more information, please check Section 4.B “How to exercise your rights”.

Right to withdraw consent

Where the processing is based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. For more information, please check Section 4.B “How to exercise your rights”.

4.B. How to exercise your rights 

If you wish to exercise any of the rights mentioned above, please contact UCB’s Data Protection Officer by e-mail at dataprivacyuk@ucb.com or otherwise reach out to us by regular mail at:

UCB Pharma Ltd

To the attention of the Data Protection Officer

208 Bath Road

Slough, Berkshire SL1 3WE

United Kingdom.

Please clearly identify the right(s) you wish to exercise and include your contact details (including a valid e-mail or postal address) so that we can respond to your request. Please note that you may be asked to provide proof of your identity.

When you contact us to exercise any of the rights mentioned above, we will respond to your request within one month following receipt of the request. This period may be extended by two additional months where necessary, but in that case we will inform you of any such extension within one month of receipt of your initial request together with the reasons for the delay.

Right to lodge a complaint with supervisory authority

In accordance with article 77 GDPR you have the right to lodge a complaint with a supervisory authority, in particular in the European Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that UCB’s processing of your personal data infringes the GDPR. Please visit the website of the relevant supervisory authority for more information on how to submit such a complaint.

 

5. MORE DETAILS ON HOW WE PROCESS YOUR PERSONAL DATA

5.A. Who we share your personal data with

Principle

We will disclose your personal data only as described in this Policy (as further detailed above), as may be updated from time-to-time.

Subsidiaries/affiliated companies and third party processors

UCB transfers or discloses your personal data to its subsidiaries/affiliated companies and to third party service providers processing personal data on UCB’s behalf for the purposes set out above.

Third party service providers include the mailing house sending magazines (Fine Print),  IT services and website hosting companies, (internet) connectivity providers, email providers (Sendgrid), providers of data analytics (including Google) and tracking services, as well as service providers that provide technical and administrative support for the Website and underlying IT systems (including Twilio). These service providers provide their services from locations within the EU (including Germany, Malta, UK and Ireland) and outside of the EU Google (USA)).

Other third parties include regulatory and government agencies (see further below in this Policy), and potentially, third parties with whom UCB may merge or which may be acquired by UCB (see further below in this Policy). 

Compliance with laws and legal proceedings

UCB will disclose your personal data where:

  • UCB is required to do so by applicable law, by a governmental body or by a law enforcement agency;
  • To establish or exercise our legal rights or defend against legal claims;
  • To investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies or as otherwise required by law.

Other

If a third party acquires all (or substantially all) of our business and/or assets, we will disclose your personal data to that third party in connection with the acquisition. However, such disclosure will occur subject to and in accordance with applicable data protection laws, including the GDPR.

 

5.B. International transfers

UCB will transfer your personal data to its affiliates, including our affiliates outside of the EEA. In that case  UCB relies on UCB's Binding Corporate Rules

UCB will also transfer your personal data to certain third party service providers both within the EEA (including Germany, Malta, UK and Ireland) and outside of the EEA (USA).

The transfer of your personal data to (other) third party service providers outside of the EU (as set out above under this Section 5B) occurs on:

  • The basis of Standard Contractual Clauses that have been executed between UCB and the relevant third party service provider. For more information on these Standard Contractual Clauses, please reach out to us as set out above under Section 4.B (“How to exercise your rights”).

For more information on how Google processes your personal data within the framework of Google Analytics, please consult How Google uses data when you use our partners' sites or apps.

 

5.C. Links to third party sites

This Website may contain links to other websites operated by third parties, including but not limited to patient organization and other information resources and certain social media sites such as YouTube, Vimeo etc. This Policy does not apply to any website, other than this one. Third party websites are governed by their own terms and conditions. You should therefore always carefully check the privacy and cookie policies of third party websites before accepting to be redirected to them.

Hello Jon, welcome to MyPatchandMe™.

As part of your tailored programme, and to provide you with the best experience and the most relevant information, please let us know:

How long have you been using Neupro® (rotigotine) for Parkinson’s disease?

less than 3 months
more than 3 months

Please let us know where you learned about the programme?

my doctor
my nurse
my pharmacist
patient support groups
internet search
someone has recommended the programme to me
other
Please note
You need to provide an answer to both questions before proceeding

Your opinion is very important to us in order to understand how you are managing your disease and treatment and to make this support programme the best experience for you

Please click on this link.