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Valneva UK Limited (“Valneva“) has created this privacy statement in order to demonstrate our firm commitment to privacy. The following discloses our information gathering and use practices for the Valneva website, www.valnevauk.com and pages to which it links or which are owned by Valneva and which refer to the present Privacy Statement (collectively referred to as the “Site“).

The present policy (hereafter referred to as the “Privacy Policy”) regulates your access and use of the Site and serves to inform you of our policy pertaining to the collection, use and disclosure of information that you may provide, whether intentionally or unintentionally, by your use of the Site.

IT IS THUS IMPORTANT THAT YOU CAREFULLY READ AND FULLY UNDERSTAND THE ENTIRE PRIVACY POLICY PRIOR TO USING THE SITE.

Valneva (“we“, “us” or “our“) recognises our responsibility to protect Personal Data in our custody or control. “Personal Data” means personally identifiable information, i.e.  any information relating to an identified or individual, such as your name, birthday, gender, address, email address, phone number, health information, and comments or enquiries you have made about our products or services when such comments or enquiries are linked to you or any other information of similar nature.

This Privacy Policy applies to individuals we deal with in the United Kingdom including consumers, patients, health care professionals and others within the health care or pharmaceutical industries (“you” or “your“), and explains how we collect, use, disclose and otherwise process  and protect your Personal Data. The policy further includes a description of your data privacy rights as a data subject.

By using this website or otherwise supplying us with your Personal Data, you agree that we may use any Personal Data you have given, in the manner stated below.

1. Personal Data

We may collect Personal Data e.g. names, addresses, telephone numbers, email addresses, only when voluntarily provided by you when you register or otherwise voluntarily submit information to us. Some of this information may relate to your health, which is particularly sensitive. We may collect also CVs, information on your permits, licensees, potential conflicts of interest, references and merits. We may also collect information relating to adverse events.

2. Data Controller

A Data Controller is the one determining the purposes and means of the processing of Personal Data. Valneva UK Limited, with registered address at, Morton Fraser London, St Martin’s House, 16 St Martin’s le Grand, London, EC1A 4EN, United Kingdom will collect and process your information as Data Controller.

3. Legal Basis for Processing

Valneva processes your Personal Data on defined legal grounds. We may process your Personal Data when it’s necessary for the performance of a contract between us, when we have a legitimate interest to do so, or when there is a legal obligation that we have to comply with. Sometimes you have given specific consent to the processing activities. If the consent concerns a child under the age of 16 (or such other lower age determined by the local laws applicable to this Privacy Policy), consent must be given or authorized by a person with parental responsibility for the child.

4. Personal Data Collection

Valneva and its agents and representatives collect Personal Data, sometimes including special category data that is particularly sensitive personal data (e.g.  data concerning health) in a number of circumstances, including when you provide it to us voluntarily or in other circumstances with your consent or as permitted or required by law. For example, we may collect your Personal Data when you:

  • request information;
  • enquire or provide comments about our products and services;
  • participate in advisory boards;
  • participate in clinical trials;
  • participate in contests or other promotions;
  • fill out questionnaires or surveys;
  • participate in social media, or post information on bulletins or on the Site;
  • submit your resume or other Personal Data in connection with employment possibilities with us; or
  • otherwise provide your Personal Data to us, including by telephone, mail, email, facsimile or through any of the Site.

The information we may collect includes:

  • personal and business contact information, such as name, birthday, title, address, telephone, gender number and email address or any other information of similar nature;
  • information that our sales representatives may collect during their visits with physicians and other health care professionals with whom they deal, for instance title, qualifications, areas of practice or specialisation, their questions or comments about our products, and related information about health care professionals and their administrators relevant to maintaining and managing our relationship with such persons;
  • names and other contact details of patients who use our products and their physicians and, in certain circumstances, sensitive personal data, and patient medical history, for example, where we have received a report of an adverse event, where we are providing patient-specific assistance with respect to the use or reimbursement of our products, or where we are assisting in or co-coordinating product recalls;
  • information collected in connection with enquiries or comments made by individuals who contact our Medical Information representatives;
  • names and other contact details of physicians participating in advisory boards and the opinions or comments expressed by those physicians during advisory board meetings;
  • names and other contact details of physicians involved in running clinical trials, together with their professional information such as curriculum vitae and other information that is required to be reported to relevant regulatory bodies;
  • information such as name, age, and gender of patients participating in clinical trials together with the clinical data collected in the course of the clinical trials. Valneva generally receives patients’ clinical data that has been recorded using identifiers other than the patients’ full name, such as the patients’ initials. More comprehensive patient data, including full names, may be reviewed by our clinical site managers when they attend at the trial site for compliance monitoring;
  • information from individuals visiting our premises such as their name and the name of the organisation for which they work or which they represent. We may also post video cameras in public-access areas on our premises; and
  • other information with your consent or as permitted or required by law.

Calls to and from Valneva may be recorded and/or monitored for quality and training purposes. Recordings may also be used to help us develop and improve our products and services. Information may also be actively and passively collected by the Site. See “the Site” below for details.

You have the right to decline our request of your Personal Data, however we may not be able to provide you with the requested services should you chose to do so.

Please note that if you wish to subscribe and connect your personal social media account to our web site, e.g. if you would like to share information on your own social media account, certain Personal Data will be shared to us such as Personal Data linked to your profile or your friends’ profiles on the applicable social media account.

If you are sharing Personal Data of another individual, you guarantee that you have the authority to share that data and give us the permission to process the Personal Data provided in accordance with this Privacy Policy.

5. Purposes

Valneva collects Personal Data for a variety of purposes relating to the operation of our business and the delivery of services to you, including to:

  1. provide our products and services and generally manage and administer our business including maintaining business records for reasonable periods and defending and bringing legal actions;
  2. develop and improve our products;
  3. provide you with health and product-related information;
  4. reply to your requests, enquiries and comments;
  5. receive and assess product enquiries, reports of adverse events, and product complaints;
  6. assist in or co-ordinate product recalls;
  7. establish and maintain our relationship with health care professionals and administrators and other individuals with whom we have contact in the course of our business;
  8. provide assistance and advice to health care professionals and institutions with respect to our products;
  9. test and analyse our products for efficacy and safety;
  10. meet legal, regulatory, insurance, security, ethical and processing requirements such as adverse event and clinical reporting to relevant regulatory bodies;
  11. monitor compliance with informed consent requirements when patients participate in clinical trials, and verify that clinical data collected by Valneva in the course of the clinical trial conforms to the source data available at the site of the clinical trial;
  12. use feedback provided to us in the course of advisory board meetings to develop the strategic positioning of our products;
  13. manage, administer, collect and enforce accounts;
  14. provide remuneration to individuals who have performed services for Valneva;
  15. enable us to act responsibly in the event of a health or other crisis or emergency and to enhance workplace security;
  16. evaluate resumes or other Personal Data submitted to us in connection with employment possibilities. For candidates who are not offered or do not accept a position, we may retain their information in the event that an appropriate position becomes available or that they re-apply to Valneva;
  17. offer and administer contests, promotions, surveys and websites including social media;
  18. ensure the security and integrity of the Site and operations.

We may also use your Personal Data for other purposes with your consent or as permitted or required by law.

6. Direct Marketing

We will not use your personal data for marketing activities unless you have consented to receive marketing communications from us.

7. Transfer of Personal Data and Use of Service Providers

This website is owned and operated by Valneva in the United Kingdom, but the information you provide may be accessible or transferred to our affiliates, vendors or suppliers in other countries, including countries outside the European Economic Area (“EEA”). We may further  transfer Personal Data to outside agents or service providers (including affiliates acting in this capacity) that perform services on our behalf and according to our instructions, for example: certain payroll and benefits administration functions; receipt and administration of certain adverse event or product quality complaints; certain credit card, billing, mailing, marketing, information technology and/or data hosting or processing services, or similar services, or otherwise to collect, use, disclose, store or process Personal Data on our behalf for the purposes described in this Privacy Policy. Such third-party service providers are restricted from using the Personal Data for any other purpose other than to provide services for Valneva. Valneva is responsible for any processing by such third parties and will ensure that such service providers have entered into written agreements allowing Valneva to comply with our obligations under this Privacy Policy and applicable laws and regulations. Your Personal Data will not be disclosed to any other third parties unless you have explicitly given your consent to such disclosure or if it is required by laws or regulations. Some of these service providers may be located outside of the EEA. While outside of the EEA, your Personal Data will be subject to applicable foreign legal requirements, which may include lawful requirements to disclose Personal Data to government authorities in certain circumstances. In case of such transfer, Valneva will take reasonable efforts and security measures in an effort to keep your Personal Data secure, and Valneva is responsible to ensure that the transfer takes place in accordance with this Privacy Policy and applicable laws and regulations. We may also use, disclose and transfer your Personal Data in connection with a possible reorganization, merger, acquisition, assignment, transfer or other disposition of all or parts of our business, assets or shares. If you have any questions about the methods, we use to safeguard any personal data transferred outside the EEA please feel free to contact us using the contact details under Section 16 below.

8. Disclosures

Valneva may disclose your Personal Data (including Sensitive Personal Data) in the following circumstances:

We may disclose Personal Data when required in order to meet legal, regulatory, industry self-regulatory, insurance, audit, security or ethical requirements, including obligations to health and drug regulatory and self-regulatory bodies, physicians, hospitals, or other health care facilities.

Your Personal Data may be used by Valneva and disclosed to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of Valneva’s business or assets, including for the purpose of permitting such parties to determine whether to proceed or continue with such transaction or business relationship and to fulfil reporting or audit requirements. Assignees or successors of Valneva or our business or assets may use and disclose your Personal Data for similar purposes as those described in this Privacy Policy.

We also may disclose your Personal Data to third parties, located in the EEA and/or any other country, where required or permitted by applicable laws, court orders, or government regulations (including as required by national and foreign laws applicable to Valneva or our agents and service providers).

9. Consent

By using the Site, you are indicating your acceptance to follow and be bound by the Privacy Policy in its entirety, as it may be modified from time to time without prior notice or indication to you to that effect, as well as by the Terms and conditions of use of the Site, as published from time to time by Valneva.

You authorise Valneva to collect and to retain all relevant information relating to your use of this Site and you hereby authorise any party to provide us with such information. You understand and agree that unless you notify Valneva of the contrary by e-mailing us, you further authorise us to disclose, on a confidential basis, to any party with whom Valneva has business relations, all relevant information relating to your dealings with us and this Site.

By using the Site, you are also indicating your understanding of the fact that whenever you submit information through this Site, you explicitly authorise us to collect, use and disclose such information within the parameters set out in the present Privacy Policy, as amended from time to time.

If you have provided us with Personal Data and wish to withdraw your consent to its retention, use or disclosure, please contact us as described below in the “Access, Correction and Contacting Us” section.

You may withdraw or withhold your consent, subject to legal or contractual restrictions and reasonable notice, or by ticking the relevant boxes on the forms when you submit, or we collect Personal Data from you (as applicable). If you withdraw your consent to certain uses of your Personal Data, we may no longer be able to provide certain of our products or services. Where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfil the purposes described in this Privacy Policy or otherwise at the time of collection.

There are instances where we may be permitted or required by law to collect, use or disclose your Personal Data without your consent including, for example, to comply with a court order, to comply with national or international regulations or a legally permitted enquiry by a government agency, or to collect a debt owed to us.

10. Security

We take reasonable steps to protect your Personal Data using physical (locked filing cabinets and restricted access to offices), electronic (especially firewalls) or procedural security measures appropriate to the sensitivity of the information. Valneva will take appropriate steps to ensure that Personal Data about you is protected from loss or theft, as well as unauthorised access, disclosure, copying, use or modification.

Although we have enacted security measures, we cannot guarantee the security of any information that you submit via email or over the Internet. To the extent permitted under applicable law, we make no warranty, express or implied, concerning the security or integrity of any Personal Data. Submission of Personal Data using such networks is done at your own risk, since no Internet transmission is ever 100% secure or error-free (in particular, emails sent to or from the Site may not be secure). You should take special care in deciding what information you send to us via email or posting on the Site. Moreover, where you use passwords, ID numbers or other special access features on the Site, it is your responsibility to safeguard them.

11. Links to other Websites

The Site may contain links or references to other websites to which this Privacy Policy does not apply. Valneva is not responsible for the data collection and use practices of companies or organisations to which the Site may provide links. We encourage you to read the privacy statement/policy of every website you visit.

Valneva makes no representations whatsoever about any other website which you may access through this Site. In addition, a link to a website does not mean that Valneva endorses or accepts any responsibility for the content, or the use, of such website

12. The Site

Active Information Collection

The Site may actively collect information from visitors both by asking you specific questions and by permitting you to communicate directly with us via email and/or feedback forms. Some of the information that you submit on the Site may be Personal Data.

Passive Information Collection

As you navigate through the Site, certain information can be passively collected (that is, gathered without your actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, Internet tags, web beacons and navigational data collection (log files, server logs, clickstream). Your Internet browser automatically transmits to the website some of this anonymous information, such as the URL of the website you just came from and the Internet Protocol address and the browser version your computer is currently using. The Site may also collect anonymous information from your computer through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of the Site might not work without cookies.

The Site may use and combine such passively collected anonymous information to provide better service to site visitors, customise the sites based on your preferences, compile and analyse statistics and trends, and otherwise administer and improve the sites for your use. Such information is not combined with Personal Data actively collected on the Site unless you have consented.

Cookies

The following is a description of cookies and other passive tracking methods.

A “cookie” is a bit of information that a website sends to your web browser that helps the site remember information about you and your preferences.

“Session” cookies are temporary bits of information that are used to improve navigation, block visitors from providing information where inappropriate and collect aggregate statistical information on the site. They are erased once you exit your web browser or otherwise turn off your computer.

“Persistent” cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (such as passwords), helping to determine what areas of the website visitors find most valuable, and customising the website based on your preferences on an ongoing basis.

Detailed below are the cookies that have been implemented on this site:-

Name: _ga
Expires: 2 years
Purpose: This helps us count how many people visit the Site by tracking if you’ve visited before

Name: _gat
Expires: 10 minutes
Purpose: Used to manage the rate at which page view requests are made

Name: VISITOR_INFO1_LIVE
Expires: 8 months
Purpose: Let’s YouTube count the views of embedded YouTube videos

Name: PREF
Expires: 2 years
Purpose: Records basic user preferences for YouTube videos

Name: seen_cookie_message
Expires: 1 month
Purpose: Saves a message to let us know that you’ve seen our cookie message

IP Addresses and Tags

A site may use Internet Protocol (IP) addresses. An IP address is a number assigned to your computer by your Internet service provider. In most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user’s computer). The IP address can be used to diagnose problems with a server, report aggregate information, determine the fastest route for your computer to use in connecting to a site, and administer and improve the site.

“Internet tags” (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the website server information such as the IP address and browser type related to the visitor’s computer. Tags may be placed both on online advertisements that bring people to the site and on different pages of the site. Such tags indicate how many times a page is opened, and which information is consulted.

“Navigational data” (log files, server logs, and clickstream data) are used for system management, to improve the content of the site, for market research purposes, and to communicate information to visitors.

13. Collection of Personal Data from Children

This Site is not directed to individuals under the age of sixteen (16) (or such other lower age determined by applicable laws), and we do not knowingly collect any Personal Data from children under such age.

Should we need to process Personal Data of an individual under the age of sixteen (16) (or such other lower age determined by applicable laws) consent to such processing must be given by an authorised person with parental responsibility for the child.

14. Retention and Erasure of Personal Information

We will retain your Personal Data only for the period necessary to fulfil the purposes outlined in this Privacy Policy or the period to which you have consented, unless a longer retention period is required by laws and regulations.

15. Privacy Policy Changes

This Privacy Policy may be revised from time to time. If we intend to use or disclose Personal Data for purposes materially different than those described in this Privacy Policy, we will make reasonable efforts to notify affected individuals, if necessary, including by posting the revised Privacy Policy on this site. We recommend that you review this Privacy Policy frequently.

Your continued provision of Personal Data or use of the Site following any changes to this Privacy Policy constitutes your acceptance of any such changes.

16. Information Regarding Your Rights

If you would like to access your Personal Data or get it rectified, updated, erased or to transfer it to other organizations please contact us at the address below. You also have the right to object or to restrict some processing and, where we have asked for your consent to process your Personal Data, to withdraw your consent at any time and we will stop any future use of your Personal Data (unless there is a legitimate interest that prevent us from doing so). We may request a reasonable fee for administering certain requests. Authorised employees, agents and mandataries of Valneva who require access to your Personal Data in order to fulfil their job requirements will have access to your Personal Data.

You may contact us by writing to us at the following address:

Valneva UK Limited, Centaur House, Ancells Business Park, Ancells Road, Fleet, Hampshire GU51 2UJ

NOTE: If you are a physician or other health care professional and would like to record an adverse event, please contact safety@valneva.com

17. Contact the Supervisory Authority

If you have any comments or complaints regarding the way your personal data is being handled, you have the right to contact the supervisory authority in the United Kingdom (The Information Commissioner’s Office (“ICO”) to lodge a complaint:

The Information Commissioner’s Office, Water Lane, Wycliffe House,Wilmslow – Cheshire SK9 5AF

Tel. +44 1625 545 745

E-mail: international.team@ico.org.uk

Website: https://ico.org.uk

 

UK/TRA/0518/0236b May 2018