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Privacy policy LinkedIn

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PRIVACY POLICY FOR

MERZ THERAPEUTICS LINKEDIN CHANNEL AND GROUPS

We, Merz Therapeutics GmbH (“Merz“, “we“) manage publicly accessible profiles and closed groups on various social networks, including the LinkedIn platform. Your visit to these profiles and entry into our groups initiates a variety of data processing activities. Below, we provide an overview about the processing of your personal data when you visit our LinkedIn profile or are a member of a closed group offered and managed by us.

Merz processes your data in compliance with the data protection provisions of the Regulation (EU) 2016/679 (General Data Protection Regulation; “GDPR”) as well as corresponding national law.

A. CONTROLLER FOR THE PROCESSING OF YOUR PERSONAL DATA

When you visit our Merz Therapeutics LinkedIn profile or join our LinkedIn groups operated by us, your personal data will not only be used and stored by us, but also by the social network LinkedIn, which is operated by LinkedIn Ireland Unlimited Company and LinkedIn Corporation (both referred to as “LinkedIn” unless stipulated otherwise). This applies even if you do not have a profile on LinkedIn yourself.

I. Merz as controller

As the operator of the Merz Therapeutics LinkedIn profile and groups, Merz processes your personal data named in section B below as the controller within the meaning of Art. 4 No. 7 GDPR.

II. LinkedIn as controller

In addition, the operator of the social network, in this case LinkedIn Ireland Unlimited Company (for users within the EU) and LinkedIn Corporation (for users outside the EU), is the controller for the processing of personal data on the platform that does not concern the Merz Therapeutics LinkedIn channel or groups managed by Merz and does not serve the purposes of Merz. Information about the personal data processed by LinkedIn can be found in the respective data protection information provided by LinkedIn (https://de.linkedin.com/legal/privacy-policy.).

Merz is not able to influence the processing of personal data carried out by LinkedIn as controller.

B. WHICH PERSONAL DATA IS PROCESSES FOR WHICH PURPOSE?

I. LinkedInGroup

We have created a LinkedIn group (hereafter “Group“) focused on medical and scientific content. The Group can be accessed via invitation only. The goal of our Group is to engage HCPs and facilitate scientific exchange on neurological conditions and movement disorders management. Your visit to our Group initiates the following data processing activities:

  1. We process your first name, surname and professional qualifications in advance for the purposes of selection and suitability for our LinkedIn Group.
  2. We process your first and last name and contact details for the purpose of inviting you to join our LinkedIn Group and subsequently to verify your identity. For this purpose, we will send you an invitation link that will give you access to our closed Group.
  3. Data entered in our Group, e.g. comments, videos, pictures, likes, messages, etc., are uploaded by LinkedIn and are generally not processed by Merz. However, we reserve the right to delete content if this should be necessary (e.g. due to inappropriateness). Further, we screen the content regularly in order to be able to respond to suggestions from you and pass them on internally in anonymized form. If necessary, we also communicate with you via the Group. In our Group, posts are visible to other members of the Group.
  4. Furthermore, we are legally obliged to react to and report information about side effects you might share in the Group. Therefore, should you draw attention to observed side effects within the Group, we also process this information.

The legal basis for the processing of personal data by Merz is Art. 6 (1) sentence 1 lit. f GDPR. Our legitimate interest lies in the creation of a professional network to allow an exchange of knowledge, and our interest in being able to use the results from the discussions in the Group on an anonymized basis for our business purposes. Insofar as the processing concerns a side effect report, the legal basis is our compliance with a legal obligation, Art. 6 (1) sentence 1 lit. c GDPR.

II. Merz Therapeutics LinkedIn profile

In addition, Merz operates the official Merz Therapeutics LinkedIn channel. If you visit this channel or interact with the contents on this channel, the following personal data is processed:

Data entered on our LinkedIn profile, e.g. comments, videos, pictures, likes, messages, etc., are uploaded by LinkedIn and are generally not processed by Merz. However, we reserve the right to delete content if this should be necessary (e.g. due to inappropriateness). We screen the content regularly in order to be able to respond to suggestions from you and pass them on internally in anonymized form. The legal basis for the processing of personal data by Merz in this context is Art. 6 (1) sentence 1 lit. f GDPR. Our legitimate interest lies in monitoring external reactions to our LinkedIn channel.

III. Processing in the event of direct contact with Merz

If you contact us in our Group (e.g. by responding to one of our posts or by sending us private messages) or otherwise via LinkedIn, the data you provide will be processed by us solely for the purpose of answering your request.

Your data may be passed on to other Merz companies if and insofar as this is necessary to answer your enquiry. You can view an overview of the Merz companies here https://www.merz.com/about-merz/locations. The legal basis for the processing of the data described above is, depending on the content of the respective contact, Art. 6 (1) sentence 1 lit. b or f GDPR.

If, in order to respond to the request, data must be transferred to Merz Group companies outside the European Union or the European Economic Area and the Merz Group company has its registered office in a country that does not ensure an adequate level of data protection in accordance with a decision of the European Commission, the necessary safeguards for the protection of personal data are contained in the standard contractual clauses adopted by the European Commission. These can be accessed here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc/standard-contractual-clauses-international-transfers_en.

IV. Reporting of possible side effects of Merz products

If you use our Merz Therapeutics LinkedIn channel or otherwise contact Merz via LinkedIn to report that you suffered a potential side effect from a Merz product, we will collect and process various types of health-specific data relating to you. This data includes the information you shared in your post or message and your name and other personal data visible to us. Such data is used for the exclusive purpose of investigating your report and understanding how our drug or device may have caused it. If necessary, we might also contact you directly for this purpose. Merz is in some cases also legally required to share reports about adverse events with public authorities. This processing is based on our compliance with a legal obligation to monitor risks in connection with our products (Art. 6 para. 1 lit. c) GDPR) and, as far as health data is concerned, for ensuring high standards of quality and safety of health care and of medicinal products or medical devices (Art. 9 para. 2 lit. i) GDPR).

When processing personal data in connection with reports about unwanted side effects regarding products for which Merz Pharmaceuticals GmbH is the market authorization holder, Merz acts as joint controller together with Merz Pharmaceuticals GmbH, Eckenheimer Landstrasse 100, 60318 Frankfurt am Main, Germany. Regarding pharmacovigilance services, Merz is responsible for all essential data processing operations. As between Merz and Merz Pharmaceuticals GmbH, Merz is also responsible for complying with data subjects’ rights under the GDPR, providing information about the data processing to data subjects, and, where necessary, conducting data protection impact assessments and fulfilling notification obligations in the event of personal data breaches. Notwithstanding the above, you are also entitled to exercise your data protection rights vis-à-vis Merz Pharmaceuticals GmbH. If you want to contact Merz Pharmaceuticals GmbH or its data protection officer, please address your request to Merz Pharmaceuticals GmbH, attn. data protection officer, Eckenheimer Landstrasse 100, 60318 Frankfurt am Main, Germany, or dataprotection@merz.com.

For more detailed information about how the Merz group processes personal data regarding unwanted side effects, please see www.merz.com/fin.

C. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

Merz is supported by specialized technical service providers for the technical processing of personal data. These service providers are carefully selected and are legally and contractually obliged to ensure a high level of data protection. The legal basis for the cooperation with these service providers is Article 28 GDPR.

If we transfer personal data to a party outside the European Union or the European Economic Area, it will either be located in a country that ensures an adequate level of data protection as decided by the European Commission, or an adequate level of data protection will be established by standard contractual clauses approved by the European Commission and concluded between us and the respective party. The standard contractual clauses can be accessed here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc/standard-contractual-clauses-international-transfers_en.

D. DURATION OF THE RETENTION OF YOUR PERSONAL DATA

Unless otherwise specified in this Privacy Policy, personal data will be deleted by Merz when it is no longer needed for the purposes for which it was processed and the statutory retention periods have expired.

E. RIGHTS IN RELATION TO PROCESSING OF PERSONAL DATA

Should you wish to receive detailed information or a copy of the personal data stored by Merz about you, you can contact Merz. You may also receive the data that you have provided to Merz in a structured, common and machine-readable format or request that Merz transmit this data to a third party. If you discover that the data stored about you is incorrect or incomplete, you may at any time request that this data be corrected or completed without delay. Under the conditions specified in Articles 17 and 18 of the GDPR, you may also request the deletion or restriction of the processing of personal data. If you have declared your consent to the processing of your personal data, you have the right to withdraw your consent at any time without affecting the lawfulness of the processing carried out on the basis of the consent until its withdrawal.

You also have the right to lodge a complaint with the competent data protection supervisory authority.

Insofar as the processing of your personal data is based on our legitimate interest within the meaning of Art. 6 (1) sentence 1 lit. f GDPR, you have the right to object to the processing of personal data concerning you at any time for reasons arising from your particular situation; this also applies to any profiling based on this provision. Merz will then no longer process the personal data, unless Merz can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims. If your personal data was processed for the purpose of direct marketing, Merz will immediately stop processing your personal data for this purpose.

F. CONTACT INFORMATION

I. Merz

If you have any questions about the processing of personal data by Merz or wish to exercise your rights in relation to such processing, you may contact Merz at any time. To do so, simply send a letter to the following address:

Merz Therapeutics GmbH
Data Protection
Eckenheimer Landstraße 100
60318 Frankfurt am Main
Germany

You can reach Merz’s data protection officer at datenschutz-therapeutics@merz.de.

Furthermore, we refer to our Merz Privacy Policy (see www.merz.com/fin), in which we provide general information about the processing of personal data of various groups of persons (e.g. visitors to our website, study participants, purchasers of our products or members of a health care profession).

II. LinkedIn

If you have any question regarding the data processing carried out by LinkedIn or want to exercise your data protection rights towards LinkedIn, please contact LinkedIn directly via the contact details provided by LinkedIn.