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DATA PROTECTION POLICY

This website (hereinafter the «site») is owned by Grünenthal Chilena Ltda. (hereinafter «we» or «our»).

We respect your privacy and are committed to protecting your information.

The privacy policy that follows governs our information collection practices on this site. If you want more information about the provider of this website, please ask us at the contact indicated in Section 3.

1. PROCESSING OF PERSONAL DATA

At Grünenthal we believe that transparency is the foundation of a trustful partnership. Below we will inform you of how we process your personal data when you use our website. We use your personal data because it is necessary for certain features of our website to be available and to offer you the best possible experience. Unless otherwise stated, the legal basis for processing your personal data arises from the need to use said data to be able to offer the functionality of the website that you need (according to Law No. 19,628 on the Protection of Personal Data Personal, and any other applicable legislation on the matter).

1.1 USE OF OUR WEBSITE

1.1.1 ACCESS TO OUR WEBSITE

When you request access to our website, your browser will transfer certain data to our web server. This is done for technical reasons so that the data you request is available. In particular, the following information is collected, which is then briefly stored and used:

• IP adress
• Date and time of access
• Time zone offset from Greenwich Mean Time (GMT)
• Content of the request (specific site)
• Access status/HTTP status code
• Amount of data transferred
• Website access request
• Browser, language settings, browser operating system version and browsing surface

We will also store such data for a limited period of time in order to start tracking personal data in the event of a successful or unsuccessful attempt to gain unauthorized access to our servers.

(according to Law No. 19,628 on Protection of Personal Data, and any other applicable legislation on the matter).

1.1.2. CONFIGURATION OF COOKIES

What are cookies?

Our website uses so-called «cookies». Cookies are small text files that are stored in the memory of a device through the browser. They store certain information (for example, your preferred language or site settings). Your browser may resend this information to us when you return to our website, depending on the duration of the cookie.

What cookies do we use?

We classify cookies into two categories: (1) functional cookies, which are necessary for the functionality of our website, and (2) optional cookies. They are used for website analysis and marketing purposes. The following tables present a detailed description of the optional cookies we use:

optional cookies

Purpose and content	Durability
Website analysis with Google Analytics: These cookies assign a randomly generated identity to your device. This allows us to identify your device the next time you visit us. To learn more about website analytics, please refer to the relevant chapter below.	2 years
Website Analytics with Sitecore Experience Analytics: When used, these cookies assign a randomly generated identity to your device. This allows us to identify your device the next time you visit us. To learn more about website analytics, please refer to the relevant chapter below.	session duration

Subject to your consent

We will only use optional cookies by obtaining your prior consent (in accordance with Law No. 19,628 on the Protection of Personal Data, and any other applicable regulations). When visiting our website for the first time, a banner will appear asking for your consent to the use of optional cookies. If you consent, we will place a cookie on your device and the ad will not appear again while the cookie is active. At the end of the cookie’s duration, or if you decide to actively delete the cookie, the ad will appear again the next time you visit our website and again ask for your consent.

How to prevent the use of cookies

It is possible to use our website without using cookies. In your browser, at any time, you can set or completely disable the use of cookies.

Consult your browser’s help menu for assistance:

Internet Explorer™:

https://support.microsoft.com/es-es/help/17442/windows-internet-explorer-delete-manage-cookies

Safari™:

https://support.apple.com/es-es/guide/safari/sfri11471/mac

Chrome™:

https://support.google.com/chrome/answer/95647?hl=en&;hlrm=en

Firefox™:

https://support.mozilla.org/es/kb/habilitar-y-deshabilitar-cookies-sitios-web-rastrear-preferencias

However, such action may restrict certain features or adversely affect the usability of our website. You can object to the use of optional cookies at any time by using the corresponding option to opt out indicated in the table above.

1.1.3 ANALYSIS OF WEBSITES

sitecore

This website may use the «Sitecore Experience Analytics» web analytics service to help us continually improve the user-friendliness of our website. Sitecore uses «cookies» stored on your computer that allow you to analyze your use of the website. The information generated by the cookie regarding your use of the website is transmitted to and stored on EU-based, advanced security cloud servers (Azure cloud, Dublin, Ireland). You can use the corresponding settings in your browser software to prevent cookies from being saved; however, we warn you that if you do so, you will not be able to fully use all the options offered by the website.

Google Tag Manager

This website may use GTM (Google Tag Manager – tag management system) to initiate and control the connection with Google Analytics. It is mainly used to minimize administrative efforts and analyze reporting problems.

Google Analytics

For our websites we use Google Analytics, a web analysis service of Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, United States (hereinafter «Google»). Google will analyze your use of our website on our behalf. For these purposes, we use, among others, the cookies that are described in detail in the aforementioned table. Information collected by Google in connection with your use of our website (for example, the URL from which you came to our site, the pages of our website you visited, browser type, language settings, operating system , screen resolution) will be transmitted to a Google server in the USA where it will be stored and analyzed. The corresponding results will then be made available to us anonymously. During this process, data about your usage will not be connected to your full IP address. On our website we have activated the IP anonymization function offered by Google, which will delete the last 8 digits (IPv4 type) or the last 80 bits (IPv6 type) of your IP address. In addition, Google is certified under the EU-US Privacy Shield, which ensures that an adequate level of data protection is maintained with respect to Google’s data processing in the US.

You may revoke your consent to the use of web analytics at any time, either by downloading and installing the Google Browser Plugin offered or in the aforementioned table regarding consent, in which case an opt-out cookie will be placed. Both options will prevent the use of web analytics only when you use the browser in which you installed the plugin and as long as you do not delete the opt-out cookie.
You will find more information about Google Analytics in the Google Terms of Use, the Google Analytics Privacy and Data Protection Regulation and the Google Privacy Policy.

By using this website you will be consenting to Google processing your data in the manner and for the purposes set out above.

General information about online behavioral advertising

Online behavioral advertising, also known as targeting, allows advertising companies to identify users and place them in certain target groups by presenting advertisements. This information gives the possibility of offering more relevant ads to the user.

Behavioral advertising is carried out through three stages: collecting information through “tracking pixels”, storing and processing log file information, and finally using said information when the user returns for retargeting. or double retargeting. Next we will explain the stages in more detail.

Use of tracking pixels on this website

Tracking pixels are small images from websites that are used to record and analyze the log file in order to evaluate statistics. When visiting a website, tracking pixels write information to the cookie file in the user’s browser.

1.1.4 USE OF THE CONTACT FORM

You can contact us directly through the contact forms available on our website. In particular, you may provide us with the following information:

• name, surname and title;
• address (street, zip code, city)
• country
• contact details (eg email address, phone number)
• message

We collect, process and use the data provided through the contact forms to exclusively process your specific request.

1.1.5 SUBSCRIPTION TO OUR NEWSLETTER

If the website offers it to you, you can sign up to receive a newsletter. Based on your prior consent, we will collect and use the indicated email address to send you the newsletter (in accordance with Law No. 19,628 on the Protection of Personal Data, and any other applicable legislation on the matter).

If you wish to receive a personalized newsletter, you may voluntarily provide us with the following additional information:

• Name and surname
• Treatment
• City
• Country
• Profession
• Specialty
• Themes of interest

For the subscription to our newsletter we use the so-called double opt-in subscription processes (double opt-in). After signing up for the newsletter, we will send a message to the indicated email address requesting your confirmation. If you do not confirm the subscription, it will be automatically deleted. To prevent misuse of your personal data, we will record your subscription and confirmation, the IP address you used when you subscribed, the time of your subscription and confirmation, the messages we sent you regarding your subscription and the text of your subscription and confirmation.

You may revoke your consent to receive the newsletter at any time with effect for the future. To declare that you want to unsubscribe, you can use the respective link that is included in all newsletters or refer to the contacts indicated in Section 3.

1.1.6 EXTERNAL SERVICES OR CONTENT ON OUR WEBSITE

On our website we include third-party services and/or content. When using third-party services or when third-party content is presented, for technical reasons, communication data is exchanged between you and the respective provider.

The respective service or content provider may also process your data for its own additional purposes. To the best of our knowledge, we have configured the services and content of providers who process data for their own reasons so that any communication for reasons other than presenting their services or content on our website is blocked or communications are enabled when you have opted explicitly for using the service in question. However, since we do not have control over the data collected and processed by third parties, we cannot provide binding information about the scope and reasons for the processing of your data.

For more information about the scope and reasons for the processing of your data, please consult the data protection declaration of the providers whose services and/or contents are included and who are responsible for the protection of your data in this context:

• Youtube videos)

This website may use plug-ins from the US company Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA («Google»), which operates YouTube. As a consequence, our website may transmit the registration information to Google. The Google server in the United States then automatically stores information (“log data”), such as information that your browser sends to a website when you visit it or information that an application on your mobile phone sends when you use it. Such log data may contain your IP address, the address of the website you visited that uses Google features, browser type and settings, the date and time of your request, information about how you use Google, and cookies.

You can find more information about data collection, how YouTube evaluates and processes your information and your rights in YouTube’s privacy policy.

YouTube / Google:  https://www.google.com/intl/en/policies/privacy/

• Vimeo (videos)

This website may use plug-ins from the American company Vimeo, LLC, 555 West 18th Street, New York, New York 10011, USA. As a result, our website may transmit registration information to Vimeo. The Vimeo server in the United States then automatically stores information (“log data”), such as information that your browser sends to a website when you visit it or information that an application on your mobile phone sends when you use it. Such log information may include your IP address, the address of the website you visited that uses Vimeo features, browser type and settings, the date and time of your request, information about how you use Vimeo, and cookies.

More information about data collection, how Vimeo evaluates and processes your information and your rights can be found in Vimeo’s privacy policy:  http://www.vimeo.com/privacy

Use of Facebook, Google+, LinkedIn, Twitter and Instagram plugins

On our website we may use so-called social plugins («plugins») of the social networks Facebook and Google+ and the microblogging services of Twitter and Instagram. These services are offered by the following companies: Facebook Inc., Google Inc., Twitter Inc. and Instagram LLC («Providers»).

• Facebook (social media)

Data protection for the use of Facebook plugins («like» button)

Our pages may integrate plugins of the social network Facebook, provider Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA. You can recognize the Facebook plugins by the Facebook logo or the «like» button » on our page. An overview of Facebook plugins can be found here: http://developers.facebook.com/docs/plugins/

When you visit our site, the plugin creates a direct connection between your browser and the Facebook server. Your IP address will inform Facebook that you have visited our site. If you tap the Facebook «Like» button while logged in to your Facebook account, you can link the content of our pages to your Facebook profile. This will allow Facebook to associate the visit to our pages with your user account. It should be noted that, as providers of the web pages, we do not receive information about the content of the transmitted data or about the use that Facebook makes of them. For more information see Facebook’s data protection declaration at  https://www.facebook.com/policy.php

If you do not want Facebook to associate your visit to our pages with your Facebook account, please log out of your Facebook username and account.

Conversion measurements with the Facebook pixel

With your consent, we use the «Visitor Action Pixel» of Facebook Inc., 1601 S. California Ave, Palo Alto, Ca 94304, USA («Facebook») as part of our Internet presence. We may use it to track the actions of users who have viewed or clicked on a Facebook ad. This allows us to track the effectiveness of Facebook advertising for statistical and market research purposes. In this sense, the data collected is anonymous to us, that is, we do not see the personal data of individual users. However, Facebook will store and process this data, which will be communicated to you to the best of our knowledge. Facebook may connect such data to the Facebook account and use its own advertising, in accordance with Facebook’s use policy. https://www.facebook.com/policy.php

You will be able to enable Facebook, as well as its partners, to turn Facebook ads on or off. For these purposes, a cookie may also be stored on your device.

Only users over 13 years of age may grant this consent. If you are a minor, please ask an educated person for advice.

• LinkedIn (social media)

Data protection declaration for the use of LinkedIn

Our website may use features of the LinkedIn network. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. A connection to the LinkedIn servers will be generated by accessing our website that includes LinkedIn functions. LinkedIn is informed that you have visited our site via your IP address. If you click the «recommend» button on LinkedIn and are logged into your LinkedIn account, LinkedIn will be able to connect your visit to our website with you and your user account. We inform you that as operators of this website, we have no knowledge of the content of the data that is transmitted to LinkedIn or how it is used.

For more information, see LinkedIn’s privacy policy at:  https://www.linkedin.com/legal/privacy-policy

• Twitter (social media)

Data protection declaration for the use of Twitter

Functions of the Twitter service may have been integrated into our website. Twitter Inc., Twitter, Inc. 1355 Market St, Suite 900, San Francisco, CA 94103, USA offers such functions. By using Twitter and the «retweet» function, the websites you visit are linked to your Twitter account and are public to other users. This data is also transmitted to Twitter.

We inform you that as the provider of the sites, we have no knowledge of the content of the data transmitted and its use through Twitter. For more information, see Twitter’s protection policy at:  https://twitter.com/es/privacy

Regarding the privacy settings on Twitter, you can change the account settings through  https://twitter.com/settings/account 

• Instagram (social media)

Data protection declaration for the use of Instagram

Functions of the Instagram service could have been integrated into our website. Such features are provided by Instagram, operated by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA (“Instagram”).

When you access a page of our website that contains such a plugin, your browser will establish a direct connection to the Instagram servers. The respective provider will transmit the content of the plugin directly to your browser and integrate it into the page. Through such integration, the provider will receive the information requested by your browser to the corresponding page of our website, even if you do not have a profile or are not logged in. This information (including the IP address) is transmitted directly from your browser to the server of the corresponding US provider where it is stored.

If you are connected to the service, the providers can directly track your visit to our website and your Instagram profile. If you interact with the plugins, for example by pressing the «Instagram» button, this information will also be transmitted directly to the provider’s server where it will be stored. The information will also be published on the social network, on your Instagram account and will be public to your contacts.

You can find more information about the purpose and extent of data collection and the treatment and subsequent use that the provider will give them, as well as your rights in this regard and the configuration options of privacy protection in the policies of Instagram protection:  https://help.instagram.com/325135857663734/

• Pardot Marketing Automation System

On some of our websites we use the marketing automation system of Pardot LLC, 950 East Paces Ferry Road, Suite 3300 Atlanta, GA 30326, USA («Pardot Marketing Automation System»). Pardot’s Marketing Automation System is specialized software for capturing and evaluating movement profiles of website visitors. If Pardot LLC processes personal data, it will do so solely on our behalf and in accordance with our instructions. We enter into an individual agreement with Pardot LLC in accordance with the EU data protection directive.

However, as a preventive measure, we advise that Pardot’s marketing automation system uses «cookies» that are stored on individual users’ devices and that allow analysis of the use of the website. You can prevent the storage of cookies at any time through the corresponding settings in your Internet browser. However, by blocking these cookies, some of the features and uses we offer may be restricted.

• google maps

We may integrate Google Maps on our website to display geographic information. In accordance with Law No. 19,628 on the Protection of Personal Data, and any other applicable regulations, this serves to safeguard our legitimate interests, which prevail when valuing interests, in an optimized representation of our offer in individual locations.

Google LLC offers Google Maps ( www.google.com ).

Google LLC’s headquarters are in the United States. This country has an adaptation regulation from the European Commission. This refers to the EU-US Privacy Shield, under which Google LLC has been certified. You can access the current certificate here:  https://www.privacyshield.gov/list

When accessing a website that incorporates Google Maps, the Google web server automatically collects the access data in so-called server log files, which your browser automatically communicates, for example the name of the requested file, the last website visited, date and time of retrieval, browser used, amount of data transferred, IP address, requesting provider, etc. When using Google Maps, Google also processes data about the use of the map functions of website visitors.

For more information about Google’s privacy policy and configuration options, visit  https://policies.google.com/privacy

• Google reCAPTCHA

In order to protect against misuse of our web forms as well as spam, we may use the services of Google reCAPTCHA as part of some forms on this website. By checking manual input, this service prevents automated programs (so-called «bots») from carrying out abusive activities on this website. In accordance with Law No. 19,628 on the Protection of Personal Data, and any other applicable regulations on the preservation of our justified legitimate interests in the protection of our website against improper use and as an interference-free representation of our online presence .

Google LLC offers Google reCAPTCHA ( www.google.com ).

Google LLC’s headquarters are in the United States. This country has an adaptation regulation from the European Commission. This refers to the EU-US Privacy Shield, under which Google LLC has been certified. You can access the current certificate here:  https://www.privacyshield.gov/list

Google reCAPTCHA uses a code embedded in this website, called JavaScript, as part of the review methods that allow us to analyze your use of the website, such as cookies. The automatically collected information about your use of this website, including your IP address, is generally transmitted to a Google server in the United States where it is stored. Google reCAPTCHA also evaluates other cookies stored by Google services in your browser.

No personal data is read or stored from the fields that are entered in the corresponding forms. For more information on Google’s privacy policy, visit  https://policies.google.com/privacy

You can prevent Google’s collection of the data generated by JavaScript or the cookie relating to your use of the website (including your IP address) as well as Google’s processing of such data through your browser settings. Please note that such action may limit the functionality of our website during your use.

1.1.7 REGISTRATION FOR CLOSED USER GROUPS

Limited access for special user groups

We can only share specific information, such as details of our products, with a limited group of people. Consequently, we may request the following personal data from you:

• Name and surname
• Username and password
• Email address
• Collegiate number
• RUT
• Profession
• Specialty
• labor direction
• Phone

This will allow us to be more communicated and thus we will be able to:

• Get in touch with you in person or remotely, using channels such as SMS, instant messaging, emails, voice calls, video conferences, and any other platform.
• Deliver medical samples to your office or work address.
• Send you, physically or digitally, information that is of interest to you, for example, Continuing Medical Education, events and medical congresses, among others.

We process such personal data in order to grant you access to our website. They will be deleted in the case of requesting that your user account be deactivated.

1.1.8 INFORMATION ON SIDE EFFECTS AND QUALITY CLAIMS

Please note that our website is not designed or intended to provide communications about side effects, lack of therapeutic effectiveness, medication errors, gray market/counterfeit drugs, misuse or off-label use, claims regarding quality/or other issues about the safety or quality of our products.

In case you want to report side effects or quality complaints, you can do so by contacting your healthcare professional (for example, your doctor or pharmacist) or the Chilean Institute of Public Health. You can also use the notification form of our portal dedicated to the notification of suspected adverse effects ( https://www.grunenthal.cl/grt-web/172100848.jsp  ) or write a message to the following email address: drugsafety.CL@grunenthal.com

You should be aware that if you report unwanted side effects or other issues about the safety and quality of our products, we will be legally bound to address your report and may need to contact you to clarify the issues. Subsequently, and consequently, we may have to notify the health authorities of your information, which will be sent using a pseudonym, which means that information by which you can be directly identified will not be sent. We may also need to send notifications using pseudonyms to the Grünenthal group and/or cooperating partners, as they may also be required to notify the appropriate health authorities.

1.1.9 USER SURVEYS

Sometimes we conduct surveys among users of our website, completing them is voluntary. We use functional cookies to conduct user surveys. The technical information recorded in user surveys is the same as that recorded when users visit the website (see above). The responses submitted in the user survey will not be linked to your personal data such as your IP address.

1.2 ACCESS TO DATA FOR TREATMENTS ON OUR ACCOUNT

In some cases we will use specialized service contractors to process your data. They are carefully selected and regularly checked. They will only process personal data following our instructions and strictly in accordance with our directives, based on the corresponding data processing agreements.

1.3 DATA PROCESSING OUTSIDE CHILE

Part of your data could be processed outside the national territory, in which case we will ensure that we achieve sufficient levels of protection for your data, for example by entering into specific agreements with our contractual partners.

2. INFORMATION ABOUT YOUR RIGHTS

In accordance with data protection regulations, you have the following rights:

• right to information about the personal data we store;
• the right to request that the processing of your personal information be corrected, erased (as long as we are not legally required to maintain such information) or restricted;
• right to object to processing for reasons of our own legitimate interest, public interest or characterization, unless it can be proven that there are compelling, justified reasons beyond your interests, rights and freedoms, or that such processing is carried out for the purposes of assert, exercise or defend legal claims;
• right to the portability of your information;
• right to file a claim with the information protection authorities.
• right to revoke your consent to the collection, processing and use of personal data at any time, with effect for the future. For more information, please consult the previous sections in which the data processing based on your consent is described.

If you wish to exercise your rights, please submit your request through the contact form in the email that you will find below.

3. CONTACT

Do you have any questions about the data protection we offer? If so, please contact us! You can use our contact form or write to our data protection team at the following address: dataprivacy.cl@grunenthal.com

REQUESTS AND CLAIMS

If, as the owner of the data, you do not agree with the way in which Grünenthal or people at Grünenthal treat your data, please contact us at: dataprivacy.cl@grunenthal.com or by calling 800 210 129

Finally, we inform you that you can file a claim with the competent authorities, especially when you consider that you have not obtained satisfaction in the exercise of your rights, through the enabled website and/or the channels that we have made available to you.

4. MODIFICATION OF THE DATA PROTECTION DECLARATION

From time to time, we may update our data protection statement and will post such updates on our website. They will enter into force with their publication, so we recommend that you visit our site regularly to stay informed of possible modifications.

This data protection declaration was last updated in March 2019.