Privacy Notice

The operation of the Hub is a joint effort between two companies, each handling a distinct portfolio of products and content. Throughout the notice you may find this distinction being made. You may find the details of each of the data controllers below:

For matters relating to the Established Medicines portfolio:

Kyowa Kirin International UK HoldCo Ltd (to be renamed KKI Grunenthal UK HoldCo Ltd.) and Kyowa Kirin International UK NewCo Ltd (together known as “Grünenthal Meds”) is the controller of your personal data collected about you through this Hub

If you have any questions regarding this privacy notice or wish to exercise any of your rights, please contact any of the below entities, depending on the type of product line you use. You can also contact our Data Protection Officers:

For matters relating to the Established Medicines portfolio:

Controller contact details: Grünenthal Meds at dataprivacy.grt-meds@grunenthal.com

DPO contact details at: dpo-grunenthalmeds@kinast.eu

This Privacy Notice is designed to help you understand how we manage your personal information when you visit the Hub..

There are certain circumstances where different terms regarding how we handle your personal information may apply. If a data collection undertaken by us has its own terms, those terms - not this Privacy Notice – will apply.

If you are a healthcare professional, you might want to check the specific privacy notices for healthcare professionals provided by the Hub’s data controllers, available in the links below:

For matters relating to the Established Medicines portfolio:

at GRT Privacy Notice

Personal data means all information that can directly or indirectly identify you or other individuals. We collect different types of personal data depending on the context of your interactions with us

We collect the following types of information:

Personal data provided directly by you

We collect your contact / professional details, preferences and other data you share with us:

• when you reach out to us to ask questions or to otherwise interact with us;
• completing forms and surveys or if you provide feedback about a product
• or therapy area; when you visit the Hub and moreso when you create an account.

Personal data collected automatically when accessing the Hub

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

• IP address
• Date and time of access
• Time zone difference to Greenwich Mean Time (GMT)
• Content of request (specific site)
• Status of access/HTTP status code
• Transferred volume of data
• Website requesting access
• Browser, language settings, version of browser software operating system and surface We will also store such data for a limited period of time so that we are able to initiate a tracking of personal data in the event of actual or attempted unauthorised access to our servers.

Use of cookies

What cookies are: Cookies are small text files stored in your terminal's memory via your browser. They store certain information (for example your preferred language or site settings). Your browser may retransmit these to us when you revisit our website, depending on the lifespan of the cookie.

Cookies we use: We differentiate between two categories of cookies: (1) functional cookies which are necessary for the functionality of our website and (2) optional cookies. These are used for website analysis and marketing purposes. You can find a detailed list of the cookies that we use in the cookie banner that pops up when you access our website or by clicking on the “privacy settings” symbol.

Subject to your consent: We only use optional cookies if we have obtained your prior consent. When you visit our website for the first time, a banner will appear asking you to give us your consent to the setting of optional cookies.

Please visit our Cookies Notice for more detailed information.

Accessing to private areas of the website

Some of our Hub pages are gated behind a registration page where you can access more content directed to healthcare professionals. In addition, some private portions of our websites also require you to register with your personal data and login details to access valuable or premium content linked to specific therapy areas, such as:

• on-demand publications;
• videos;
• brand promotion;
• other disease awareness materials;
• learning platforms;
• and medical education-related content.

This registration and processing of your personal data are valued as a proper and justified counter-performance for the content.

Information that you need to provide in order to register to our Hub are the following data categories:

• Title
• First Name
• LastName
• Work Email
• Password
• Role Speciality
• Job Title
• Workplace
• Department (Hospital HCPs)
• Department Phone Number
• Practice Number

Information from other sources

We also may obtain information related to you from other sources, including our service providers (such as technology providers), public sources (such as professional registration databases and publicly accessible social media content). We also receive information about your professional life (such as medical specialisation and professional background) from data suppliers, such as IQVIA. We occasionally purchase contact information. We always check the vendor obtained the data in a lawful manner; Lastly, we may receive data related to you from learning platforms and course management systems (e.g. training records which may also include your full name and email address).

We use information held about you for different purposes depending on the type of relationship we have with you.

We use your information for the following purposes:

• to conduct our day-to-day businesses, including the delivery of products and services;
• For market research;
• managing our relationship with you, including responding to your requests and notifying you about changes to our products or services;
• To understand your needs and seek your views on our products and services, or in the context of a therapeutic area or disease;
• To provide content and facilitate access to information through various communication channels, including through our websites and applications;
• To improve our level of service and our sites ensuring content is presented in the most effective manner for you and your computer;
• To enable new ways of communication and interactions;
• To manage events, webinars, newsletters, and media communication channels;
• For security and internal operations, including troubleshooting and testing;
• To provide educational coursework and trainings;
• For administrative and quality assurance purposes;
• To comply with our contractual obligations;
• To comply with laws and regulations;
• To manage and follow up on adverse events reports;
• To record, investigate and respond to complaints;
• For the establishment, exercise or defence of legal claims and to defend our rights;
• Analytics, profiling and marketing (see more details in the next section).

We use information held about you for different purposes depending on the type of relationship we have with you based on several lawful reasons for us to process your personal data. We usually rely on consent, the performance of a contract, compliance with laws and legitimate interest.

In particular:

• Performance of a contract: to manage your Hub account and conduct our day-to-day business when we have a contract with you, and for the delivery of products and contractual services.
• Compliance with legal obligations: when required to comply with our obligations in accordance with applicable laws and regulations, pharmacovigilance, tax, IP and employment laws (when there is such a relationship with you), including transparency, or to prevent and detect crimes, such as fraud, corruption and bribery.
• Consent: when we rely on consent, you can withdraw it at any time. For example, we use consent:
  • For non-essential cookies or similar technologies;
  • for transparency reporting, when consent is required;
  • for certain types of email communications, including newsletters;
  • for participating in certain events, electronic marketing communication and media communication projects
  • to coordinate your participation and attendance to webinars, surveys or e- conferences, when consent is required.
• Legitimate interest: For the rest of purposes, if none other legal basis apply, we use legitimate interest pursued by us insofar as such interests do not pose a high risk to your rights and freedoms. For example, we rely on the legitimate interest for the following purposes:
  • managing our relationship with you, including responding to your requests and notifying you about changes to our products or services;
  • To provide content and facilitate access to information through various communication channels through the Hub;
  • To improve our level of service and our site ensuring content is presented in the most effective manner for you and your computer;
  • To enable new forms of engagement and communication;
  • To understand your needs and seek your views on our products and services, or in the context of a therapeutic area or disease, when consent is not required;
  • To manage events, webinars, newsletters, and media communication channels
  • For security and internal operations, including troubleshooting and testing;
  • To provide educational coursework and trainings;
  • For administrative and quality assurance purposes;
  • To record, investigate and respond to complaints;
  • For the establishment, exercise or defence of legal claims and to defend our rights;
  • Analytics, profiling and marketing, when consent is not required.

The Hub is not directed to children.. 

The Hub does not seek to collect personal information from individuals under the age of 18. Individuals under the age of 18 should receive permission from their parent or legal guardian before providing any personal information to us via this Hub.

As a parent or guardian, if you have knowledge that we have collected information from your child through this website, please contact us at the Contact information above to request removal.

We will hold your personal data on our systems for as long as is necessary to fulfil the purposes that we collected it for, including for the purposes of satisfying any legal, accounting or other reporting requirements.

By law, we are required to retain certain information for a prescribed period of time. In circumstances where there are no such legal requirements, to determine the appropriate retention period, we will consider the nature of the personal data, the purposes for which we are processing your personal data and the potential risk of harm from unauthorised use or disclosure of your personal data.

Therefore, some information may be kept for more or less time according to our retention policy and applicable laws.

We will NOT sell your personal data to any third parties. We may disclose your personal information with any member of our group or with selected third parties where we have a legal basis for doing so.

We may share your information with selected third parties including:

• Within our group – Information collected through the Hub is shared with our group and affiliates to fulfil the defined purposes. In particular:

For matters relating to the Established Medicines portfolio: with members of Grünenthal Meds group:

• Kyowa Kirin International NewCo Netherlands B.V.
• Kyowa Kirin International NewCo France S.A.S.
• Kyowa Kirin International NewCo Germany GmbH
• KKI NewCo Spain S.L
• Kyowa Kirin International NewCo Italy S.r.l.
• Kyowa Kirin International NewCo Ireland Ltd.
• Kyowa Kirin International NewCo Sweden AB
• Service providers - When we use other companies to provide services on our behalf, e.g. technology and cloud providers, marketing and communication agencies, auditors or other professional advisors, advertising networks and analytics providers, search engine providers, processing of payments, delivery, learning platforms, and other support services.
• Business transfers - If we merge with another organisation or form a new entity.
• Business partners - for the performance of any contract we enter into with them or you or when we run an event in partnership with other named organization.
• Healthcare Professionals and Clinical Research Organisations.

We may disclose your personal information to public authorities, regulators or other third parties:

• To comply with any court order or legal obligation
• When data is requested by our regulators, government agencies or law enforcement agencies or is required by any stock exchange rules;
• To protect the rights, terms of use, property, or safety of us, our employees or others (e.g. fraud protection and credit risk reduction).

We use the open source software tool Matomo (formerly PIWIK) from InnoCraft Ltd, 150 Willis St, 6011 Wellington, New Zealand on our website to analyze the surfing behavior of our users. Matomo is an open source tool for web analysis.

Matomo Tag Manager is a tag management system for managing JavaScript and HTML tags used to implement tracking, analytics and marketing tools.

Matomo uses cookies. These text files are stored on your computer and make it possible for us to analyze the use of the website. For this purpose, the usage information obtained by the cookie is transmitted to us and stored so that the usage behavior can be evaluated. Your IP address is immediately anonymized; thus you remain anonymous as a user. The information generated by the cookie about your use of this website will not be disclosed to third parties.

We understand this analysis as part of our Internet services. We would like to use it to further improve the website and adapt it even more to the needs of the users.

These processing operations are only carried out if explicit consent is given in accordance with Art. 6 (1) a) GDPR.

If individual pages of our website are called up, the following data is stored:

• Bytes of the IP address of the calling system of the user are anonymized.
• The website from which the user accessed the called website (referrer).
• The subpages accessed from the accessed website
• The time spent on the website
• The frequency of accessing the web page

In this regard, the software runs exclusively on the servers within our control and within the Matomo Cloud. We have concluded a data processing agreement with InnoCraft Ltd. about data processing on our behalf. Storage of the users' personal data only takes place there. The data is not passed on to third parties.

We store this data for a period of at least two years, unless you revoke your consent beforehand.

You can view the data protection provisions of Matomo at: https://matomo.org/privacy/

As international enterprises we consist of numerous entities worldwide, the data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”), Switzerland (“CH”) or the United Kingdom (“UK”) for the purposes described in this notice.

For more information on our companies groups please see above section 9.

It may also be processed by service providers operating outside the EEA, CH or the UK, including the United States. They work for us, among other things, to process your payment details, the provision of technology, and cloud services, marketing and communication agencies, advertising networks and analytics providers, search engine providers, specialty advisory services, or lawyers.

If we do this, your personal information will continue to be subject to an adequate level of protection or appropriate standard contractual clauses and/or other safeguards approved by the regulators. A copy of the relevant transfer mechanism can be provided for your review on request to the contact details above.

We are committed to facilitate the exercise of your rights granted by the data protection laws.

You have the following rights according to applicable data privacy laws:

• right of information about your personal data stored by us;
• right to request the correction, deletion (provided that we are not legally obliged to keep the data) or restricted processing of your personal data;
• right to object to a processing for reasons of our own legitimate interest, public interest or profiling, unless we are able to prove that compelling, warranted reasons overruling your interests, rights and freedom exist, or that such processing is done for purposes of the assertion, exercise or defense of legal claims;
• right to data portability;
• right to file a complaint with a data protection authority.
• right to revoke your consent to the collection, processing and use of your personal data at any time with future effect. For further information please refer to the chapters above describing the processing of data based on your consent.

How to exercise your rights: If you would like to exercise any of these rights, please contact us using the details set out in the ‘Contact Us’ section. We may ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal information. 

We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Links provided to external websites are governed by different terms.

Sometimes we provide links to external websites run by other organisations. In these cases, the privacy notice on these external websites will apply. We encourage you to read them if you visit these websites.

We may change this Privacy notice from time to time in response to technical, legal or business developments.

You can check the "effective date" posted to see when the Privacy Notice was last updated. If we make any material changes, we will take appropriate measures to inform you according to applicable laws.