Privacy notice

This Privacy Notice describes how and for which purposes Boehringer Ingelheim Vetmedica GmbH (hereafter “Boehringer Ingelheim”, “we”, “our”, “us”) processes the personal data we collect about you through this COMBAT solution. In any event, we respect your privacy and will only collect and process your personal data in accordance with applicable data protection and privacy laws (i.e. the European General Data Protection Regulation - GDPR).This Privacy Notice explains (a) what kind of personal data we collect when you use the COMBAT app and (b) how we process such personal data within the COMBAT app.

CONTENT

1.WHAT IS PERSONAL DATA?
2.PURPOSES OF DATA PROCESSING
- 2.1. Registration, account data and communication
- 2.2. Log data
- 2.3. Use of cookies and related data processing with the help of technologies
- 2.4. Further purposes
3. TRANSFER OF PERSONAL DATA
- 3.1. Reporting obligations to regulatory authorities and enforcement of rights
- 3.2. Service provider (Processor)
- 3.3. Boehringer Ingelheim companies
- 3.4. Transfer to third parties
- 3.5. Social plugins and third-party content
- 3.6. Data transfer to recipients outside the EU
4.RETENTION PERIODS
5.YOUR RIGHTS
6.CONTACT AND QUESTIONS
7.CHANGES TO THIS PRIVACY NOTICE

1. WHAT IS PERSONAL DATA

Personal data means any information relating to you, provided that you can be identified or are identifiable (directly or indirectly) with such information. For example, personal data includes your name, address, phone number and email address. By contrast, it does not include information of a general nature that does not identify you (for example, the number of users of the Platform).

2. PURPOSES OF DATA PROCESSING

2.1. Registration, account data and communication
We process your data in order to provide you with the services on this COMBAT app, for example when you create a report as guest or registered user, register or log in, to operate, provide, manage, maintain and support the COMBAT app and the functioning of the COMBAT solution in accordance with the Terms of Use that form the contractual basis for your use of the COMBAT app.

The legal basis is Article 6 (1) b) GDPR

Where necessary, you can modify the data by editing your account/profile via the settings of the app (in case of a password-protected area) or by sending an e-mail to info@boehringer-ingelheim.com asking to have your account data modified.
2.2. Log data
When you are using the COMBAT app, we receive log data sent by your browser and/or including data sent by your device (e.g. unique device or card identifiers, IP address, time and date, content viewed). Collecting log data is technically required to enable you to use our app (the legal basis is Art. 6 (1) b) GDPR) and, if necessary, to review and assert our and third-party's rights in the event of damage or violations of legal regulations, our terms of use and the rights of third-parties. The legal basis is Article 6 (1) b) GDPR. The log files will be stored for as long as necessary for the respective purpose, in principle no longer than 14 days.
2.3.Use of cookies and related data processing with the help of technologies
We use cookies (small text files placed on your browser) and similar Technologies such as pixel tags (hereinafter referred to as “Cookies”). The respective cookies can be divided into (a) essential and (b) non-essential cookies and/or Local Storage functionalities.
2.3.1.Essential Cookies and Local Storage functionalities
Essential Cookies and Local Storage functionalities are necessary for the app to function properly by providing basic features such as resuming a user's session when the app is reopened. Such Technologies may be stored on your device or process data stored on your device. Legal basis is Art. 6 (1) b) GDPR and Section 25 of the German Telecommunications Telemedia Data Protection Act) We store these essential Cookies for up to one year.
2.3.2.Non-essential cookies and local storage functionalities for optimization and analysis
Based on your consent, we set Cookies and local storage functionalities for analytical purposes to asses how you're using our app. This way, we collect information about how well certain services are received and we can adjust and improve them.

You may withdraw your consent at any time here. With your consent, we use the following services:

Adobe Analytics (Omniture)
Cookies from Adobe Analytics allow us to analyze all traffic and usage patterns of individual users (without further identification) or groups (e.g. which services are used how often, how frequently do users return, how long do they stay, which websites and which region are users coming from). This cookie is stored for up to three years.

Adobe Analytics is a service of Adobe Systems Software Ireland Limited. Adobe acts as our processor. In exceptional cases, data may be transferred to the U.S. Therefore, we concluded the EU Standard Contractual Clauses with Adobe in the U.S.

The data processing by Adobe Analytics may include the following information:
- • information about your web browser and device (such as device type, web browser type, advertising identifier, operating system, connection speed and display settings);
- • your IP address, which may be used to approximate your general location (in order to protect your personal data as much as possible, your IP address is shortened and replaced with a generic IP address); and
- • location information from your mobile device or web browser.
- Please note that Adobe may also process the data collected from you for its own purposes. Since we have no influence on such processing by Adobe, Adobe is solely responsible for such processing for its own purposes.
  
  Please also note that Adobe is likely processing your personal data in countries outside the European Union (EU) / the European Economic Area (EEA), in particular the U.S. The U.S. is a so-called third country for which there is no adequacy decision of the European Commission pursuant to Art. 45 GDPR and it cannot be guaranteed that Adobe can ensure an adequate level of data protection in accordance with the requirements of the GDPR. In particular, it cannot be ruled out that U.S. authorities may be able to access your personal data and that no effective legal remedies are guaranteed for EU citizens.
  
  We use Adobe Analytics exclusively on the basis of your consent (Art. 6 para. 1 lit. a GDPR), which you may withdraw at any time here. Your consent to the use of Adobe Analytics is not required for the use of the Platform and the Platform Services.
  
  For further information about Adobe Analytics, please see Adobe’s privacy policy.
- 2.4.Further purposes
  If necessary, we process your personal data for additional purposes:
  - •satisfying our legitimate interests (Art. 6 (1) f) GDPR), including the following:
  - (i) to complete a corporate transaction (e.g., corporate restructuring, sale or assignment of assets, merger);
  - (ii) to protect, enforce and defend our rights, property and interests;
  - • ensuring compliance with legal obligations, court orders or other binding decisions of public authorities (Art. 6 (1) c) GDPR)
  - • as a contractual/statutory requirement according to Art. 13(2)(e) GDPR.

3. TRANSFER OF PERSONAL DATA

We do not share personal data with any third party, unless this (a) is necessary to provide the app and/or its services, (b) is permitted by applicable law or (c) has been agreed by you:

3.1. In order to comply with legal reporting obligations, to protect our rights and/or the rights of third-parties, we may share and disclose personal data to rights holders, consultants, courts and competent authorities in accordance with legal provisions (e.g., mandatory reports in respect of a suspected adverse event).
3.2. We engage service providers to process your personal data for the purposes described in this privacy policy. These service providers process the data only on our behalf, according to our instructions, under our control and in accordance with this privacy policy.
3.3. As part of a global group of companies, we involve other Boehringer Ingelheim companies that support us with data processing (e.g., as part of our pharmacovigilance obligations to analyze and process a reported adverse event). These group companies process the data exclusively for the purposes stated in this privacy policy as Joint Controller according to Art. 26 GDPR.
3.4. We may transfer data to contractual partners who process data under their own responsibility and for their own purposes (e.g., LinkedIn or Twitter, if you have given your consent). The data is transferred solely for the purposes described in this Privacy policy.
3.5. We have not implemented any tools, by which information is automatically transferred to the provider of social media services when you visit our website (Social Plugins).

Any forwarding to social media providers such as YouTube for example takes place exclusively via link, so that data about your visit to our services (e.g. IP address, time, URL) or data available on your end device (e.g. Cookie information) is only transmitted to the respective providers when the link is consciously used.
3.6. Authorities, service providers, business partners and Boehringer Ingelheim companies may process personal data outside the EU. In these cases, we ensure an adequate level of data protection to comply with European law (usually through EU standard contractual clauses published by the European Commission or, if necessary, other appropriate safeguards). You can request a copy of the contract that implements the appropriate protection of personal data by contacting our Data Privacy Officer using the contact details set out below.

4. RETENTION PERIODS

Boehringer Ingelheim will store your personal data as long as it is necessary for the respective purposes, which is usually to provide the services you have requested. This means for example, that we store your user account data (login, profession, name etc.) until you delete it. In some cases, we are obliged to store your data for longer in order to comply with statutory retention periods.

We have specified retention periods for certain processing purposes.

5. YOUR RIGHTS

You have the right to:

•request information about your personal data processed by Boehringer Ingelheim;
•in justified cases, request deletion, rectification or restriction of the processing of your personal data;
•in certain circumstances, request transfer of your Personal Data to you or another person in a commonly utilizable format;
•file a complaint with a data protection authority;
•request the deletion of your Personal Data if they are no longer necessary for the purposes of processing or there is no legal ground for their further processing.
•object to processing of your Personal Data at any time as far as such processing is only based on Boehringer Ingelheim’s legitimate interest (Art. 6 (1) f) GDPR). In this case, we will not process such personal data any longer, unless the interests of Boehringer Ingelheim prevail. You can object to the use of data for direct marketing purposes at any time without a weighing of interests.

Should you have given your consent to the processing of your personal data, you can withdraw it at any time with effect for the future; such withdrawal will not affect the lawfulness of the processing until such withdrawal.

6. CONTACT AND QUESTIONS

If you have any questions about this Privacy Notice or about how we use your personal data, please contact us at the following address:

Boehringer Ingelheim Vetmedica GmbH
- Data Protection Officer –
Binger Strasse 173, D-55216 Ingelheim am Rhein, Germany
E-Mail: datenschutz@boehringer-ingelheim.com

If you still have questions or concerns regarding data processing, you can also contact any supervisory authority. The authority responsible for Boehringer Ingelheim is:

Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit
Rheinland-Pfalz
Hintere Bleiche 34, 55116 Mainz, Germany
E-mail: poststelle@datenschutz.rlp.de

7. CHANGES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in compliance with the legal requirements. This may be the case, for example, to comply with new legal requirements or to reflect new features within the app.. Updates of our Privacy Statement will be published on this app. Any amendments become effective upon publication on this app.

Last updated: October 2022