Effective Date: May 25, 2018
This EU General Data Protection Regulation (GDPR) Privacy Notice explains how Allergan plc, including our affiliated entities (referred to collectively as “Allergan,” “we,” “our,” or “us”) handles your Personal Data and can include Personal Data about others where you share their Personal Data with us. It details how we collect your Personal Data, why we collect it, and to whom we may share it. This Privacy Notice also discloses your Personal Data rights. It applies to all your Personal Data, including Personal Data stored electronically or in hard copy.
Allergan collects and processes your Personal Data, which can come directly from you, publicly available sources (for example, academic journals you may have published an article in), or third-parties with whom we contract (for example IMS/IQVIA). Personal Data includes all information that identifies you or can be used to identify you.
The types of your Personal Data we collect depends on the nature of your relationship with Allergan and applicable laws. The Personal Data we process about you, includes the data we collect directly from you either as part of your business relationship with us or through other interactions you may have with us.
In addition, we may obtain Personal Data about you from publicly available sources and third parties, which may include the following categories of Personal Data:
Processing of your Personal Data includes where we may record, organize, structure, store, adapt or alter, retrieve, consult, use, disclose by transmission, dissemination, or otherwise make available, align or combine, restrict, erase, or destroy your Personal Data.
We may process your Personal Data for the following purposes:
For any additional purposes where we are required to notify you and get your consent, including those purposes required by local law, we will obtain your consent before we process your Personal Data for those purposes.
The applicable legal basis for which we process your Personal Data for the specific purposes listed above, include the following:
We will share or disclose your Personal Data with the following entities:
We may transmit your Personal Data to our other global affiliates. Allergan affiliate names and contact details can be found at https://www.allergan.com/home. Additionally, these affiliates may further transmit your Personal Data to our other global affiliates. Some of our affiliates and their database locations may be in countries that do not ensure an adequate level of data protection similar to the laws in the country in which you reside. Regardless, all our affiliates are required to treat your Personal Data in accordance with this Privacy Notice and our privacy and data protection policies and procedures.
EU-US and Swiss-US Privacy Shield Notice: Allergan and its affiliates in the United States may receive Personal Data from individuals in the European Economic Area (EEA) and Switzerland. We comply with the EU-US and Swiss-US Privacy Shield Principles (Privacy Shield Principles), with respect to the collection, use, and retention of Personal Data from the EEA and Switzerland. If there is any conflict between the terms of this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles will govern. For more information about the Privacy Shield Framework and to view our certification, go to https://www.privacyshield.gov/. The International Centre for Dispute Resolution (ICDR) acts as our third-party dispute resolution provider, as required by the Privacy Shield Framework. If you have a complaint about our Privacy Shield compliance, you can contact us directly or contact the ICDR at https://www.adr.org/aaa/faces/services/fileacase. In certain circumstances it may be possible for you to invoke binding arbitration. We are subject to the investigatory and enforcement powers of the US Federal Trade Commission regarding our adherence to the Privacy Shield Principles.
We may transmit your Personal Data to our third parties with whom we contract to carry out services on our behalf to perform activities or functions related to the processing purposes regarding your Personal Data that are described above. Our third parties are contractually obligated to comply with applicable laws or regulations, including having a valid EU Personal Data cross-border transfer mechanism in place to receive the EU personal data, which can include an “adequacy” determination by the European Commission, EU-US and/or Swiss-US Privacy Shield certifications, and/or executing EU Standard Contractual Clauses with us.
For more information about our cross-border transfers of your Personal Data, please contact us using the information as described in the “how do you contact us” section below.
We use industry-standard administrative, technical, and physical safeguards to protect your Personal Data against loss, theft, misuse, unauthorized access, modification, disclosure, and destruction. We restrict access to your Personal Data to only those employees and third parties acting on our behalf who have a legitimate business need for such access. We will only transfer your Personal Data to third parties acting on our behalf where we have received written assurances that your Personal Data will be protected in a manner consistent with this Privacy Notice and our privacy policies and procedures.
Your Personal Data will be maintained for the duration of your relationship with us. We will store and retain the Personal Data we collect about you in accordance with our Corporate Record Retention Policy, after which it will be archived or deleted. A detailed schedule of our retention practices can be found at https://www.allergan.com/home. Please note that certain information could be retained for longer periods of time if we have continuing obligations to you or if required by local law.
You have the right to see and get a copy of your Personal Data, including an electronic copy, that we have as well as to ask us to make any corrections to inaccurate or incomplete Personal Data we have about you. You can also request that we erase your Personal Data when it is no longer needed for the purposes for which you provided it, restrict how we process your Personal Data to certain limited purposes where erasure is not possible, or object to our processing of your Personal Data. In certain circumstances you may be able to request that we send a copy of your Personal Data to a third party of your choosing.
To exercise any of these rights, please contact us as set forth in the “how do you contact us” section below. You also have the right to lodge a complaint with the supervisory authority (see details under “remedies” below) where you believe that your rights have been violated.
From time to time we may make changes to this Privacy Notice to reflect changes in our legal obligations or the ways in which we process your Personal Data. We will communicate to you any material edits to this Privacy Notice and it will become effective when it is communicated.
Please contact Allergan’s EU Data Protection Officer (DPO) using the below information to:
Allergan’s EU DPO
Allergan Ltd, Marlow International Parkway, Marlow, Buckinghamshire, SL7 1YL, UK
For more information about your privacy and data protection rights, or if you are not able to resolve a problem directly with us and wish to make a complaint, please contact your country-specific data protection authority or Allergan’s lead data protection supervisory authority:
Irish Data Protection Commissioner
Canal House, Station Road, Portarlington, R32 AP23 Co. Laois
+353 57 8684800
+353 (0)761 104 800
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