MEAD JOHNSON NUTRITION (UK) LTD - PRIVACY NOTICE FOR HEALTHCARE PROFESSIONALS

 Last update: 01 October 2020.

Welcome to Mead Johnson Nutrition (UK) Ltd's Global Privacy Notice ("Privacy Notice").  We are a Reckitt Benckiser company.

We are committed to protecting your privacy. This Privacy Notice applies to all of our brands globally and explains how we collect, use, disclose and protect your Personal Information and respect any rights you benefit from under your local law. 

In this Privacy Notice "we", "us" and "our" refers to all the companies of the Reckitt Benckiser group. As this Privacy Notice applies globally, there may be differences in how we collect, use or disclose your Personal Information from country to country, in which case we will inform you about any specific processing activities that take place in your country. 

Your Personal Information and any other Personal Information that is shared by you and collected by us, is controlled by Reckitt Benckiser Plc (having a registered office at 103-105 Bath Road, Slough, Berkshire, SL1 3UH, United Kingdom, Europe) or our Reckitt Benckiser company located in your country. For more information about us, our local companies, our brands and our presence in your jurisdiction, please visit www.meadjohnson.com. 

Definitions

By "Personal Information" (in some countries referred to as "personal data" or "personally identifiable information") we mean any information relating to an identified or identifiable individual. This is broader than just information of a personal or private nature, and also includes information such as your name, date of birth, and e-mail address. Please see Section 3 below for what Personal Information is obtained from you. 

By "Sensitive Personal Information" (in some countries referred to as "sensitive personal information" or "special categories of data") we mean any Personal Information relating to an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data or biometric data processed for the purpose of uniquely identifying that individual, data concerning health, or data concerning an individual’s sex life or sexual orientation. It also includes information about an individual’s criminal offences or convictions, as well as any other information deemed sensitive under applicable data protection laws.

Quick Reference

1.Scope of our Privacy Notice

2.Fair and lawful processing

3.How do we obtain your Personal Information

4.For which purposes we may use your Personal Information

5.To whom we may disclose your Personal Information

6.How we protect your Personal Information

7.Your choices regarding direct marketing

8.Your rights

9.Complaints

10.How long we retain your Personal Information

11.Children

12.Transfers to other countries

13.How to contact us

14.Changes to this Privacy Notice

1.Scope of our Privacy Notice

Our Privacy Notice applies to all Personal Information we collect, use, share or otherwise process through our business activities, both online and offline, which display, link or refer to this Privacy Notice, including: 

• our websites;
• our official social media pages;
• our e-mails;
• our apps;
• our online and offline campaigns; and
• your conversations or correspondence with our representatives.

Throughout this document, we will refer to our online activities as "Sites" and to our offline activities as "Services".

You should be aware of the fact that our Sites may contain hyperlinks to third party websites, apps, etc. which are not controlled by us and which are not covered by this Privacy Notice. We have no responsibility or liability for the content and activities of these third-party websites, apps, etc. As these third parties may collect your Personal Information, we suggest that you consult the privacy policies of these third parties to learn more about their use of your Personal Information.

Our websites make use of cookies. For more information on this subject, please also consult our Cookies Policy.

Further, when using our Sites or Services, please always also read our Terms of Use.

2.Fair and lawful processing

Consent: we process Personal Information for the below listed purposes on the basis of your consent, unless stated otherwise. In some cases, where required by local law, we may ask for your explicit consent for processing Personal Information for a specific purpose. We only collect, use, disclose or otherwise process your Personal Information where it is fair and lawful to do so. Your consent may be withdrawn at any time by contacting us through the mediums described in this privacy notice. If you have shared data with us about a third party (such as a patient) with their consent, you must indicate to them that they always have the right to withdraw consent for their Personal Information to be shared with us, at any time. If they do withdraw their consent, you are required to notify us immediately, so we can stop processing their Personal Information.

Performance of a contract: in many cases providing Personal Information to us is necessary for the performance of your contract with us or the services you have requested such as our newsletter. If you do not wish to provide Personal Information to us, we may not be able to provide you with the products, samples, updates and services you have requested from us.

Legitimate interests: we may use Personal Information for our legitimate interests to improve our products, samples, services and website content and for administrative purposes.

Compliance with legal obligations: we may disclose Personal Information as permitted or required by law when we believe in good faith that it is necessary for safety purposes, required for legal reporting, necessary to protect our legal rights or to protect the rights of others.

3.How do we obtain Personal Information?

Personal Information obtained from you directly 

Firstly, we may obtain Personal Information from you directly, e.g. when you sign up for our newsletters, register on our Sites, buy a product from us, request a sample from us, fill out a survey, make a comment or enquiry, post something on our social media pages, subscribe to direct marketing etc. 

Personal Information collected this way may include (but is not limited to): 

• name;
• address;
• e-mail address;
• user name;
• telephone number (and recordings when you call our consumer line);
• credit card or other payment information;
• age;
• date of birth;
• due date;
• your date of birth;
• gender;
• product purchase and usage information;
• household information;
• information, feedback or content you provide regarding your marketing preferences;
• user-generated content, posts and other content you submit to our Sites;
• information about other individuals or third parties (such as your patients) that you have provided to us. In such cases, we assume that you have the authority to share any personal information your provide to us about them and you must be able to demonstrate that you have collected such consent if we request it;
• in limited circumstances based on your explicit consent or for carrying out our legal obligations or if necessary for reasons of substantial public interest, Sensitive Personal Information such as information relating to your image, health (including information related to product usage and medical history), sexual life (and related behaviour) and biometrics collected during volunteer consumer research studies (such as facial expression recognition, heart rate and skin condition); 
• in limited circumstances (and only upon being granted your patient’s explicit consent to do so) we will collect your patient’s date of birth or actual age, to be able to provide you with age appropriate suggestions and information;
• demographic information; or
• any other Personal Information you voluntarily provide us with directly.

Personal Information collected automatically 

Secondly, some Personal Information may be collected automatically when you visit or use our Sites (and those of our third-party service providers acting on our behalf), such as information collected by cookies and other technologies (such as web analytic tools and pixel tags) on our websites. Please also consult our Cookies Policy for more information on how we make use of cookies and similar technologies. 

Personal Information collected this way may include (but is not limited to):

• information about your (mobile) device or your type of browser;
• information about the way you use our websites, such as details of the web pages you have viewed, the banners and the hyperlinks you have clicked, etc.;
• whether you have opened e-mails sent by us to you;
• the websites you have visited before arriving at one of our websites;
• your IP address;
• the hyperlinks you have clicked;
• your user name, profile picture, gender, networks and any other information you choose to share when using third party sites (such as when you use the “Like” functionality on Facebook or the +1 functionality on Google+);
• your MAC address;
• information you choose to share by using social media tools incorporated in our websites or using your social media log-in details to access certain of our product sites or applications; and
• information you share with us about your location. Where we are required to do so by local law, we will only use that information where you have agreed that we can.

Personal Information obtained from other sources 

Lastly, we may also collect Personal Information about you or third parties from other sources. These other sources may include (but are not limited to): 

• other health care professionals;
• service providers for health care professionals;
• regulatory and professional bodies (such as the General Medical Council or the General Pharmaceutical Council);
• public bodies (such as HMRC or the Home Office);
• our trusted advisors (such as external lawyers, auditors, financial, tax and public relations advisors);
• our trusted business partners; 
• social media sites; 
• consumer research organisations;
• credit reference agencies;
• intermediaries that facilitate data portability; and
• other members of our group.

Personal Information collected this way may include your interests such as names, addresses, telephone numbers, hobbies, consumer and market research data, purchase behaviour, publicly observed data or activities such as blogs, videos, internet postings and user generated content.

4.For which purposes may we use your Personal Information

We use your Personal Information for our following purposes:

• based on your contract with us, handling and managing your purchase, any requests for samples of our products or prescriptions, communicating with you in connection with your purchase, request for samples or prescription, to process your payments, to deliver any requested samples, purchased products and services, and to offer you services that may be of interest to you;
• allowing you to participate in promotions, contests, surveys and polls;
• allowing you to share information and ideas on our social media pages, forums, blogs and other communication channels, to participate in social sharing and to send messages to a friend through our Sites or the websites of our trusted business partners;
• better understanding your needs in order to provide you with more relevant information, analysing and evaluating our corporate activities, testing, developing and evaluating new products and improving our existing products and services, conducting market research and audits, identifying user trends and examining the degree of effectiveness of our marketing campaigns and your degree of satisfaction with them;
• telling you about our products and services and sending you promotional materials (such as announcements relating to new products, promotions, savings programs, samples of our products, joint promotions and other programs) relating to our brands and those of our carefully selected trusted business partners, subject to your consent to such marketing where required by local law;
• sharing samples of our products with you (or with your patient directly if so requested); 
• managing our Sites, and tune the experience and content of our Sites to your previous activities on our Sites, in view of personalizing your experience when visiting our Sites; 
• responding to your requests or enquiries;
• dealing with any product adverse events you report to us;
• administering general record keeping;
• enabling the reporting of the number of samples to designated areas and territories; and
• meeting legal and regulatory requirements.

Your local law may require us to set out in this Privacy Notice the legal grounds on which we rely in order to process Personal Information In such cases, our use of Personal Information is permitted by law because which are as follows:

• it is necessary for our legitimate interests in the effective delivery of information, our marketing communications, services and products to you and in the effective and lawful operation of our business in each case provided such interests are not overridden by your rights;
• it is necessary for taking steps to enter into a contract with you for the products you purchase, or for carrying out our obligations under such a contract; 
• it is required to satisfy any legal or regulatory obligations that we are subject to; and
• in limited circumstances and if required by local law, you have agreed to us processing your patient’s Personal Information and Sensitive Personal Information (for which you will always be required to: (i) obtain express prior consent of the patient, or the parent or guardian of the patient if they are not of a suitable age to give such consent; and (ii) be required to share evidence of such consent being acquired by yourself, if requested by us), such as when you opt in to marketing or processing with the explicit consent of the patient, in the case of Sensitive Personal Information, such as health information;
• in limited circumstances and if required by local law, you have agreed to us processing Personal Information and Sensitive Personal Information, such as when you opt in to marketing or processing with your explicit consent in the case of Sensitive Personal Information.

We may create anonymous data records from Personal Information by excluding information (such as your name or your patient’s name) that make the data personally identifiable to you so that it can no longer be associated with you or your patient (directly or indirectly). We use this anonymous data to analyse our products and services. We reserve the right to use such anonymous data for any purpose and disclose anonymous data to third parties, including but not limited to our research partners, in our sole discretion.

5.To whom we may disclose Personal Information collected by us

Intra-group sharing

Personal Information may be collected by us shared between the different companies and brands of our group, for the purposes set out in this Privacy Notice. As we have stated above, this Privacy Notice applies to all these companies’ and brands’ use of Personal Information shared by you. For more information about us, our companies, our brands and our presence in your jurisdiction, please visit www.rb.com 

Third party service providers

We may share Personal Information collected by us with trusted third party service providers who work on our behalf, such as marketing agencies, market research companies, e-commerce fulfilment partners, software, data hosting and other IT service providers, merchants selling our products, call centres, payment processors, distribution and logistics companies etc. These third party service providers are required not to use Personal Information shared by you, other than to provide the services requested by us or otherwise in accordance with our instructions. 

Other trusted third parties

We may also share Personal Information collected by us, with other trusted third parties, such as our business partners, advertisers (where we are permitted to do so) and data exchanges, so that we can offer you tailored content, including more relevant advertising for products and services which may be of interest to you. These third parties may set and access their own cookies, web beacons and similar tracking technologies on your device in order to deliver customised content and advertising to you when you visit RB websites.

Our websites and/or applications may also allow you to log in using a social network or other third-party account. An example of a third-party login is “Log in with Facebook”. Logging into one of our sites with your social network or other third-party account may allow us to gather information that you give us permission to access from that social network or third party. The login feature may also transfer information to the social network or third party, such as your username and password, to authenticate you. The social network or third party may also automatically collect information such as your IP address, information about your browser and device and the address of the web page you are visiting on our site. The login feature may also place and read cookies from that third party that may contain a unique identifier the social network or other third party assigns to you. The functionality of, and your use of, the login is governed by the privacy policy and terms of the party that provided the login functionality, rather than this Privacy Notice.

Acquisitions

If another company acquires (part of) our company, business, or our assets, that company may acquire all or part of the Personal Information collected by us and will assume the rights and obligations regarding the Personal Information as described in this Privacy Notice. In the unlikely event of an insolvency, bankruptcy or receivership, the Personal Information may also be transferred as a business asset, subject to any applicable law.

Disclosures

We may disclose Personal Information collected by us if we believe in good faith that such disclosure is necessary for our legitimate interest or prudent in light of our obligations under applicable law:

• in connection with any legal investigation;
• to comply with relevant laws or to respond to court our authority orders, subpoenas or warrants served on us;
• to protect or defend our rights in legal procedures; or
• to investigate or assist in preventing any violation or potential violation of the law, this Privacy Notice, or any applicable Terms of Use.

6.How we protect Personal Information collected by us

We value the trust you place in us. 

We have implemented appropriate technical and organisational measures to protect Personal Information collected by us against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access and against all other unlawful forms of processing.

When collecting or transferring Sensitive Personal Information we use a variety of additional security technologies and procedures to help protect this information. 

The Personal Information you provide us with is stored on computer systems located in controlled facilities which can only be accessed by a limited number of persons who have a need to know in order to carry out their tasks and any services requested by you. 

When we process highly confidential information (such as credit card numbers) over the Internet, we protect it through the use of encryption.

7.Your choices regarding direct marketing

We may periodically send you free newsletters, surveys, offers, and other promotional materials related to our products and services which we believe are useful for you, if you have consented (opted-in) to receive such messages via e-mail or any other electronic channel (where such opt-in is required under your local law).

If you do not wish to receive such communications anymore, you will always have the opportunity to "opt out" by following the unsubscribe instructions provided in each of our direct marketing e-mails or by contacting us directly (please see our contact information at “how to contact us” below).

Where permitted under applicable law, we may send you service messages identifying any updates to our Privacy Notice (even where you have opted out of receiving marketing messages from us).

8.Your rights 

Depending on your location, you may have rights in relation to the Personal Information you share. In particular, you have the right to:

• request a copy of Personal Information we hold about you;
• ask that we restrict the way in which we use your Personal Information;
• ask that we update the Personal Information we hold about you, or correct any Personal Information that you think is incorrect or incomplete;
• ask that we delete personal data that we hold about you (the “right to be forgotten”);
• withdraw consent at any time for the future, to our processing of your Personal Information (to the extent such processing is based on consent);
• object to our processing of your Personal Information (including for direct marketing purposes); or
• request your Personal Information be transferred to you or another data controller (the “data portability” right).

If you share any Personal Information about a third party with us and the third party requests any of the following from you:

• a copy of Personal Information held about them by us;
• ask that we restrict the way in which we use their Personal Information;
• ask that we update the Personal Information we hold about them, or correct any Personal Information they believe is incorrect or incomplete;
• ask that we delete personal data that we hold about them (the “right to be forgotten”);
• withdraw consent at any time for the future, to our processing of their Personal Information (to the extent such processing is based on consent);
• object to our processing of their Personal Information (including for direct marketing purposes); or
• request their Personal Information be transferred to you or another data controller (the “data portability” right).

you are required to immediately notify us so that we may fulfil the third party’s request as soon as possible.

In addition, in certain circumstances we may process shared Personal Information through automated decision-making, including profiling. This may include segmenting and tailoring the data to enable us to match our communication and products to your perceived needs. For example, to automatically send you tailored communications based on the relevant stage of pregnancy or a specific condition of the patient. In the case we process Personal Information through automated decision-making we will inform you about the logic involved, as well as the significance and the envisaged consequences of such processing for you. Depending on your location, you may be able to request not to be subject to automated decision-making, including profiling.

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights pursuant to the General Data Protection Regulation and the Data Protection Act 2018. 

If you would like to exercise these rights or understand if they apply to you, please click here to complete and submit an online request form. Alternatively, you can get in touch using the details set out at “how to contact us” below.

9.Complaints

If you are unhappy with the way we have handled your or any shared Personal Information or any privacy query or request that you have raised with us, you have a right to complain to your local data protection regulator.

In the UK you may submit a complaint to the Information Commissioner’s Office using the details below. 

Information Commissioner’s OfficeWycliffe houseWater LaneWilmslowCheshireSK9 5AFTel: 0303 123 1113

ico.org.uk

10.How long we retain Personal Information for

We will only retain Personal Information as long as reasonably required for the purposes as set out in this Privacy Notice or otherwise to comply with legal or regulatory requirements applicable to us. 

When Personal Information is processed:

• for the performance of your contract with us, we retain Personal Information for a period of 7 years following completion of a contractual order;
• for meeting, legal and regulatory requirements, we retain Personal Information as it is set out by the applicable law; and
• In all other cases, we process Personal Information for 2 years from the date we captured it.

11.Children

Most of our Sites are not directed towards children and we request that children below the age of 16 do not provide Personal Information through our Sites. 

If you are the healthcare professional, parent or legal guardian of a child under 16 who has registered on one of our Sites, or who you believe has otherwise provided Personal Information to us, please contact us using the details set out at “how to contact us” below to have the information deleted. Information voluntarily provided by children via e-mails, message boards, chat sessions etc. may be used by other parties to generate unsolicited e-mails. We encourage parents and legal guardians to inform children about how to use the Internet in a safe and responsible manner.

Depending on your location and where permitted by local law we may will collect information on your children (such as their date of birth) in order to provide you with relevant information about our products and services. 

12.Transfers to other countries

Your Personal Information may be transferred to and processed in other countries where laws governing the processing of Personal Information may be less stringent than the laws in your country (including jurisdictions outside the European Economic Area). 

In such cases, where required by local law we will ensure that there are adequate safeguards in place to protect your Personal Information. Depending on the location of the RB entity exporting the relevant Personal Information, this adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission. Where we are legally required to do so, further details of these transfers and copies of these agreements are available from us on request. 

To the extent required and valid under your local law, you consent to your Personal Information being transferred and processed this way.

13.How to contact us

We welcome your feedback. If you have any comments, questions or complaints regarding this Privacy Notice or our processing of your Personal Information, or would like to exercise any of the rights set out at “your rights” above that are applicable in your location, you can contact us by sending an email to PrivacyOffice@rb.com or write to us at:

RB Global Privacy OfficeTurner House103-105 Bath Road Slough,United KingdomSL1 3UH

14.Changes to this Privacy Notice

This Privacy Notice was last modified on 1 April 2020. This document is a notice to you and not a contract between us. We may occasionally modify or amend it from time to time. When we make changes to this Privacy Notice, we will update the revision date at the top of this Privacy Notice. Where those changes are material, we will take steps to let you know. The new modified or amended Privacy Notice will apply from that revision date. Please always verify whether you have consulted the latest version of the Privacy Notice.

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