Privacy and Cookie Policy

PRIVACY AND COOKIE NOTICE

This privacy and cookie notice (“Notice”) is provided by Teva Pharmaceutical Industries Ltd. (“Teva“) and its affiliates. You can view a list of all the Teva affiliates at the following website: http://www.tevapharm.com. Teva is referred to in this Notice as “we”, “us” and “our.”

1.Scope of this Notice

This Notice describes how we use your personal data and your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “How we store your information and your rights” section. This Notice applies to personal data we collect through:

a. Sites

We process your personal data when you visit or use our websites (each, a “Site”). Our Sites may include links to other websites over which we have no control. Teva is not responsible for the privacy policies or practices of other websites. We may also link to other websites operated by Teva or Teva’s affiliated companies which operate under separate privacy policies. If you access these websites via our Sites, you should review the privacy policies of those sites so you can understand how they collect, use and share your information.

Teva’s website uses YouTube API Services to display videos, which are bound by the YouTube Terms of Service: https://www.youtube.com/t/terms. The Google Privacy Policy may also be viewed at http://www.google.com/policies/privacy.

b. Conflict of Interest Checks

We will process your personal data if one of our employees has declared a potential conflict of interest (i.e. any situation in which personal, social, financial, political or other interests are placed before those of Teva) that concerns you.

c. Your Role as a Healthcare Professional

Teva collects information about healthcare professionals when you interact with us or our representatives.

Teva also collects personal data from a number of third party data sources, in particular from publicly available sources such as public registers of healthcare professionals, published journals and event materials and from websites of healthcare professionals or their employers. Teva collects and process such publicly available data only to the extent where the purposes for such collection and processing are compatible with and correspond to the initial purposes for which the respective data are made publicly available. Teva also specially makes use of third party data providers to enhance its own knowledge of the healthcare sector. This data will include information about your role(s), your qualifications, your speciality, your employer, your experience, your publications and other information related to your profession.

d. Supplier Checks

When you engage with Teva as a supplier or you are a Teva supplier’s personnel, we will process your personal data, including your name, personal identification number, professional contacts, bank account details and other related information and financial information.

2. How We Use Your Information

We process the personal data we collect in relation to our Sites for the following purposes:

with your consent:
- provide you with information on Teva’s business activities, products or services in direct marketing communications by email or other agreed avenues; and
- to place cookies and similar technologies, as described in the ‘Cookies and related tracking technologies’ section below.

to allow us to pursue our legitimate business interests, in particular:
- to respond to your queries or other correspondence you have submitted through Sites;
- to analyse the use of our Sites in order to continuously improve content and measure performance;
- to optimize and tailor the use of our Sites and our communication to you.

If you are relevant for conflicts of interests checks, we will process your personal data:

to allow us to pursue our legitimate business interests, in particular:
- to carry out conflict of interest checks and assessments where you have been identified by a Teva employee for a potential conflict of interest with Teva and keep records of the same; and
- to take appropriate action to remediate conflicts of interest.

If you are a healthcare professional, we will also process your personal data:

with your consent where required under law, to contact you or otherwise providing you with information regarding Teva products or events.

to allow us to pursue our legitimate business interests, in particular:
- to develop and maintain our relationship with you and to better understand the healthcare sector;
- except where consent is required under law, to contact you or otherwise providing you with information regarding Teva products or events;
- to tailor our communications to you based on your expertise and professional interests;
- to analyse your use of our sites, your interests and experience, collecting information in relation to any calls or visits from our representatives;
- to carry out and follow-up training, information and communication actions for example to invite you to a symposia, congresses, seminars, debates and carry out market research, scientific cooperation or research;
- prior to entering into any personal services contract with you, checking that your professional expertise and experience match our identified need for that service (this is a legal obligation in some cases); and
- to assess the purchases you have made and other information collected from you included your marketing preferences and how you browse our relevant Sites (only where applicable).

to comply with our legal obligations:
- prior to entering into any personal services contract with you, checking that your professional expertise and experience match our identified need for that service.

if we enter into a contract with you, to fulfil the contract, in particular:
- to fulfil any of our obligations owed to you under such contract such as to manage your orders and to make payments to you; and
- managing orders, questions and complaints regarding products where you have placed orders, posed questions or submitted complaints.

If you are a supplier or supplier personnel, we will process your personal data:

To fulfil our contract with you, including arranging payment for the provision of your services.

to allow us to pursue our legitimate business interests, in particular:
- to manage our business relationship with you / your employer;
- to plan for, conduct and monitor the business and our supplier contracts;
- for market research;
- for investigating allegations of misconduct; and
- for due diligence of Teva’s operations in cases of mergers and acquisitions.

We also generally process personal data:

with your consent as described in any consent sought from you;
to handle any questions or complaints you may have about Teva or Teva staff (this is in our legitimate interests);
to meet legal (incl. out tax and accounting obligations), regulatory, pharmacovigilance and compliance requirements, in particular to respond to requests for information from government authorities;
to comply with all legal and self-regulatory obligations including transparency and disclosure obligations or anti-gift obligations (this may either be in our legitimate interests or a legal obligation);
to manage and respond to requests concerning medical information (this may either be in our legitimate interests or a legal obligation); and
for using data in connection with dispute resolution, legal claims, compliance, regulatory and investigative purposes as deemed necessary by Teva (including disclosure of such information in connection with legal process or litigation) (this may either be in our legitimate interests or a legal obligation).

Where we collect personal data to perform our contract with you or to comply with our legal obligations, this is mandatory and we will not be able to perform the contract or we may be prevented from complying with our legal obligations to you or third parties (such as mandatory reporting, tax and accounting) without this information. In all other cases, provision of the requested personal data is optional, but this may affect your ability to receive certain services or take part in certain activities where the information is needed for those purposes.

Legitimate Interests
You can find more information regarding Teva’s legitimate interest balancing test by contacting us at the addresses specified in “Your Rights” section below.

Sharing Your Personal Data
Teva discloses your personal data to the following categories of recipients (in all cases, only when necessary to fulfil their functions):

our staff (including employees and external consultants), professional advisors and agents;
other functions and companies in the Teva group of companies worldwide such as Teva Pharmaceuticals Industries Ltd. in Israel, Teva Pharmaceuticals Europe B.V., Teva Croatia (PLIVA HRVATSKA), Teva Romania and Teva Pharmaceuticals USA Ltd, who provide IT support, IT hosting and other group services such as HR, Finance and other support;
third party service providers which process your personal data on behalf of Teva and who are bound by contractual obligations to keep your personal data confidential and appropriately secure, such as:
- IT support, website hosting, CRM hosting, event management and analytics providers;
- in the case of supplier and supplier personnel personal data, administrative, consultancy and logistical support service providers, investment houses for the purposes of benefits management, and training providers;
- Inquiry and other database hosting and support
- various HR, travel and administration services.
- government authorities (including tax authorities), regulatory agencies and law enforcement officials, if required for the purposes specified above, if mandated by law, or if required for the legal protection of our legitimate interests in compliance with applicable laws.
- if you are a healthcare professional, relevant regulators as required, such as EMA and pharmaceutical self-regulatory bodies such as EFPIA in Europe;
- our third party sources of personal data where we need to confirm and have agreed to assist them with the accuracy of information (for example, if you are a healthcare professional, we may share personal data with our third party sources where we become aware that you have moved to a new role);
- in relation to the performance of our relations, the protection of our legitimate interests or the compliance with our legal obligations, we may disclose your personal data to service providers such as banks, postal service providers, lawyers, auditors, etc. When dealing with such providers, we require them to strictly comply with all applicable data protection rules and laws, as well as the specific rules applicable to their activities and the protection of the information they process in the course of such activity;
- in the event that the business is sold or integrated with another business, potentially our advisers, any prospective purchaser’s advisers and any new owners of the business and third parties (and their advisors) with whom we merge with or acquire in future.

Cookies and Related Tracking Technologies

Use of Cookies on the Site

Teva uses cookies to collect information about you and store your online preferences. Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the website when you return to it: this is useful because it allows the website to recognise your device. To find out more about cookies please visit www.allaboutcookies.org

If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.

Information on deleting or controlling cookies is also available at www.allaboutcookies.org. Please note that by deleting our cookies (or disabling future cookies) you may not be able to access certain areas or features of the Site.

Please note that by deleting our cookies (or disabling future cookies) you may not be able to access certain areas or features of the Site.

Teva uses the following categories of cookies on the Site:

Category 1: Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for (such as remembering your login details) cannot be provided.

Category 2: Performance Cookies
These cookies collect information on how people use the Site. For example, we use these cookies to help us understand how customers arrive at the Site, browse or use the Site and highlight areas where we can improve such as navigation, user experience and marketing campaigns. The data collected is only used to improve how the Site works. For example we use Google Analytics to better understand how customers use the Site. If you don’t want Google Analytics to be used in your browser, you can install this Google add-on: https://tools.google.com/dlpage/gaoptout?hl=en_GB.

Category 3: Functionality Cookies
These cookies remember choices you make (such as language choices). These can then be used to provide you with an experience more appropriate to your selections and to make your visits to the Site more tailored. The information these cookies collect may be non-directly identifiable and they cannot track your browsing activity on other websites.

Category 4: Social Media Cookies
Our Site includes buttons that allow you to connect with the following third party social media networks Facebook and Linkedin. When you consent to us sending your personal data to these entities or when you click on these connect buttons, you agree that your device will access the respective webpages and device data and other information about your visit will be sent to the relevant social network to provide measurement services, target ads and as otherwise set out in their privacy policy (together with information about the rights and options to protect your privacy). These are available at the following addresses:
http://www.facebook.com/policy.php;
https://www.linkedin.com/legal/privacy-policy.

We are not responsible for their subsequent use of your personal data or any personal data you provide them once you leave our website. If you would like to exercise your data subject rights over the personal data shared with a third party social media site, you can either contact us at EUprivacy@tevaeu.com, Linkedin or Facebook as set out in their privacy policy. To withdraw your consent, please follow the link to manage your cookie preferences.

Category 5: Advertising cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. They are usually placed by advertising networks with our permission. They remember that you have visited the Site and this information is shared with other organizations such as advertisers.

Customize and include if necessary depending on whether social media plug-ins are used, and if so, which ones.

Use of Web Beacons

Some pages of our Site and e-mails we may send may contain electronic images known as web beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages or read our e-mails. Web beacons collect only limited information which include a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. These beacons do not carry any personal data and are only used to track the effectiveness of a particular campaign.

How We Store Your Information

If we have a contract with you, your personal data will be retained for the duration of your contract and for an appropriate duration after its termination in your country to protect us from any legal claim.

Otherwise, your information will be retained for two years, or as reasonably necessary for the purposes set out above, in accordance with applicable laws. For more information on your particular circumstance, please contact us using the contact information listed below.

Your Rights – for Europe

You may be entitled under applicable law to ask Teva for a copy of your information, to correct it, erase or restrict its processing, or to ask us to transfer some of this information to other organisations. You may also have rights to object to some processing. These rights may be limited in some situations – for example, where we can demonstrate we have a legal requirement to process your personal data.

Where you have consented to the processing of your data, you may withdraw such consent at any time.

You have an absolute right to opt-out of processing for direct marketing purposes at any time. You can do this by following the instructions in the communication where this is an electronic message or by contacting us using the details set out below. For certain Sites, you may also have an ability to change some marketing preferences online.

If you have any concerns about how we process your personal data or wish to exercise any of your rights or wish to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with Teva’s Data Protection Office by contacting us. We hope that we can satisfy any queries you may have about the way in which we process your personal data. However, if you have unresolved concerns you also have the right to complain to the data protection authority in the location in which you live, work or believe a data protection breach has occurred.

International Transfers

Teva operates internationally and will transfer your information to the recipients set out in the ‘Sharing Your Personal Data’ section in countries outside your own country and outside the European Economic Area, including to Israel and the United States. When transferring your information to Israel, Teva relies on the European Commission’s adequacy decision with respect to the transfer of data from the European Union to Israel; when transferring to the US, Teva uses Teva Pharmaceutical USA Ltd.’s Privacy Shield certification; when transferring to other countries outside the EEA which do not benefit from an adequacy decision from the European Commission, Teva generally relies on EU Commission approved standard contractual clauses. Information on the relevant mechanism can be provided upon request.

Contact Information

If you live in Europe, you can contact us at EUPrivacy@tevaeu.com.
If you live in the United States, you can contact us at USPrivacy@tevapharm.com.
For other regions, please contact us at IL_Privacy.Tevail@teva.co.il.

Changes to this Notice

This Notice may change from time to time. Teva will place an updated version of the Notice on this page and may otherwise communicate changes as appropriate.

Last modified: 24th July 2020