This privacy and cookies policy (the "Privacy Policy") sets out how your personal data is collected and processed in connection with your use of the Oncodemia platform available at www.oncodemia.com (the "Platform") and the separate pharmacist registration site available at https://inscription.unifyhealth.app (the "Registration Site") by Accord Healthcare France, 635 Rue de la Chaude Rivière, 59000 Lille, France as data controller ("we", "us" or "our").

This Privacy policy covers:

1. The information we collect about you and how we use it
2. Cookies and other technologies
3. Who we give your information to
4. Where we store and transfer your information
5. Child safety
6. How we protect your information
7. How long we keep your information
8. Your data protection rights
9. Changes to this policy
10. Contact us

 

We are committed to protecting and respecting your privacy. Therefore, it is important that you understand how we process your personal data and how we ensure that we comply with our legal and regulatory obligations to you in accordance with current data protection legislation (the "Data Protection Legislation"), including but not limited to the EU General Data Protection Regulation 2016/679 (the "GDPR").

By using the Platform and the Registration Site and by accessing our services, you acknowledge that you have read this Privacy Policy.

1.      The information we collect about you and how we use it

We collect and process the following personal data about you at:

1.1 Information that you communicate directly to us

This is information about you that you communicate directly to us when you interact with us by filling in forms on the Platform or Registration Site or by corresponding with us by telephone, e-mail or otherwise. This includes information for the purposes of:

• Create your account on the Platform and identify yourself when you log on to the Platform Register to use the Platform.
• Complete the registration form of the Registration Site to be displayed with a yellow pin in the pharmacy locator in the separate Unify Health app.
• Participate in a survey via the Platform.
• Submit a query to us or report a problem with the Platform or the Registration Site.
• To send you commercial communications about our products and services.

You can consult the full list of processing purposes and, for each of these purposes, the applicable legal basis for processing and the data collected, in the table at the end of this Privacy Policy.

To find out more

The data you provide directly to us may include:

• Information relating to your identity: your first and last name, your username and your chosen password (hereinafter collectively referred to as "Identity" in the table at the end of the Privacy Policy);
• Your coordinates: e-mail address, city and country of residence ("Contact");
• The content of your request for contact and subsequent communication ("Content of communications");
• Information relating to your professional profile, including: the country in which you work, your position, your pharmacy's registration number (RPPS), the country/professional association of registration, your pharmacy's name, address and website, your profile photo (if you wish to share one), and a brief description of your or your pharmacy's specialty to help cancer patients find pharmacists in the separate Unify Health app ("Professional Profile").

1.2 Information we collect about you when you use the Platform and the Registration Site

We collect information about you when you visit the Platform or the Registration Site. This information includes:

• Technical information relating to your device and browser ("Technical");
• Information relating to your interaction with the Platform or the Registration Site ("Usage");
• Information relating to your use of course content on the Platform and the status of your certification on the Registration Site ("Certification").

To find out more

The data we collect when you use the Platform and the Registration Site may include:

• Technical information includes the IP address used to connect your computer or mobile device to the Internet, your connection details, browser type and version, time zone setting, browser plug-in types and versions, operating system and Platform and the Registration Site;
• Session information about your visit, including the full URL, the navigation path to, via and from the Platform and the Registration Site (including date and time); items viewed or searched for, page response times, download errors, duration of visits to particular pages, page interaction information (such as scrolling, clicks and mouse pointer), methods used to leave the page and telephone numbers or social media handles used to contact our customer service.
• Training information, including modules taken and completed, answers you provide to case studies and/or "knowledge check" exams on the Platform, learning resources consulted on the Platform, comments you make on course content and professional development information you may have.
• Location data strictly necessary to identify the location from which you access the Platform or the Registration Site, to enable us to make the content of the Platform or the Registration Site compliant with applicable local legal requirements and to determine the locations of users accessing our services.

 

1.3 Information we receive from other sources

This is information we receive about you or the pharmacy in which you work, in particular:

• Information about your pharmacy to supplement your profile submitted through the Registration Site, including the information we collect via Google Business.
• If you or your pharmacy use any of the other websites or applications we operate or other services we provide.

 

2.      Cookies and other technologies

The Platform and the Registration Site use cookies and/or other similar technologies to collect and store certain information. These are generally pieces of information or code that a website transfers or accesses from the hard drive of your computer or mobile device to store and read information about you. Cookies and other similar technologies are used to remember you when you use a computer or a mobile device to interact with the Platform or the Registration Site.

The Platform and the Registration Site use cookies and similar technologies to distinguish you from other users of the Platform and the Registration Site. This helps us to provide you with an optimised experience when you browse the Platform or the Registration Site and also enables us to improve the services we offer you.

A number of cookies and other similar technologies that we use only last for the duration of your web session and expire when you close your browser. Others are used to remember you when you return to the Platform or the Registration Site.

Where personal data is collected via these cookies by us as data controller, it will be processed in accordance with the provisions of this Privacy Policy.

Where third-party cookies enable our partners to collect and process your personal data, we invite you to consult their privacy policy in order to find out the conditions under which your personal data is processed. The full list of partners authorised to place cookies on the Platform and the Registration Site and the link to their privacy policy is available in the table at the end of this section.

To find out more

We and our partners use the following categories of cookies:

• Strictly necessary technical cookies: these are cookies that are necessary for the operation of the Platform and the Registration Site. They include, for example, cookies that enable you to visit and connect to secure areas of the Platform and the Registration Site and to remember your identifier the next time you connect.
• Audience measurement and analytical cookies: with your consent, cookies are placed on to enable us to recognise and count visitors to the Platform and the Registration Site and to see how visitors to interact with them. This helps us to improve the operation of the Platform and the Registration Site, for example by ensuring that users find what they are looking for.

Cookie settings

You can manage your cookie preferences at any time:

• On the Platform and the Registration Site via the cookies banner accessible during your browsing and/or the "Cookie settings" tab accessible from all pages of the Platform or the Registration Site

When the cookies banner is displayed on the Platform and/or the Registration Site, you can choose to configure your choices by cookie category. The "Manage my choices" button on the banner brings up a settings screen that enables you to see the categories of cookies used on the Platform and the Registration Site and to select the purposes of the cookies that you accept or refuse.

You can change these settings at any time by clicking on the "Cookie settings" tab accessible from all pages of the Platform and the Registration Site.

• From your browser

If you wish to deactivate cookies on the Platform and/or the Registration Site, with the exception of strictly necessary cookies which cannot be deactivated, you can also modify the settings of your browser. How you do this depends on the browser you are using. You will find more information on how to deactivate cookies for the main browsers below:

For Microsoft Internet Explorer :

1. Select the " Tools" menu, then "Internet Options".
2. Click on the "Confidentiality" tab
3. Choose the appropriate setting

For Google Chrome :

1. Select "Settings" then "Advanced".
2. Under "Confidentiality and security", click on "Content settings".
3. Click on "Cookies

For Safari :

1. Select "Settings" then "Confidentiality".
2. Click on Delete all website data

For Mozilla Firefox :

1. Select the Tools menu, then Options.
2. Click on the "Confidentiality" category
3. Locate the "Cookie" option and select the appropriate options
4. 
   

For Opera 6.0 and above: Select "Files" from the menu, then "Settings".

How long your choices regarding cookies are retained

Your choices concerning the acceptance or refusal of cookies on the Platform and the Registration Site are kept for six (6) months, after which you will be asked again to express your agreement, refusal or configuration of cookies.

List of cookies used on the Platform and the Registration Site

For more information on the cookies we use and the purposes for which we use them, see:

3.      Who we give your information to

The aim of the Platform is to provide training and resources related to helping cancer patients in your pharmacy. The Registration Site allows individuals who have completed the Oncodemia training on the Platform to apply, via the Registration Site, to make themselves available to cancer patients in their community by sharing professional and pharmacy details. The patients will access Google maps information for the location of the pharmacy that successful applicants work at and associated information shared through the Registration Site.

In addition, we may share your personal data with:

• Any member of our group, i.e., our ultimate parent company Intas Pharmacueticals Ltd.  and its subsidiaries, which are involved in the process of processing your personal data in accordance with this Privacy Policy. To consult the complete list of these companies, please click here. If one of these companies wishes to use your information for direct marketing purposes, we will only send them the information for this purpose with your prior consent.
• Third parties providing us with services necessary for the operation of the Platform and the Registration Site.
• Public bodies and authorities (administrative or judicial) in cases where we are required to disclose your personal data in order to comply with a legal obligation to which we are subject.

You can consult the full list of recipients for each of the purposes of processing in the table at the end of this Privacy Policy.

To find out more

Third parties with whom we may share your personal data include:

• The companies that process your personal data on our behalf and in accordance with our instructions and the applicable legislation relating to data protection. This includes the companies that provide the following services: access control and data security services, hosting and storage services, translation, legalization and notarization services and customer relationship management services. These companies (which may include third party service providers and/or other companies in our group) will only process your data to the extent strictly necessary to provide the relevant services. The processing of your data by these companies takes place within the framework of the data processing agreements entered into with us and as required by the Data Protection Legislation.
•  Analytical service providers which help us to improve and optimize the Platform and the Registration Site, as described in the "Cookies and other technologies" section of this Privacy Policy.

We may also transmit your personal data in the following cases:

• If we sell all or part of the company's assets or activities, we will share personal data with potential buyers.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property or safety of Accord Healthcare Limited, our users or others. This includes sharing information with public bodies and authorities and other companies and organizations for the purposes of fraud protection and the prevention of cybercrime.

 

4.      Where we store and transfer your information

The personal data collected via the Platform and the Registration Site are hosted on servers located in the European Union. However, as we are located in the United Kingdom, all of your personal data is processed in the United Kingdom. In addition, we may transfer your personal data to service providers or to our group companies located outside the EEA who may not be subject to a law providing equivalent data protection to the Data Protection Legislation.

We take steps to ensure that the transfer of your data is subject to appropriate safeguards and that it is processed securely and in accordance with this Privacy Policy.

To find out more

We may transfer your personal data to countries outside the EEA in the following cases:

• To ensure the operation of the services provided via the Platform and the Registration Site.
• To comply with our legal obligations.
• To facilitate the commercial activities of our group, provided that our legitimate interest in this respect does not infringe your rights and freedoms.

Pseudonymized usage data of the Platform and Registration Site (that does not directly identify users to Google) may be transmitted to Google servers in the USA. Google client processing terms include approved standard contractual clauses for protection of any personal data transfers. Google is also certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Data transfers to service providers in the USA are adequate if they are certified in accordance with the DPF. Further information on the DPF can be obtained at the following link: https://www.dataprivacyframework.gov/s/.

If we transfer your personal data to a country for which there is no adequacy decision adopted by the European Commission, the transfer of data is generally governed by the conclusion of standard contractual clauses and, if necessary, by the implementation of additional security measures.

For more information on the transfer of personal data to countries outside the EEA and/or on the specific guarantees put in place, please contact us at the following e-mail addresses EMENA_Compliance@accord-healthcare.com concerning the Platform and privacy@unifyhealth.app concerning the Registration Site.

5.      Child safety

Protecting the safety of children when they use the Internet and online services is important to us. The Platform and Registration Site are intended for use only by persons aged 18 or over. By using the Platform and/or the Registration Site, you confirm to us that you meet this condition. If we become aware that any data we have collected relates to a child under the age of 18, we will take all necessary steps to delete such data, including closing the associated user account.

6.      How we protect your information

All information you provide to us is stored on secure servers. Where you choose a password which enables you to access certain secure parts of the Platform or the Registration Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

We implement appropriate technical and organisational measures to protect your personal data, such as encryption of data in transit and encryption at rest for non-active systems (including back-ups). Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

The Platform and the Registration Site may, from time to time, contain links to external third-party sites. We are not responsible for the privacy practices or the content of these sites and accept no responsibility for the use of your personal data via these sites. We therefore recommend that you read the privacy policies on third-party sites.

The Platform and the Registration Site do not process personal data for the purposes of automated decision-making that has any legal effect or significantly affects you.

7.      How long we keep your information

We retain your personal data for as long as you use the Platform and the Registration Site, or as necessary to manage your application on the Registration Site or for the term of your valid designation as a yellow pin in the Unify Health app, for the limitation period of any related legal action.

We may also retain information beyond the set retention period for research purposes and to help us develop and improve our services, in which case your information will be anonymized.

You can consult the full list of data retention periods applicable for each of the purposes of processing in the table at the end of this Privacy Policy.

8.      Your rights with regard to personal data

You have the right to within the limits provided for by the Data Protection Legislation:

• obtain a copy of your personal data held by us;
• request the rectification or deletion of your personal data held by us;
• request that we restrict the processing of your personal data (while we verify or investigate your concerns about the information, for example);
•  to object to the further processing of your personal data, or to object to marketing and any marketing-related profiling (by clicking on the unsubscribe link at the end of all our marketing and promotional communications, or by sending us an email).
• request that the personal data you have provided be transferred in a structured, commonly used and machine-readable format to a other data controller designated by you;
• not to be the subject of a decision based solely on automated processing, including profiling, which produces legal effects concerning you (note, as indicated above, that the Platform and the Registration Site do not use personal data to make such automated decisions)
• provide us with instructions on what to do with your personal data after your death;
•  to withdraw your consent at any time where the processing of your personal data by us is based on your consent.

When we receive a request to exercise any of the above rights, we will respond within one month of receiving your request. This period may be extended by a further two months in cases where the requests are complex or numerous and where such an extension is authorized by the Data Protection Act. If this is the case, we will inform you within one month of any extension and the reason for it.

You can exercise the rights listed above at any time by contacting us at the addresses listed in the "Contact us" section below.

If we have not responded satisfactorily to your request, you have the right to lodge a complaint with the relevant local data protection authority, which is the Commission Nationale de l'Informatique et des Libertés (the "CNIL") in France. Contact details can be found by clicking on the following link: Data protection authorities - European Commission (europa.eu) 

9.      Changes to this Privacy Policy

Any changes we may make to this Privacy Policy will be published on this page. In the event of substantial changes, you will be notified by e-mail of the updated Privacy Policy.

10.   Contact us

Any questions, comments and requests concerning this Privacy Policy and requests to exercise your rights should be addressed to our Data Protection Officer, in English or French, at the following address:

• By e-mail to the following addresses

1. For the Platform: EMENA_Compliance@accord-healthcare.com
2. For the Registration Site: privacy@unifyhealth.app

• By post to Data Protection Department, Accord Healthcare France, 635 Rue de la Chaude Rivière, 59000 Lille, France.