1. SCOPE OF THE PRIVACY POLICY
We are committed to protecting your privacy. It is important that you understand how we look after your personal data and how we make sure that we meet our legal obligations to you under the applicable data protection legislation (the "Data Protection Laws"), including, but not limited to, the General Data Protection Regulation 2016/679 (“GDPR”). This privacy policy outlines how Accord Healthcare Limited ("Accord") will use, store and share your personal data, and supplements any other fair processing or privacy notices provided to you.
If you have any questions in relation to this policy or generally how your personal data is processed by us please contact our Data Protection Responsible Person by email at EMENA_compliance@accord-healthcare.com; or by letter addressed to: The Data Protection Responsible Person, Accord Healthcare Limited, Sage House, 319 Pinner Road, North Harrow, Middlesex, HA1 4HF, United Kingdom.
This policy applies to any personal data that we collect about you when:
you visit our websites or apps, including: www.accord-animalhealth.com;
you voluntarily provide such personal data when registering with us;
you voluntarily submit personal data to us using the forms on our websites or apps;
you submit personal data to us when you otherwise make contact with us, including in person, by email, by phone or through social media.
2. WHO ARE WE?
In this privacy policy, the terms "we", "our", and "us" are used to refer to Accord Healthcare Limited, company number: 04596349, whose registered office is Sage House, 319 Pinner Road, North Harrow, Middlesex, HA1 4HF, United Kingdom (“UK”).
We are a controller of your information which means that we are responsible for looking after it. We will use your personal data fairly, lawfully and in a transparent manner, and in accordance with the applicable Data Protection Laws.
3. HOW WILL WE USE YOUR PERSONAL DATA?
We only process your personal data as described in this Privacy Policy or in other fair processing or privacy notices provided to you. We reserve the right to conduct additional processing to the extent permitted or required by law and inform you accordingly.
4. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
The types of personal data we collect depends on the interactions you have with us, but mainly these may include:
name and contact data (including your name, country of practice, postal address, telephone number, e-mail address, area of expertise and other similar contact data);
data in order to satisfy identification requirements when exercising any of your rights under Data Protection Laws (including your passport, photo driving licence or national identity card);
automatically collected and stored data (even without registration or other data entry) and information on the calling and device such as IP address, user agent (browser and operating system), referrer, response data volume, URL, date/time, protocol version, HTTP-Verb, query strings, status code.
5. WHERE DO WE GET THIS INFORMATION FROM?
We collect some of your information directly from you, either through information that you give to us or information that we collect during your visits to our websites or apps or through your communications with us.
Please note that we may combine personal data we receive from other sources with personal data you give to us and personal data we collect about you.
A. When do you give us information about you?
You may share personal data about yourself and your circumstances by:
filling in forms on our websites, registering to use our websites, and continuing to use our websites;
exercising one of your rights under Data Protection Laws;
giving us information about yourself in any communications with us either by telephone, e-mail, post, through our websites/apps or otherwise.
B. When do we collect information about you?
We may collect personal data about you:
when you visit our websites or apps, including details of your visits, such as Internet Protocol (IP) address used to connect your computer to the internet, MAC addresses, traffic data, location data, your login information, time-zone setting browser type and version, browser plug-in types and versions, operating system and platform, weblogs, cookies and other communication data, and the resources that you access. For more information please see our Cookies Policy:
when calling our customer service team, including a recording of such calls;
C. From which third parties do we receive information about you?
We generally do not receive personal data about you from other third parties.
6. WHY DO WE NEED YOUR PERSONAL DATA?
We may use the personal data we collect for the following purposes:
to communicate with you regarding any requests or queries you may submit;
to meet contractual, legal, regulatory and compliance requirements;
to inform you or your organisation of any news on our products and/or business that we reasonably believe could be of interest to you (as appropriate in accordance with the Data Protection Laws). If you would like to stop receiving such information from us at any time, please unsubscribe by following the instructions provided in any such emails that we send to you, or use the contact details at the beginning of this policy. You may also wish to sign up to one or more of the preference services (also known as “Robinson Lists”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving;
to ensure that you, your organisation, our employees or us comply with applicable laws, our code of conduct and our related internal policies;
to administer our websites;
to handle complaints, train our employees and to improve our quality and service standards;
to establish, exercise or defend legal claims;
to analyse the use of our websites or apps;
to ensure a smooth connection establishment as well as a comfortable use;
to ensure the security and stability of the website, i.e. the detection and prevention of attacks on the website (= our legitimate interests in the processing). The data will be stored separately from your (possibly provided) other personal data and will be deleted as soon as they are no longer necessary to achieve the purpose of their collection. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. In the case of storage of data in log files, this is the case after 7 days at the latest. Storage beyond this period is possible. In this case, however, the IP addresses are deleted or alienated beforehand, so that an assignment of the calling client is no longer possible.
other purposes that we have communicated to you.
7. WHICH IS THE LEGAL BASIS FOR USING YOUR DATA?
A. Necessary for the entry into or performance of a contract (Article 6.1.b of GDPR)
When you enter into a transaction with us, a contract between you and us will have been formed. In order for us to negotiate, enter into and fulfil our obligations under such contract (e.g. to allow you to place an order for goods or services), we may need to collect, process and share (as further detailed below) your personal information. Please contact EMENA_Compliance@accord-healthcare.com for further information.
B. Legitimate business interests (Article 6.1.f of GDPR)
We may use your personal data (excluding special categories of personal data) as set out in this privacy policy where necessary for the legitimate interests of our business to enable us to:
provide your organisation with products and services as requested by your organisation;
respond to your claims or queries;
carry out research to understand our customers and how they use our products and services;
develop and improve our products and services provided to you or your organisation and to our other customers;
ensure high standards of quality and safety of our products;
support processes and procedures to assist with the prevention and detection of crime or other unlawful activity;
establish, exercise or defend legal claims;
As indicated below, we may also pass your personal data to members of our company group (to see a full list of such group companies, please click here) and other third parties where necessary for our legitimate business interests.
We are required to carry out a balancing test of our legitimate business interests in using your personal data outlined above against your interests and rights under the Data Protection Laws. As a result of our balancing test, which is detailed below, we have determined, acting reasonably and considering the circumstances, that we are able to process your personal data in accordance with the Data Protection Laws on the basis that this is necessary for our legitimate business interests.
Necessity: We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests as we process your personal data only so far as is necessary to achieve the purposes outlined in this privacy policy.
Impact of processing: We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests as such processing of your personal data does not unreasonably intrude on your privacy.
C. Consent (Article 6.1.a of GDPR)
We may use your personal data as set out in this privacy policy where you have given your consent to us.
Notwithstanding the foregoing, please note that in accordance with Data Protection Laws and other applicable laws we may, on occasion, send you marketing messages by email and post about us, our products and services and our events and offers without your consent where you or your organisation have purchased similar goods or services from us and you have not unsubscribed.
You have the right to withdraw your consent to processing of this nature at any time using the details at the beginning of this privacy policy.
D. Compliance with a legal obligation (Article 6.1.c of GDPR)
We may also use your personal data as set out in this privacy policy when such processing is necessary for complying with a legal obligation to which we are subject, such as responding to subject access requests or notifying personal data breaches to the supervisory authorities. Please contact EMENA_Compliance@accord-healthcare.com for further information on which law imposes us a legal obligation to use your personal data.
8. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
A. Group Companies
We may share your information with our parent company Intas Pharmaceuticals Ltd (Corporate House, Nr. Sola Bridge, S. G. Highway, Thaltej, Ahmedabad – 380 054, India) and other members of our group of companies (located in India or elsewhere around the world and listed in the link below) but only for the purposes specified in this privacy policy, to comply with a legal obligation or it is necessary in our legitimate interests. To see a full list of such companies, please click here. In particular:
for internal reporting purposes;
compliance purposes;
for the provision of intra-group quality assurance services;
for the provision of intra-group legal services;
for the provision of intra-group IT services.
B. Third-party services providers
We (and the members of our group of companies) may also disclose your personal data to carefully selected third-party service providers who provide services such as:
data security, website hosting, cloud hosting, storage solutions, software as a service (SaaS) and other IT services;
legal, regulatory services;
customer relationship management (CRM) services;
external salesforce services; and
access control and security services.
We will only share your information with these suppliers where this is necessary for them to provide us with the services we need. We do not share your information with third parties for marketing purposes.
Please contact EMENA_compliance@accord-healthcare.com for further information.
C. Legal and regulatory requirements
We may also disclose your personal data as required by law, including laws outside your country of residence, to comply with a court order or to comply with other legal or regulatory requirements, for example, to the relevant agencies responsible for the supervision and safety monitoring of medicines, data protection supervisory authorities.
D. Transfers outside of the European Economic Area
The information which we collect about you may be transferred outside the European Economic Area as detailed in sections A, B and C above.
While some members of our group and third-party services providers are located in countries whose laws (according to the European Commission) do not offer the same level of protection to personal data as that granted by countries within the EEA, such as Intas Pharmaceuticals Ltd (Corporate House, Nr. Sola Bridge, S. G. Highway, Thaltej, Ahmedabad, 380 054, Gujarat, India) and Lambda Therapeutic Research, Ltd (Lambda House, Plot No. 38, Survey no. 388, Near Silver Oak Club, S. G. Highway, Gota, Ahmedabad, 382481, Gujarat, India), we and the members of our group of companies adopt appropriate security measures to prevent unauthorised and unlawful use of personal data. Furthermore, such transfers are usually supported by contractual commitments between such group entities and/or third parties to ensure that the relevant technical and organisational and other safeguards required by the Data Protection Laws have been put in place.
For further information on transfers outside of the European Economic Area and/or specific safeguard methods adopted, please contact EMENA_compliance@accord-healthcare.com.
9. HOW LONG DO WE KEEP IT FOR?
We will keep your personal data for as long as required:
to prove compliance with applicable laws or as required by applicable laws, regulations, government agencies and other public authorities;
to maintain your account;
for the provision of services by us;
to answer your queries;
to allow us to bring or defend legal proceedings;
or as otherwise set forth below or notified by us to you.
10. SECURITY OF YOUR PERSONAL DATA
When handling your personal data, we take appropriate measures reasonably designed to protect your information from unauthorised access, loss, misuse, disclosure, alteration or destruction. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our websites or apps; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
11. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, which are set out below. You may contact us using the details at the beginning of this privacy policy to exercise any of these rights.
In some instances, we may be unable to carry out your request, in which case we will write to you to explain why.
A. You have the right to request access to your personal data
You have the right to request confirmation that your personal data is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal data.
B. You have the right to ask us to rectify your personal data
You have the right to request that we rectify your personal data if it is not accurate or not complete.
C. You have the right to ask us to erase your personal data
You have the right to ask us to erase or delete your personal data where there is no reason for us to continue to process your personal data. This right would apply if we no longer need to use your personal data to provide services to you, where you withdraw your consent for us to process special categories of your personal data, or where you object to the way we process your personal data (see sub-section F below).
D. You have the right to ask us to restrict or block the processing of your personal data
You have the right to ask us to restrict or block the processing of your personal data that we hold about you. This right applies where you believe the personal data is not accurate, you would rather we block the processing of your personal data rather than erase your personal data, where we do not need to use your personal data for the purpose we collected it but you may require it to establish, exercise or defend legal claims.
E. You have the right to port your personal data
You have the right to obtain and reuse your personal data from us to reuse for your own purposes across different services. This allows you to move personal data easily to another organisation, or to request us to do this for you.
F. You have the right to object to our processing of your personal data
You have the right to object to our processing of your personal data on the basis of our legitimate business interests, unless we are able to demonstrate that, on balance, our legitimate interests override your rights or we need to continue processing your personal data for the establishment, exercise or defence of legal claims.
G. You have the right not to be subject to automated decisions
You have the right to object to any automated decision making, including profiling, where the decision has a legal or significan impact on you.
H. You have the right to withdraw your consent
You have the right to withdraw your consent, at any time, where we are relying on it to process your personal data.
12. CHILDREN'S POLICY
We do not knowingly collect, retain or use personal data received from children under 18 years of age, and no part of our websites or apps is directed to children under the age of 18. If your child has provided us with personal information without your consent, you may inform us at EMENA_compliance@accord-healthcare.com, or write us a letter to the address given at the beginning of this policy. If we discover that we have received or collected any personal information from children under 18 years old, we will take steps to delete such information promptly.
13. WHAT IF YOU HAVE A COMPLAINT?
If you have any concerns regarding our processing of your personal data, or are not satisfied with our handling of any request made by you, or would otherwise like to make a complaint, please contact our Data Protection Responsible Person in the first instance using the details at the start of this privacy policy, so that we can do our very best to sort out the problem.
You also always have the right to lodge a complaint with the competent data protection authority of your country of residence (in the United Kingdom, the Information Commissioner's Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom, www.ico.org.uk; for the EU countries, please refer to the relevant authority’s details here: https://edpb.europa.eu/about-edpb/about-edpb/members_en).
15. THIRD PARTY AND SOCIAL MEDIA WEBSITES AND APPS
Our websites and apps may, from time to time, contain links to and from the websites and/or apps of third parties. If you follow a link to any of these websites or apps, please note that these websites and apps have their own privacy policies and that we do not accept any responsibility or liability for these policies or your use of those websites and apps.
16. MERGER, SALE, OR OTHER ASSET TRANSFERS
If we are involved in a reorganisation, acquisition, asset sale, merger, financing, transition of services to another provider, due diligence, bankruptcy or receivership, your information may be disclosed and transferred in connection with and as part of such a transaction as permitted by law and/or contract.
17. CHANGES TO THIS PRIVACY POLICY
We will take reasonable measures to communicate any changes to this privacy policy to you, and will post any updated privacy policies on this page.
18. REFERENCES TO THE EU/MEMBER STATES
For the purposes of this policy, references to the EU or its Members States shall include the United Kingdom.
This policy was last reviewed and updated in July 2023.
For further details please feel free to refer to our Corporate Privacy Notice.