SANOFI fully understands the importance of privacy and the protection of personal data in the digital era and is committed to ensure an adequate level of data protection for all persons with whom Sanofi has dealings. This includes, notably:
What you will find in this document
This Global Privacy & Data Protection Policy (“Policy”) describes SANOFI’s global practices to ensure an adequate protection of personal data, i.e. any information relating to an identified or identifiable natural person, for all data processing carried out in the framework of its business and activities (“Personal Data”).
The objective of this Policy is to help you understand:
What processing activities does this Policy cover?
This Policy is intended to apply to all processing activities SANOFI conducts towards the persons it deals with in its professional business activities. Specific privacy and data protection information notices (“Privacy Notice”) and/or consent forms will, if necessary, be communicated to you regarding specific situations where SANOFI may process your Personal Data. These Privacy Notices shall describe in more detail how your Personal Data will be processed in relation with the processing in question. If the legislation of your country so requires, this Policy and/or Privacy Notices may be supplemented by local mandatory provisions, as the case may be.
For the purposes of this Policy SANOFI means Sanofi and all its affiliates. Each Privacy Notice shall set out which SANOFI entity determines for what reasons (i.e. the purposes) your Personal Data is processed as well as the resources (i.e. the means) allocated to such processing.
Validity and evolution of this Policy
This Policy may be modified by SANOFI, from time to time, in particular to adapt its terms to evolutions or changes of applicable legislations and/or to SANOFI’s practices. Changes will be available on this page. We invite you to check this Policy periodically.
The purposes: SANOFI will always collect your Personal Data for explicit and legitimate purposes
SANOFI collects your Personal Data for the following purposes:
On what ground? SANOFI will always process your Personal Data lawfully
Depending on the data processing at stake, SANOFI will generally process your Personal Data on either one of the following legal basis:
SANOFI may, on a case-by-case basis, rely on other legal grounds, such as the protection of your vital interests, in accordance with applicable data protection law, as set forth in the applicable Privacy Notice.
Where does the Personal Data come from? SANOFI will always collect Personal Data from trusted sources
SANOFI may collect your Personal Data from different sources:
About children Personal Data
While in some instances we may collect Personal Data about children with the consent of his/her parent or guardian for the provision of our services such as clinical activities or for patient support programs, we do not otherwise knowingly solicit Personal Data from, or market to, children. If a parent or guardian becomes aware that his or her child has provided us with personal information, he or she should contact us as described in the “How to Contact Us” section below. We will take steps to delete such information from our database in accordance with applicable legal requirements.
Who has access to Personal Data: SANOFI will share your Personal Data only with authorized parties
For the purposes described above, SANOFI may need to share your Personal Data with the following authorized third-parties:
SANOFI may need to share your Personal Data with other third-parties, in which case you will be duly informed through the applicable Privacy Notice.
In any case, SANOFI will require that such third-parties:
Where Personal Data may be transferred: SANOFI will ensure that transfers of your Personal Data outside EU are safeguarded
SANOFI is a multinational organization with affiliates, partners and subcontractors located in many countries around the world. For that reason, SANOFI may need to transfer (via access, visualization, storage..) your Personal Data in other jurisdictions, including from the European Economic Area to outside the European Economic Area, in countries which may not be regarded as providing the same level of protection as the jurisdiction you are based in.
Safeguards for international transfers of Personal Data: In cases where SANOFI needs to transfer Personal Data outside the European Union, it shall ensure that adequate safeguards, as required under applicable data protection legislation, will be implemented (including, notably, the European Commission’s Standard Contractual Clauses, as applicable).
In this respect and in particular, for intra-group transfers of Personal Data implemented for clinical studies and pharmacovigilance purposes, SANOFI has implemented and shall apply its “Binding Corporate Rules” validated by the EU Data Protection Authorities.
How secure: SANOFI will implement security measures to protect your Personal Data
We have implemented a variety of technological and organizational procedures and measures to ensure the integrity and confidentiality of your Personal Data from unauthorized access, use and disclosure. These measures shall take into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.
For instance, we store your Personal Data on servers that have various types of technical and physical access controls, which may include, for instance, if appropriate, encryption. We may also aggregate, pseudonymize or anonymize Personal Data to ensure that no personally identifiable information is communicated to third parties.
How long: we will retain your Personal Data for no longer than necessary
SANOFI will retain your Personal Data only for the period necessary to fulfill the purposes outlined in this Policy.
As an exception, SANOFI may be required to retain your Personal Data for longer periods as required or permitted by law, or as necessary to protect its rights and interests. In such a case, you will be informed of the intended retention period in the applicable Privacy Notice.
Your rights: SANOFI will ensure that you can exercise your rights pertaining to your Personal Data
You can exercise your rights as provided by data protection laws.
To that end, SANOFI informs you that you are entitled:
If you would like to exercise any of these rights, please contact us as described in the “How to Contact Us” section below and we will take necessary steps to respond as soon as possible.
You may also file a complaint before a competent data protection authority regarding the processing of your Personal Data. While we suggest that you contact us beforehand, if you wish to exercise this right, you should contact directly the competent data protection authority.
How to contact us
SANOFI welcomes any questions or comments you may have regarding this Policy or its implementation. Any such questions or comments should be submitted using the contact information below:
You can send any request pertaining to SANOFI’s use of your Personal Data to our Data Protection Officer at the following email address: ZALocalPrivacyOffice@sanofi.com
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