We take privacy seriously. This notice tells you who we are, what information about you we collect, and what we do with it. We will use information about you only in accordance with applicable data protection laws. Click on “find out more” in each section for further information.
Please also read our terms of use relating to the service you are interested in. They provide more information about the way we do business, and any restrictions on eligibility that may apply.
Who are we?
This privacy notice is issued by the Vectura Fertin Pharma group of companies, which is made up of a number of companies or “affiliates” as set out at the end of this notice.
“We” (or “us” or “our”) refers to Vectura Fertin Pharma Inc. and its affiliates.
How do we collect information about you?
We may collect information about you in various ways.
- You may provide us with information directly (e.g. filling in a form or making a call to us).
- We may collect information automatically when you interact with our systems or we communicate with you (e.g. when you use a Vectura Fertin Pharma website or, where we use technologies to observe when you receive or open e-mails).
- We may also acquire information from third parties (e.g. statistical information about the population in certain geographical areas).
- For example, where permitted by law, we may infer information about you from aggregated information we acquire from third parties. This may include, for example, statistical information about people in certain geographical areas.
In this notice, we refer to all the methods by which you are in contact with us as “touchpoints”. Touchpoints include digital (for example, websites).
We may collect information about you automatically through the use of cookies and similar tracking technologies on digital touchpoints. The specific cookies and technologies used will depend on the touchpoint in question. To learn about the cookies and similar technologies used on a touchpoint, including how you can accept or refuse cookies, please see the cookie notice made available on or through that touchpoint.
We may also collect information in other contexts made apparent to you at the time.
We may collect information that you provide directly. Typically, this will happen when you:
- request information about our products;
- use a Vectura Fertin Pharma digital touchpoint (e.g. a website);
- contact us through a touchpoint, or by e-mail;
We may collect information from an electronic device, if you choose to send the information to us. This may be shared with us through a direct connection to the internet.
We may collect information about you automatically. Typically, this will happen when you:
- communicate with us (for example, through a touchpoint);
- use Vectura Fertin Pharma touchpoints (for example, through tracking mechanisms (such as cookies and web beacons/pixels), where we use them, that you receive when you use the Vectura Fertin Pharma touchpoint or get an e-mail from us);
- use third party websites (for example, using technology similar to that described in the bullet above, that you receive when you visit a Vectura Fertin Pharma touchpoint or get an e-mail from us); or
As mentioned above, we may collect information about you automatically through the use of cookies and similar tracking technologies (such as web beacons/pixels) that you receive when you visit digital Vectura Fertin Pharma touchpoints or get an electronic message from us. The specific cookies and other mechanisms used will depend on the touchpoint in question. To learn about these mechanisms used on a Vectura Fertin Pharma touchpoint, including how you can accept or refuse cookies, please see the information made available on or through that touchpoint. These mechanisms may include Google analytics cookies (see www.google.com/policies/privacy/partners/.)
Where permitted by law, we may acquire information about you from third parties. This may include information shared between Vectura Fertin Pharma affiliates.
Where permitted by law, we may infer information about you from information about you that we already have. For example, we may use aggregated information about people in certain geographical areas, that we acquire from third parties, to infer your preferences.
We may also collect information in other contexts made apparent to you at the time.
What information about you do we collect?
We may collect various types of information about you:
- information you give us in forms or surveys, and similar information that you give to third parties to be transferred to us
- information you give us in communications (e.g. e-mails) you have with contact centres
Information that we collect from you directly will be apparent from the context in which you provide it.
Information that we collect from an electronic device, if you choose to send the information to us. Information that we collect automatically will generally concern:
- your use of third-party websites, where the information collected will be similar to that described in the bullet above (we may use cookies and similar tracking technologies (such as pixels/web beacons) to do this);
- your mobile or desktop device and software (such as your IP address or unique device identifier (for example, mobile advertising identifier (MAID) or Android ID (SSAID)), location data (either your general location (derived from your IP address, in which case the information we have will be general, e.g. the town you are in), or your precise location (if you choose to share it with us for specified purposes, e.g. store locator)), the display settings of your monitor, web browser type, operating system, (some of which may be used in “digital fingerprinting” (see for what purposes we use information about you, below)) and details of any cookies (or similar technologies) that we may have stored on your device); and
Information that we collect from third parties will generally consist of publicly available information.
For what purposes do we use information about you, and on what legal basis?
In this section, we describe the purposes for which we use personal information. However, this is a global notice, and where the laws of a country restrict or prohibit certain activities described in this notice, we will not use information about you for those purposes in that country.
Subject to the above, we use information about you for the following purposes:
- To comply with regulatory obligations
- To provide product information services to you, including dealing with your inquiries and requests
- For other purposes that we notify you of, or will be clear from the context, at the point information about you is first collected
The legal basis for our use of information about you is one of the following:
- compliance with a legal obligation to which we are subject;
- a legitimate business interest that is not overridden by interests you have to protect the information;
where none of the above applies, or where law requires it, your consent (which we will ask for before we process the information).
Purpose |
Method of collection and legal basis for processing |
Comply with regulatory obligations |
This information is generally provided to us by you directly. |
Provide product information services
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This information is generally provided to us by you directly but may be combined with information that we collect automatically (for example, using technology (such as cookies and web beacons/pixels) to monitor your use of Vectura Fertin Pharma touchpoints and e-mails from us), and using similar technology to monitor your use of third party touchpoints; and (where permitted by law) information that we acquire from third parties . We use it because we have a legitimate business interest in providing product information services to our customers that is not overridden by your interests, rights and freedoms to protect information about you. |
Market our products (where permitted by law)
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This will typically be a combination of information that you provide to us (for example, your e-mail); information that we collect automatically (for example, using technology (such as cookies and web beacons/pixels) to monitor your use of Vectura Fertin Pharma touchpoints and electronic messages (e.g. e-mails from us), and using similar technology to monitor your use of third party touchpoints; and (where permitted by law) information that we acquire from third parties. We use it on the grounds that either:
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Market our products (where permitted by law)
|
This will typically be a combination of information that you provide to us (for example, your e-mail); information that we collect automatically (for example, using technology (such as cookies and web beacons/pixels) to monitor your use of Vectura Fertin Pharma touchpoints and electronic messages (e.g. e-mails from us), and using similar technology to monitor your use of third party touchpoints; and (where permitted by law) information that we acquire from third parties (e.g. statistical information). We use it on the grounds that we have a legitimate business interest to market these things that is not overridden by your interests, rights and freedoms to protect information about you. In certain countries, where required by law, we will send you these materials in electronic format, and use these technologies, only with your consent. |
Use of Vectura Fertin Pharma touchpoints To enable you to use, and improve your experience of, Vectura Fertin Pharma touchpoints |
We use it on the grounds either that (a) we have a legitimate business interest to provide you with Vectura Fertin Pharma touchpoints, and to provide you with this support, which is not overridden by your interests, rights and freedoms to protect information about you; or (b) that you have consented to these uses (these cases will be clear from the context). |
Support for all the above purposes
|
This will typically be information that we collect automatically (for example, information about your device, and cookies and similar tracking technologies, “digital fingerprinting” as described above, and (where permitted) recordings of your calls (and transcriptions of those recordings) or visits to Vectura Fertin Pharma touchpoints). We use it on the grounds that correspond to the purpose for using the information that we are supporting. |
Business analytics and improvements
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This will typically be a combination of information that you provide to us (such as information from your communications with Vectura Fertin Pharma touchpoints); information that we collect from your electronic device information that we collect automatically; and (where permitted by law) information that we acquire from third parties. Where we have more than one type of information from these categories, we will combine them to improve our analysis. We use it on the grounds that either:
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Where we do not base our use of information about you on one of the above legal bases, or where law requires it, we will ask for your consent before we process the information (these cases will be clear from the context).
In some instances, we may use information about you in ways that are not described above. Where this is the case, we will provide a supplemental privacy notice that explains such use. You should read any supplemental notice in conjunction with this notice.
Who do we share your information with, and for what purposes?
We may share information about you with:
- Vectura Fertin Pharma affiliates;
- third parties who provide Vectura Fertin Pharma affiliates or you with products or services;
- Vectura Fertin Pharma affiliates’ carefully selected business partners and advertisers (in areas connected with our products, or consistent with their style and image) so that they can contact you with offers that they think may interest you, in accordance with your preferences; and
- other third parties, where required or permitted by law.
We share information about you with others only in accordance with applicable laws. Thus, where law requires your consent, we will first ask for it.
- Information about you will be shared with Philip Morris Products S.A. (based in Neuchâtel, Switzerland), which is the place of central administration of personal data processing for Vectura Fertin Pharma affiliates. Philip Morris Products S.A. processes the information about you for all the purposes described in this notice.
- Information about you may be shared with the Vectura Fertin Pharma affiliate that is responsible for the country in which you live (if it wasn’t the Vectura Fertin Pharma affiliate that first collected the information) for all the purposes described in this notice.
- Information about you may be shared with any other Vectura Fertin Pharma affiliate that you contact (for example information on Vectura Fertin Pharma products) in order to enhance our service to you.
Details of Vectura Fertin Pharma affiliates and the countries in which they are established are available via our website.
Sharing data with Third Parties
- To the extent permitted by applicable law, we may share information about you with third parties who provide Vectura Fertin Pharma affiliates or you with products or services (such as advisers and information services providers).
- To the extent permitted by applicable law, we may share information about you with Vectura Fertin Pharma affiliates’ carefully selected third party business partners and advertisers (in line with the kind of thing you might associate with our products, for example because they have similar or complementary image, style, or functionality)
- We may share information about you with other third parties, where required or permitted by law, for example: regulatory authorities; government departments; in response to a request from law enforcement authorities or other government officials; when we consider disclosure to be necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; and in the context of organisational restructuring.
Country-specific additional points
According to which country you are in, we want you to be aware of some further points.
Where might information about you be sent?
As with any multinational organisation, we transfer information globally to our affiliates and service providers. Your data may therefore be transferred to other countries as part of our standard operations. Whenever we transfer your data abroad, we will limit access to your data only to those who need to see it, process your data in accordance with our internal data protection standards, protect it appropriately and only transfer information in compliance with applicable data privacy laws. When data is transferred, we will require the receiving party to keep your data confidential, delete it when it is no longer required and act in accordance with this privacy notice. Accordingly, information about you may be transferred outside of your jurisdiction. For example, if you live in the EU, EEA, UK, Australia or Japan, your data may be processed in another country.
When using information as described in this notice, information about you may be transferred either within or outside the country or territory where it was collected, including to a country or territory that may not have equivalent data protection standards.
For example, we and other Vectura Fertin Pharma affiliates within the EU and EEA may transfer personal information to Vectura Fertin Pharma affiliates, or to their service providers, outside the EU and EEA. In all such cases, the transfer will be:
- on the basis of a European Commission adequacy decision;
- subject to appropriate safeguards, for example the EU Standard Contractual Clauses or binding corporate rules; or
- with your consent or as necessary to discharge obligations under a contract between you and us (or the implementation of pre-contractual measures taken at your request) or for the conclusion or performance of a contract concluded in your interest between us and a third party, such as in relation to travel arrangements.
For transfers from the UK, in accordance with the UK GDPR and guidance of the Information Commissioner’s Office.
In all cases, appropriate security measures for the protection of personal information will be applied in those countries or territories, in accordance with applicable data protection laws.
Our service providers are located in many countries throughout the world, including in particular the EEA, Switzerland, the USA, Canada, India, the Philippines, Indonesia, and Australia.
How do we protect information about you?
We implement appropriate technical and organisational measures to protect personal information that we hold from unauthorised disclosure, use, alteration or destruction. Where appropriate, we use encryption and other technologies that can assist in securing the information you provide. We also require our service providers to comply with strict data privacy and security requirements.
How long will information about you be kept?
We will retain information about you for the period necessary to fulfil the purposes for which the information was collected in accordance with our internal data retention standards. After that, we will delete it. The period will vary depending on the purposes for which the information was collected. Note that in some circumstances, you have the right to request us to delete the information. Also, we are sometimes subject to legal obligations, legally obliged to retain the information, for example, for tax and accounting purposes, to either retain the information for a set minimum period of time, or to delete it after a set maximum period of time.
Typically, we retain data based on the criteria described in the table below. Where these periods conflict with legal obligations, for example, for tax and accounting purposes, to either retain the information for a set minimum period of time, or to delete it after a set maximum period of time, we apply those set periods instead.
Type |
Explanation/typical retention criteria |
market research |
If we use publicly available information about you in order to understand the market or your preferences, we will retain the information about you for a short period in order to perform the particular item of market research. If we collect information about you in other market research contexts, we will retain that information:
|
system audit and fraud prevention |
System audit logs are retained typically for a period of up to 6 months for system recovery and for up to 10 years for fraud prevention. |
business analytics |
We keep most business analytics data for the duration of our marketing relationship with you as described in the first line of this table above. However, some elements of it, such as some device information (if you choose to share it with us), naturally go out of date after a period of time, so we delete them automatically after defined periods as appropriate for the purpose for which we collected them. |
What rights and options do you have?
You may have some or all of the following rights in respect of information about you that we hold:
- request us to give you access to it;
- request us to rectify it, update it, or erase it;
- request us to restrict our using it, in certain circumstances;
- object to our using it, in certain circumstances;
- withdraw your consent to our using it;
- data portability, in certain circumstances;
- opt out from our using it for direct marketing; and
- lodge a complaint with the supervisory authority in your country (if there is one).
We offer you easy ways to exercise these rights, such as “unsubscribe” links, or giving you a contact address, in messages you receive.
Some mobile applications we offer might also send you push messages, for instance about new products or services. You can disable these messages through the settings in your phone or the application.
The rights you have depend on the laws of your country. If you are in the UK, European Union, European Economic Area, you will have the rights set out in the table below. If you are elsewhere, you can contact us (see the paragraph “who should you contact with questions?” at the end of this notice) to find out more.
Right in respect of the information about you that we hold |
Further detail (note: certain legal limits to all these rights apply) |
to request us to give you access to it |
This is confirmation of:
On your request we will provide you with a copy of the information about you that we use (provided this does not affect the rights and freedoms of others). |
to request us to rectify or update it |
This applies if the information we hold is inaccurate or incomplete. |
to request us to erase it and in some cases an extension of this right, the right to be forgotten |
This applies if:
|
to request us to restrict our processing of it |
This right applies, temporarily while we look into your case, if you:
(if you make use of your right in these cases, we will tell you before we use the information again). This right applies also if:
|
to object to our processing it |
If we use the information about you on the basis of legitimate interest you can object to our using it for those purposes, giving an explanation of your particular situation, and we will consider your objection. |
to withdraw your consent to our using it |
This applies if the legal basis on which we use the information about you is consent. These cases will be clear from the context. |
to data portability |
If: (i) you have provided data to us; and (ii) we use that data, by automated means, and on the basis either of your consent, then you have the right to receive the data back from us in a commonly used format, and the right to require us to transmit the data to someone else if it is technically feasible for us to do so. |
to lodge a complaint with the supervisory authority in your country |
If you have any complaint, we will welcome an opportunity to resolve it for you directly. Please consider contacting us via the contact details linked to at the start of this notice before contacting a supervisory authority. If you do wish to contact a supervisory authority, details are as follows:
If you are unsure who your jurisdiction’s supervisory authority is, please contact us using the details linked to at the top of this page.
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Who should you contact with questions?
If you have any questions, or wish to exercise any of your rights, you can find contact details for the relevant Vectura Fertin Pharma affiliate, and if applicable data protection officer, linked to at the top of this notice. Contact details will also be given in any communications that a Vectura Fertin Pharma affiliate sends you.
If your country has a data protection authority, you have a right to contact it with any questions or concerns. If the relevant Vectura Fertin Pharma affiliate cannot resolve your questions or concerns, you may also have the right to seek judicial remedy before a national court.
Changes to this notice
We may update this notice (and any supplemental privacy notice), from time to time. Where the law requires it, we will notify you of the changes; further, where the law requires it, we will also obtain your consent to the changes.
First drafted 2024.