General Privacy Statement
At F. Hoffmann-La Roche Ltd and all Roche’s subsidiaries, including Roche Thailand Ltd. (“Roche”), we are committed to protecting your personal data in accordance with the applicable data protection laws. This Privacy Notice outlines the types of personal data Roche may collect, the means by which Roche may collect, use, share and/or otherwise process your personal data; steps Roche takes to protect your personal data; and choices you are provided with respect to the use of your personal data. This Privacy Notice applies to Personal Data (as defined below) collected from Healthcare Professionals and Business Partners by Roche through different channels, including physical meetings, digital platforms or websites that link to this Privacy Notice or other sources as described below.
For the purposes of this Privacy Notice, “Personal Data” is any information by which you can be individually identified both directly and indirectly, including, but not limited to, your name, address, e-mail address, and telephone number.
Our processing activities described in this Privacy Notice are not designed or intended to collect Personal Data from children under the age of 20 unless explicitly advertised in the platform. We do not knowingly collect any Personal Data on this site from anyone under the age of 20 without the prior, verifiable consent of a parent or guardian. Such parent or guardian may have the right, upon request, to view the information provided by the child and require that it be deleted. Moreover, all minors should seek their parent’s or guardian’s permission prior to using or disclosing any Personal Data on this website or online resource
Identity and Contact Details of the Data Controller
The Data Controller is the Roche subsidiary or Roche’s appointed business partner based in the country in which you are resident. Please visit the list of Data Controllers for the identity and contact details of your Data Controller(s).
Categories of Personal Data processed
We may collect the following personal data:
Personal Details: includes your age, date of birth, gender, nationality, any other categories of Personal Data on the copy of your Thai national identification card and/or passport, photo, video and/or audio recording.
Contact Details: includes your full name, LINE ID or other data relating to the instant messaging applications on mobile or computer, personal email address, professional email address, office address, mobile phone number, office phone number, employing health care organization.
Professional Information: includes your biographical information (CV), professional society memberships, affiliations/profession, job title, secondary title, therapeutic area, qualifications or experience, education and scientific/medical activity, workplace, professional license number and picture (photo).
Financial/Transaction Information: includes your bank account number and details, credit card, customer account information, order history.
Transfer of Value: includes the nature, value, date of any financial/non-financial transfers to you by Roche.
Interaction Information: includes professional interactions between Roche and you, records of your collaborations, registration and participation in Roche’s event or related activity, clinical trials in which you served or are serving as an investigator.
Profile Data: includes information about your contact and product preferences, languages, marketing preferences, qualifications or experience, collaborations, publications, posts, demographic data, feedback and interest.
Technical and Usage Data: includes your online user ID, web server logs, IP address, geographic information, viewing data, other information regarding your usage and interactions with our websites, applications, emails, and advertisements.
The copy of Thai national identification card may contain Personal Data which is regarded as special categories of Personal Data under the personal data protection law, i.e. Personal Data pertaining to religious belief and/or blood type. Roche does not have any intention to collect nor process such special categories of Personal Data and therefore, before submitting any such document to Roche, please remove or redact such data. In the event that you did not remove or redact such special categories of Personal Data from the copy of your Thai national identification card, Roche reserves the right to perform such act on its own.
There are certain circumstances which you may provide Personal Data of other persons to Roche, whether via instant messaging applications, telephone calls, emails, website, RocheConnect or any other means - for example:
(a) when you choose to send a link or a message to a friend or colleague referring them to a Roche’s website or RocheConnect. In such case, the email addresses you may provide for a friend will be used to send your friend information on your behalf and will not be collected or used by Roche or other third parties for additional purposes.
(b) when you disclose Personal Data of your patients to us for medical treatment and research purposes.
In such circumstances, you shall represent and warrant that you have duly obtained consent or explicit consent, as the case may be, from such other persons, or that there is any other legal basis for you to disclose their Personal Data to Roche.
How and Why We Process Your Personal Data
Several places on our platforms require Personal Data if you choose to use them, including surveys, registration, and content sharing features (i.e., “E-mail to a Friend” links). Roche and its business partners collect this information about you only if you voluntarily provide it to us. Please be aware that certain features in our platform may not be available to you if you elect not to provide certain Personal Data. Any Personal Data you provide to us on our platform will be used in accordance with this Privacy Notice.
More Information on our Processing Activities
This table outlines each processing activity and provides information on the categories of information collected for each activity. Furthermore, this table defines the legal basis of processing for each of these processing activities.
Categories of Personal Data
Responding to Requests or Inquiries.
We may use the information that you provide to us to take the steps necessary to respond to your request, inquiries or concerns about Roche products and/or services, or other relevant information - for example, you may submit a medical information request, inquire about a product, subscribe to one of our mailing lists, or to create an account and/or profile in Roche’s portals or websites.
1) Contact Details
2) Professional Information
We collect and process the Personal Data based on Roche’s legitimate business purposes to respond to your request, inquiries or concerns.
If reporting is required, we may process the Personal Data to comply with our legal obligations.
Completing Transactions and fulfilling contractual obligations.
We may collect the Personal Data to fulfill services that you have requested, for example register for and use an account, to administer and manage your registration and participation at Roche’s events, to fulfill business relationships with you, including processing payments, notifying you of your order status and any associated order status issues.
These purposes also include the circumstances where you are engaged by Roche as a third party service provider – for example, speaker in the medical congress, events, meeting, sponsored programs, events and initiatives, workshops and seminars, academic activities, to conduct clinical trial study/research, and/or to administer and conduct consulting and service arrangements with Roche.
1) Personal Details
2) Contact Details
3) Professional Information
4) Financial/Transaction Information
This processing is necessary for the performance of a contract with you. If you fail to provide that data when requested, we may not be able to enter into a contract with you, or to perform our obligation under such contract, or we may need to cancel the order/contract requested by you.
To the extent that Roche processes your Personal Data to fulfill the contractual obligations with your employer, Roche will rely on our legitimate interests.
For the processing of payment or proceeding with your order, Roche may need to process your Personal Data in order to comply with our obligations under applicable tax and accounting laws.
Managing business relationships with you.
We collect and process Personal Data to facilitate Roche’s decision making when it comes to identifying suitable therapeutics area experts for its various medical/ and/or scientific engagements and collaborations (including speakers at internal or external medical educational and/or commercial events (including meetings or programs), advisory boards, training, etc.) or to prepare our meetings and interactions with you.
We may combine Personal Data you provide with other information collected through our websites and online resources, Roche’s offline records and information provided to us by third parties. This processing activity involves the creation of a profile about you to manage business relationships with you, for selecting the most appropriate therapeutic areas experts and to prepare the meetings and interactions with you. You can object to this processing activity at any time by using the contact details described in the list of Data Controllers. If you opt out for this processing activity, Roche won’t be able to have a consolidated view of your professional and scientific engagements and personalized our interactions with you. No automated decisions are made that would result in legal effects or similarly significantly affect.
1) Personal Details
2) Contact Details
3) Professional Information
4) Interaction Information
5) Profile Data
6) Technical and Usage Data
Generally, we collect and process the Personal Data on the basis of legitimate interest of Roche for selecting the most appropriate therapeutic areas experts for participating at Roche’s events, collaborations, meetings and related activities.
However, to the extent that we collect your Personal Data from other sources and combine such data with the data you have provided to us in order to create your profile, we will rely on your consent for the processing of said Personal Data.
Managing and personalizing communication with you
We collect and process your Personal Data to verify your username and password, to send you a welcoming email, website updates, information about Roche’s programs, products and services, notices regarding relevant medical conditions and treatment, or other information responsive to the data that you provide to us. These include the purposes of sending you both marketing and non-marketing materials which relating to Roche’s services and products, including any materials, news and updates on medical information and any other matters relating to the healthcare professional industry, and to update you on and invite you to medical congress, events, meeting, sponsored programs, events and initiatives, workshops and seminars.
We may communicate with you via post, phone, email, social media platforms or other channels.
We may combine Personal Data you provide with other information collected through our websites and online resources, Roche’s offline records and information provided to us by third parties. This processing activity involves the creation of a profile about you, your preferences, expertise, collaborations, and how you have interacted with us in the past in order to understand your interest, needs and preferences in our products and services so that we can best serve and communicate with you.
You can object to this processing activity at any time using the contact details described in the list of Data Controllers. If you opt out for this processing activity, Roche won’t be able to send you tailored information in line with your interests and preferences. No automated decisions are made that would result in legal effects or similarly significantly affect.
1) Contact Details
2) Professional Information
3) Interaction Information
4) Profile Data
5) Technical and Usage Data
For verifying your username and password, managing, personalizing and sending certain communication (e.g. direct marketing communication), Roche processes your Personal Data based on your consent or where permitted by applicable data protection laws based on Roche’s legitimate interest.
For personalizing communication with you, Roche processes the Personal Data based on your consent.
We may also collect and process your data to fulfill a contractual obligation.
Roche may be obligated to disclose transfers of value made to healthcare professionals and healthcare organizations, as may be advisable or required under applicable global, regional and local rules and regulations and best industry practices and standards.
1) Contact Details
2) Professional Information
3) Financial/Transaction Information
4) Transfer of Value
We collect and disclose your information for our legitimate interest to enhance transparency on interactions between the industry and healthcare professionals and healthcare organizations, or to comply with our transparency legal obligations.
In other cases, we will collect and process this information pursuant to your consent.
Tracking and Monitoring Adverse Events and Pharmacovigilance.
Some specified parts of our platform may collect Personal Data related to adverse events or other activities related to pharmacovigilance. This information is very important for public health and will be used for the detection, assessment, understanding, and prevention of adverse events or other medicine-related problems. For more information about how we use and disclose Personal Data for these purposes, please see Roche’s Privacy Notice for Pharmacovigilance, Medical Information, and Product Complaints published on Roche’s website.
1) Contact Details
2) Professional Information
We collect and process the Personal Data for these purposes to comply with our legal obligations and may be required to report the data to regulatory authorities.
To Run, Maintain and Improve our Websites, Platforms and Products.
We use this information to secure, maintain and improve our websites, network systems, and other assets.
1) Technical and Usage Data
We process this information based on our legitimate interests to run, maintain, secure and improve our websites, platforms, products and services as well as for troubleshooting, product and technology development purposes.
In the event that your Personal Data is required for the purposes of proceeding with your request to enter into a contractual relationship with us, or for the performance of contract, failure to provide your Personal Data under said circumstances may result in us being unable to enter into a contractual relationship with you, or unable to perform our contractual obligation, either in whole or in part – for example, Roche may not be able to make payment to you or proceed with your order.
In addition, in the event that your Personal Data is required for the purposes of performance of legal obligation, failure to provide Personal Data under said circumstance may result in Roche and/or you being in violation or non-compliance with the applicable law or regulation – for example, tax law.
Roche uses different methods and channel to collect personal data from you and about you including:
Directly from you;
Direct interactions with you, including information obtained from you through physical or virtual meetings, collaborations, services, feedback, requests, inquiries, surveys, etc.;
Automated information collected through our websites and online sources; and/or
Third parties or publicly available sources, including websites, social media networks, journals, and third party platforms.
Cookies, Web Beacons and Other Web Trackers
On certain webpages on our Website and/or RocheConnect or emails, Roche may utilize a common Internet technology called a “Web beacon” (also known as an “action tag” or “clear GIF technology”). Web beacons help analyze the effectiveness of websites by measuring, for example, the number of visitors to a site or how many visitors clicked on key elements of a site. Web beacons, cookies and other tracking technologies do not automatically obtain your Personal Data. Only if you voluntarily submit your Personal Data, such as by registering or sending e-mails, can these automatic tracking technologies be used to provide further information about your use of the Website or RocheConnect, and/or interactive e-mails to improve their usefulness to you.
Furthermore, our websites and online resources also collect other basic information about you which may not directly identify you, but which may correspond with you or a particular device. We use some of this information to allow our websites to run, as well as to learn more about how our websites and online resources are used and to otherwise improve and administer the site. We also use this information to enable us to deliver information tailored to your interests and preferences, based on your use of the site. For example, we may collect the IP Address assigned to your computer by your internet service provider. All computer identification on the Internet is conducted with IP addresses, which allow computers and servers to recognize and communicate with each other. Roche collects IP addresses to conduct system administration and report aggregate information to affiliates, business partners and/or vendors to conduct site analysis and website performance review. This address may change each time you connect to the internet (a “dynamic” IP address), or it may remain the same (a “static” IP address). In most cases, we ask for your consent before collecting this information, in which case you will be presented with a choice as to whether you wish to allow the collection and use of this type of information. Please see Roche’s Cookie Notice published on Roche's website.
Use of Data for Marketing
Information Sharing / Recipients of Personal Data
Recipients of your Personal Data
Roche may share the Personal Data with Roche’s subsidiaries around the world. Our Roche subsidiaries will use the Personal Data for the same purposes as the Data Controller does, for example to contact you for a potential collaboration or event. A list of Roche’s subsidiaries is available in the current “Roche finance report in the list of subsidiaries and associates section”, which can be found in the Investors section of www.roche.com.
Furthermore, we may also share the Personal Data with third parties, for the following purposes:
To F. Hoffmann-La Roche Ltd and other Roche’s subsidiaries for support and maintenance of our platforms and processing activities;
To IQVIA Ltd, 210 Pentonville Road, London N1 9JY, England, UK for IT support, maintenance and business continuity purposes.
To business partners: service providers, including market research agencies, events organizers, or other third parties who provide certain services to Roche;
To cloud providers or services provider for storing purposes and to conduct technical maintenance of our platform and other web platforms;
To communication providers, including marketing platforms, electronic communication providers, social media platforms in order to send you relevant information and communicate with you;
To facilitate a merger, consolidation, transfer of control or other corporate reorganization in which Roche participates, or pursuant to a financial arrangement undertaken by Roche;
To respond to appropriate requests of legitimate government authorities, or where required by applicable laws, court orders, or government regulations; and
Where needed for corporate audits or to investigate or respond to a complaint or security threat.
International Transfers of the Personal Data
Roche may transfer the Personal Data in a geographic region that imposes different privacy obligations than your country of origin (e.g. United States and India). This means that your Personal Data may be sent to a country with less restrictive data protection laws than your own. Any such transfer will be conducted in compliance with applicable laws.
Retention / Storage Period of Your Personal Data
The length of time in which we will store your Personal Data will differ depending on the purpose for which we have collected and are processing your data. In most cases, we will keep the data for three (3) years following our last interaction with you. However, in the event that there is a contract between you and Roche, we will generally retain your Personal Data throughout a contract term. We may, however, maintain your data for a longer period of time as we deem necessary and/or if we are required by law to maintain your data, e.g. due to tax law or accounting requirements.
Information About Your Rights Regarding Your Personal Data
You may have certain rights regarding our use and processing of your Personal Data.
If data processing is based on consent, note that you have the right to withdraw your consent at any time unless applicable laws or regulations or judicial requirements require otherwise. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal. In order to withdraw your consent you can either use the mechanism as individually explained when we asked for your consent or in any case send an email to the Data Controller as indicated in the list of Data Controllers (link).
Your rights in accordance with applicable laws
If your Personal Data are covered by the Personal Data Protection Act B.E. 2562 (2019) (“PDPA”), you, subject to the limitations and conditions of the PDPA, are entitled to the following rights with respect to your Personal Data Subject to the limitations and conditions of the, you are entitled to the following rights with respect to your Personal Data:
The right to request access to Personal Data that Roche has about you and to obtain a copy of such Personal Data;
The right to request the disclosure of how your Personal Data has been acquired without your consent;
The right to request to have your Personal Data in a format which is generally readable and usable by automatic tools or machines, and to have your Personal Data in said format transmitted to another data controller(s);
The right to object to the processing of your Personal Data, particularly where your Personal Data is processed for the direct marketing purposes;
The right to erasure or de-identification of your Personal Data under certain circumstances – for example, when it is no longer needed for the purposes for which it has been collected;
The right to request that the use of your Personal Data be suspended under certain circumstances; and
The right to rectify, correct, update or complete your Personal Data.
If you have any questions regarding the rights to your Personal Data or wish to exercise any of these rights, please contact our Data Protection Officer at [email protected] or, where applicable, using RocheConnect to update your profile (if you already have your account).
In the event that you believe that our processing of your Personal Data does not comply with the PDPA, you are entitled to lodge a complaint with the Office of Personal Data Protection Committee.
Updates to This Privacy Notice
From time to time, we may revise this Privacy Notice. Any such changes to this Privacy Notice will be reflected on this page. Roche recommends that you review this Privacy Notice regularly for any changes. The date on which this notice was last revised is located at the top of this Privacy Notice.
Last Revised: January 19, 2023
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Updated newly released international medical information;
Roche’s innovative research release;
Scientific, Roche’s products and services information;
Personalized research and publication request (with limitation by publication right of use);
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Educational material that improves patient understanding; and
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